UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2IOO RENAISSANCE BOULEVARD, SUITE IOO

KING OF PRUSSIA. PENNSYLVANIA 19406-27 13

August 9,2013

Mr. Kevin Walsh

Site Vice President

Seabrook Nuclear Power Plant

NextEra Energy Seabrook, LLC

c/o Mr. Michael Ossing

P.O. Box 300

Seabrook, NH 03874

SUBJECT: SEABROOK STATION, UNIT NO. 1 - CONFIRMATORY ACTION LETTER

FOLLOW-UP INSPECTION - NRC INSPECTION REPORT O5OOO443/2012010

Dear Mr. Walsh:

On June 27,2013, the U. S. Nuclear Regulatory Commission (NRC) completed a team

inspection at Seabrook Station, Unit No. 1. The enclosed inspection report documents the

inspection results, which were discussed with you and other members of your staff.

The team inspection examined activities conducted under your license as they relate to safety

and compliance with the Commission's rules and regulations and with the conditions of your

license. Specifically, the team reviewed selected procedures and records, observed activities,

and interviewed station personnel regarding the adequacy of NextEra's actions to address the

impact of Alkali-Silica Reaction (ASR) on reinforced concrete structures. The team reviewed

selected Confirmatory Action Letter (CAL) 1-2012-002 commitments for adequacy and closure.

The NRC determined that the eleven actions committed to in the CAL have been satisfactorily

completed. The team independently verified that NextEra had appropriately assessed and

determined that allASR-affected structures remain operable. The team also confirmed that

your root cause evaluation was thorough and identified appropriate corrective actions.

Many important corrective actions necessary to resolve this issue are currently in progress and

related commitments are documented in your ASR Project Corrective Action Program. These

actions include your planned two-year test program of ASR-affected large scale concrete

specimens at the University of Texas, Ferguson Structural Engineering Laboratory (FSEL).

Therefore, while our review of the CAL items was completed during this inspection, the NRC will

continue to provide oversight of both NextEra's testing program at the FSEL and onsite ASRrelated activities. The NRC is in the process of evaluating the technical inspection results

discussed in this report to inform our future regulatory decision regarding the status of the CAL.

The results of our evaluation will be provided to NextEra in a future correspondence.
K. Walsh 2

lt should be noted that the inspection team results are based solely on Title 10 of the Code of

Federal Regulations (10 CFR) Part 50 requirements. The NRC is currently in the process of

conducting a separate review of the ASR issue as part of the license renewal process in

accordance with 10 CFR Part 54. As such, certain aspects of the ASR issue discussed may

also have applicability to the license renewal review and require additional consideration and

information beyond that discussed in this report.

In accordance with 10 CFR 2.390 of the NRCs "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 (PARS) component of the

NRC's document system (ADAMS). ADAMS is accessible from the NRC website at

http://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

l, t'^-

Division of Reactor Safety

Docket No. 50-443

License No: NPF-86

Enclosures:

1. lnspection Report No. 0500044312012010

w/ Attachment: Supplemental Information

2. Confirmatory Action Letter 1-2012-002

3. Revision to Confirmatory Action Letter 1-2012-002

cc w/encl: Distribution via ListServ

Enclosure
K. Walsh 2

It should be noted that the inspection team results are based solely on Title 10 of the Code of

Federal Regulations (10 CFR) Part 50 requirements. The NRC is currently in the process of

conducting a separate review of the ASR issue as part of the license renewal process in

accordance with 10 CFR Part 54. As such, certain aspects of the ASR issue discussed may

also have applicability to the license renewal review and require additional consideration and

information beyond that discussed in this report.

ln accordance with 10 CFR 2.390 of the NRCs "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 (PARS) component of the

NRC's document system (ADAMS). ADAMS is accessible from the NRC website at

http://www.nrc.sov/readino-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RN

Raymond K. Lorson, Director

Division of Reactor Safety

Docket No. 50-443

License No: NPF-86

Enclosures:

1. f nspection Report No. 0500044312012010

w1 Attachment: Supplemental lnformation

2. Confirmatory Action Letter 1-2012-002

3. Revision to Confirmatory Action Letter 1-2012-002

cc w/encl: Distribution via ListServ

Distribution Mencl:

W. Dean, RA

D. Lew, DRA

D. Roberts, DRP

M. Scott, DRP

A. Burritt, DRP

R. Lorson, DRS

J. Rogge, DRS

G. Dentel. DRP

R. Barkley, DRP

P. Cataldo, DRP, SRI

M. Jennerich, DRP, Rl

A. Cass, DRP, Resident OA

RidsNrrPMSeabrook Resource

V. Campbell, Rl, OEDO

Rids N rrDorlLpll -2 Resou rce

ROPreports Resource

DOCUMENT NAME: G:\DRS\Seabrook Concrete\CAl Closure Report 2012010\lR 2012-010 FINAL 8-01-13.docx

ADAMS Accession No.: ML13221A'172

g SUNS|Review

g Non€ensitive

tr Sensitive

g

tr

Publicly Available

Non-Publicly Available

OFFICE RUDRS RYDRP RI/DRS RI/DRS

NAME WCook GDentel JTrappl RLorson/

DATE 08/09/1 3 08107113 08/09/13 08/09/2013

OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-443

License No.: NPF-86

Report No.: 05000443/2012010

Licensee: NextEra Energy Seabrook, LLC

Facility: Seabrook Station, Unit No. 1

Location: Seabrook, New Hampshire 03874

Dates: November 3,2012 to June 27 ,2013

Inspectors: W. Cook, Team Leader, Division of Reactor Safety (DRS)

S. Chaudhary, Reactor Inspector, DRS

W. Raymond, Senior Resident lnspector

A. Buford, Structural Engineer, Division of License Renewal (DLR),

Office of Nuclear Reactor Regulation (NRR)

G. Thomas, Structural Engineer, Division of Engineering, NRR

A. Sheikh, Senior Structural Engineer, DLR, NRR

N. Floyd, Reactor Inspector, DRS

Approved by: James Trapp, Chief, Engineering Branch 1

Division of Reactor Safety

Enclosure
SUMMARY OF FINDINGS

1R 0500044312012010i 1110312012 - 0612712013; Seabrook Station, Unit No. 1; Confirmatory

Action Letter (CAL) Follow-up lnspection Report.

This report covered several weeks of onsite inspection at Seabrook Station, two weeks of

inspection at the Ferguson Structural Engineering Laboratory (FSEL) University of Texas -

Austin, and periodic in-office reviews, over the past eight months, by region-based inspectors

and headquarters reviewers to assess the adequacy of NextEra's actions to address the impact

of Alkali-Silica Reaction (ASR) on reinforced concrete structures at Seabrook Station. The

NRC's program for overseeing the safe operation of commercial nuclear power reactors is

described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Cornerstone: Mitigating Systems

During this second CAL follow-up inspection, the team examined the remaining six

commitments documented in CAL No. 1-2012-002, dated May 16, 2012. The CAL items

reviewed and closed during this inspection were 2, 4,7,8, 9 and 1 1. In addition, a number of

observations documented in the first CAL follow-up inspection (NRC Inspection Report

05000443/2012009, Section 9.0) were reviewed and closed in this report. Closure of CAL

Item 7 was administrative, in that, NextEra had withdrawn this commitment by letter dated

December 13,2012 (ML12362A323). NextEra's revision to this commitment was approved by

the NRC as documented in the CAL revision letter, dated January 14,2013 (ML13014A555).

The review and closure of each CAL item signifies the NRC's satisfactory assessment of

NextEra's commitments and planned corrective actions to address the ASR non-conforming

condition at Seabrook Station. However, the completion of the CAL follow-up inspections does

not represent the completion of NRC review and oversight of NextEra's actions to address the

ASR issue. As discussed in the team's review of CAL ltem 4 and the revised ASR Project

Corrective Action Plan (CAP), NextEra has planned a number of ongoing activities, in addition

to the FSEL testing program, to address ASR-affected structures.

NextEra's root cause evaluation (CAL ltem 2) appropriately identified the significant causal and

contributing factors resulting in ASR impacting reinforced concrete structures at Seabrook

Station. NextEra's ASR Project CAP (CAL ltem 4), provided in a letter to the NRC

(ML131514328), sufficiently captures the corrective actions taken and planned to address the

ASR non-conforming condition and will remain in place to track the resolution of ASR at

Seabrook Station.

The Mortar Bar Testing (CAL ltem 6, reference NRC Inspection Report 05000443/2012009) was

successfully completed, and the results indicated sufficient reactive silica and alkali in the

Seabrook structures to allow the progression of ASR for the foreseeable future. Consequently,

NextEra withdrew its commitment for Prism Testing (CAL ltem 7), and the NRC staff

administratively closed this commitment. The team reviewed NextEra's large specimen testing

program technical specifications (CAL ltem 8) and anchor testing program description (CAL

Item 11) and concluded that these programs were sufficiently developed and described to

support an understanding of the testing plans and objectives.

Enclosure
NextEra implemented a number of enhancements to the Structures Monitoring Program (CAL

Item 9) to adequately monitor the progression of ASR. The team concluded these monitoring

actions were consistent with currently available industry practices.

Lastly, the team completed a follow-up and review of a number of observations discussed in the

first CAL Follow-up Inspection Report, including: pending structural evaluations; containment

prompt operability determination (POD) observations; core sample material property testing;

quantification of pre-stressing effects of ASR expansion; additional rebar examinations; crack

indexing use in the SMP; and the Phase 3 walkdown plans and schedule.

iii Enclosure
REPORT DETAILS

1.0 Background

Alkali-silica Reaction (ASR) is a chemical reaction occurring in hardened concrete that can

change the physical properties of concrete and affect structural performance. In June 2009,

NextEra identified potential degradation in below-grade concrete structures at Seabrook. In

August 2010, NextEra completed petrographic evaluation of concrete core samples, which

confirmed ASR as the degradation mechanism. The degraded condition in numerous Seabrook

Category | structures was evaluated in the Corrective Action Program, and prompt operability

determinations (PODs) were performed. NextEra revised the PODs as new information became

available and improved analytical techniques were incorporated.

NextEra initially used the results of mechanical testing of concrete core samples to assess the

degree of structural degradation due to ASR. This is a traditional method described in American

Concrete Institute (ACl) 228.1R, "ln-Place Methods to Estimate Concrete Strength," for

assessing existing concrete structures. NextEra tested the cores for compressive strength and

elastic modulus. NextEra used the methods defined in construction and design code

ACI 318-1971, "Building Code Requirements for Reinforced Concrete," to evaluate the structural

capacity (operability) of the ASR-affected structures. However, the mathematical relationships

in ACI-318 are based on empirical data from testing of non-degraded concrete, and these

relationships may not be valid for ASR-affected concrete.

After further review of industry experience and literature pertaining to ASR, NextEra engineering

concluded that the core test data was not indicative of structural performance of ASR-affected

reinforced concrete structures. NextEra's engineering evaluation stated that once the cores are

removed from the structure, concrete core samples are no longer subject to the strains imposed

by the ASR-related expansion or restraints imposed by the steel reinforcing cage. The

engineering evaluation also stated that confinement provided by steel reinforcing bars (rebar)

and other restraints limit ASR expansion of the concrete within the structure and thereby limit

the adverse impact on structural performance. Therefore NextEra engineering concluded that

the reduction of mechanical properties observed in mechanical testing of cores was not

representative of in-situ concrete performance. Based on this conclusion, NextEra suspended

taking core samples to evaluate the concrete mechanical properties of structures impacted by

ASR and revised the operability assessment approach. NextEra's current approach for

assessing structural integrity and operability is to compare available design margins to an

assumed reduction in structural capacity due to ASR.

NextEra's operability evaluations were based upon an examination of available design margins

and a presumed ASR-caused reduction in structural design capacities. The details of this

methodology and related assumptions were developed in NextEra's Interim Assessment

(FP 100716). The assessment assumed lower-bound values of structural capacity for

ASR-affected concrete for limit states based on research test data, primarily from small-scale

test specimens. The assessment focused on the structural limit states that are the most

sensitive to ASR effects (i.e., out-of-plane shear capacity, lap splice development length, and

anchorage capacity). The assessment determined that even after applying lower-bound values

to structural limit states to assume ASR effects, the structures were suitable for continued

service. A final operability assessment will be conducted by NextEra following evaluation of

Enclosure
2

structural performance based on a proposed large-scale testing program of beam specimens

representative of Seabrook reinforced concrete structures. The test program has been initiated

at the Ferguson Structural Engineering Laboratory at the University of Texas at Austin (UT-A),

with sometesting (anchors) commenced in 2013 and large beam testing scheduled to be

completed by 2A15. Based upon the slow progression of the ASR expansion, the cunent

operability evaluations, coupled with the Structures Monitoring Program six-month combined

crack indexing, provide reasonable assurance of continued structural operability.

2.0 Confirmatory Action Letter 1-2012-002

Confirmatory Action Letter 1-2012-002, dated May 16, 2012, was written to confirm

commitments by NextEra (established during a meeting with NRC management and staff on

April 23, 2012) with regard to planned actions to evaluate ASR-affected reinforced concrete

structures at Seabrook Station. ln response to the CAL, NextEra committed to provide

information to the NRC staff to assess the adequacy of NextEra's corrective actions to address

this significant condition adverse to quality. CAL 1-2012-002 and the revision to the CAL are

provided as an Enclosure to this report. The NRC staff also formed a working group to provide

appropriate oversight of NextEra's activities to address ASR and to coordinate NRC inspection

and review activities. The ASR Working Group Charter (ML121250588) outlines the regulatory

framework and general acceptance criterion for NRC oversight and review of this issue. As

documented in NRC Inspection Report No. 0500044312012009, dated December 3,2012

(ML12338A283), CAL ltems 1, 3, 5, 6, and 10 were closed. Based on the results of this

inspection, the remaining six CAL ltems 2,4,7,8, 9, and 11 are closed.

3.0 Review of Alkali-Silica Reaction Root Cause Evaluation (CAL ltem 2)

Inspection Scope

As documented in lnspection Report No. 0500044312012009, the team reviewed NextEra's

response to CAL ltem 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."

The licensee submitted its root cause evaluation (RCE) in a letter to the NRC dated May 24,

2012 (ML12151A396). Based upon the team's initial review, the inspectors concluded that the

second root cause identified was not sufficiently characterized in NextEra's May 24,2012,

submittal. Specifically, NextEra did not clearly describe the performance and organizational

factors that contributed to inadequacies in the Structures Monitoring Program (SMP) and the

failure of the Seabrook staff to have identified ASR degradation of reinforced concrete

structures sooner. The team discussed this observation with the responsible Seabrook staff.

NextEra determined that a revision to the RCE was warranted and revised the RCE to more

appropriately develop and characterize this second root cause and the associated corrective

actions.
3

NextEra submitted a revised RCE summary for NRC review in a letter dated May 1, 2013

(ML13151A328, Enclosure 1). The team reviewed the revised RCE summary for clarity and

appropriateness of associated corrective actions, consistent with guidance outlined in 10CFR50,

Appendix B, Criterion XVl, "Corrective Action," and NextEra's Corrective Action Program.

Findinqs and Observations

The team identified no findings. Based upon the team's review, CAL ltem 2 is closed.

As documented in Enclosure 1 to the May 1 ,2013letter, NextEra summarized the two root

causes as follows: RC1 - the ASR developed because the concrete mix design unknowingly

utilized a coarse aggregate that would, in the longterm, contribute to ASR. Although the testing

was conducted in accordance with American Society for Testing and Materials (ASTM)

standards, those testing standards were subsequently identified as limited in their ability to

predict slow reacting aggregate that produced ASR in the long-term; and RC2 - based on the

long-standing organizational belief that ASR was not a credible failure mode due to the concrete

mix design, dispositions for condition reports involving groundwater intrusion or concrete

degradation, along with the structures health monitoring program, did not consider the possibility

of ASR development. ln addition, NextEra identified a contributing cause that its organization

did not prioritize groundwater elimination or mitigation, resulting in more concrete area exposed

to moisture.

The team verified that NextEra had appropriately identified the root cause(s). The ASTM

concrete aggregate testing standards in effect at the time of plant construction were properly

implemented, but later determined to be ineffective in identifying slow-reacting, ASR-susceptible

aggregates. Those standards were subsequently revised by the industry and adopted by

NextEra to prevent recurrence. NextEra's RCE concluded that the Structures Monitoring

Program did not remain current with concrete industry operating experience and associated

failure modes, such as ASR. Contributing to the shortcomings of the SMP in not identifying this

concrete degradation mechanism earlier was the "organizational mindset" that the groundwater

in-leakage was an operational nuisance and nothing more. Consequently, station and

engineering staffs were insensitive to the potential detrimental effects of the groundwater

infiltration and did not assess the long{erm impact on station structures. NextEra's

implementation of a broad periodic review process to ensure all systems and component

monitoring programs remain current and effective was determined by the team to be an

appropriate corrective action for this causal factor.

4.0 Integrated Corrective Action Plan (CAL ltem 4)

Inspection Scope

CAL No. 1-2012-002 documented NextEra's commitment to submit, by June 8,2012, a

corrective action plan for the continued assessment of ASR in concrete structures at Seabrook

Station, including development of remedial actions to mitigate the effects of ASR where

Enclosure
4

warranted. By letter dated June 8, 2012 (ML12171A227), NextEra submitted its integrated

corrective action plan (CAP) for NRC review. The CAP outlined the major elements of

diagnosis, evaluation, prognosis and mitigation of ASR-affected structures as understood at the

time. Since June 8,2012, NextEra has made considerable progress in refining the elements of

this plan, implementing the initial phases, and more clearly defining and focusing future actions.

NextEra provided an updated ASR Project CAP in a letter dated May 1 , 2013 (M113151A328,

Enclosure 2) to document these plan changes.

During this inspection period, the team conducted numerous discussions, meetings, and

conference calls with NextEra, as well as onsite inspections at both Seabrook Station and UTAustin to review NextEra's actions to address the ASR-affected reinforced concrete structures.

From these interactions, the CAP has developed greater clarity of the necessary steps

(corrective actions) to address this non-conforming condition impacting safety-related reinforced

concrete structures. As previously documented in Inspection Report 05000443/2012009 and

detailed in other sections of this report, the team assessed the adequacy of completed and

ongoing ASR-related activities identified in the integrated CAP, consistent with guidance

outlined in 10CFR50, Appendix B, Criterion XVl, "Corrective Action," and NextEra's Quality

Assurance Program.

Findinqs and Observations

The team identified no findings. Based upon the team's review, CAL ltem 4 is closed.

NextEra's ASR project staff stated that they plan to maintain the ASR Project CAP as a "living

document" and will update it periodically to capture completion of activities and add new actions,

as appropriate.

5.0 Prism Testing Commitment Withdrawn (CAL ltem 7)

Inspection Scope

CAL ltem 7 committed NextEra to "Complete longterm aggregate expansion testing (ASTM

C 1293, Concrete Prism Test) by June 30, 2013." The purpose of this CAL item was to

determine, in conjunction with the Mortar Bar Testing (CAL ltem 6), if the coarse aggregate

contributing to ASR in Seabrook reinforced concrete still contained sufficient reactive silica for

the alkali-silica reaction to continue long-term under the existihg environmental conditions.

Alternatively, these tests could demonstrate that the progression of ASR at Seabrook could be

self-limiting due to the depletion of reactive silica in the concrete. The Prism Test (as defined by

ASTM C1293) involves monitoring the expansion (by measurement of specimen elongation due

to ASR) of the test specimen (a molded concrete brick approximately 3 by 5 by 12 inches in

length) over a one-year period. Expansion in excess of 0.04o/o is considered potentially

deleterious and a positive test for slow-reactive aggregate. The Prism Test is similar to the

Mortar Bar Test (reference ASTM C1260), but has a duration of 14 days and an expansion limit

of 0.1o/o.

Enclosure
5

Based upon the results of the completed Mortar Bar Expansion Testing (reference NRC

lnspection Report No. 0500044312012009, Section 5.0), NextEra concluded that the available

quantities of silica in the concrete would not be depleted in the near term and that additional

confirmatory testing via the Prism Test method was not warranted. NextEra ran the Mortar Bar

Test several weeks beyond the 14-day test (terminated after 103 days) and observed that the

alkali-silica reaction was still progressing at the conclusion of the test, indicating the presence of

sufficiently reactive aggregate to maintain ASR for a longer period of time. The team noted that

the Mortar Bar Test involved the reuse of aggregates from Seabrook test cores (concrete that

had already experienced appreciable ASR) and similar aggregate from concrete not affected by

ASR. The side-by-side comparison of the test specimens showed no appreciable difference in

ASR progression or observed expansion rates. Accordingly, NextEra concluded the Prism Test

would add no significant knowledge to the condition assessment of Seabrook concrete.

NextEra concluded that all Seabrook reinforced structures are or may be affected by ASR,

unless specifically ruled out by further analysis, such as petrographic examination. By letter

dated December 13,2Q12, NextEra requested that CAL ltem 7 be deleted. As documented in

NRC letter dated January 14,2013 (ML13014A555), the NRC accepted NextEra's technical

basis for deleting CAL ltem 7.

Findinqs and Observations

No findings were identified. CAL ltem 7 is administratively closed.

6.0 Review of Technical Details of Large Specimen Testing Program (CAL ltem 8)

lnspection Scope

CAL ltem 8 committed NextEra to "Submit the technical details of the testing planned at the

contracted research and development facility by June 30,2012." By letter dated June 21 ,2012

(ML12179A281), NextEra submitted the Shear and Lap Splice Testing overview prepared by the

Ferguson Structural Engineering Laboratory (FSEL) at the University of Texas at Austin, dated

March 15, 2012. The purpose of the test program, as described in the FSEL document, is to

provide sufficient data and insights to establish the current and future implications of ASR on

Seabrook reinforced concrete structures. Since there is limited available literature or test data

relative to the impact of ASR on walls without transverse shear reinforcements (i.e., the majority

of Seabrook ASR-affected structures), destructive testing of ASR-affected test specimens is

being conducted to evaluate the impact of ASR on out-of-plane shear strength and lap splice

development. The test specimens being prepared at FSEL will be of representative scale and

design such that the test results may be correlated to Seabrook structures.

The team reviewed the June 21,2012, submittal and conducted a conference call on

December 18,2012, with the NextEra and UT-Austin FSEL staff to discuss the merits of the

proposed test program. Based upon the complexity of the information discussed and follow-up

inspection activities, NextEra prepared a test program overview document and a detailed test

Enclosure
6

specification to supplement the June 21 , 2012, CAL response letter. By letter dated May 1,

2013 (ML13151A328 redacted and M113151A291 un-redacted), NextEra provided the NRC

with the "seabrook Station - Specification for Shear and Reinforcement Anchorage Testing of

ASR-Affected Reinforced Concrete," (Enclosures 3 & 4) and "Approach for Shear and

Reinforcement Testing of Concrete Affected by Alkali Silica Reaction," (Enclosure 5 & 6). Each

of these documents has a proprietary and non-proprietary version.

The team reviewed the revised testing specification and the associated overview document to

verify that the overall test program approach and application of test results would reasonably

address the Seabrook ASR-affected concrete non-conforming condition. The team discussed

the test program with the FSEL, MPR and responsible NextEra engineering staffs.

Findinqs and Observations

No findings were identified. Based upon team review of the submitted testing program

documents and related inspection activities, the team concluded that NextEra has provided an

appropriate level of detail of the proposed large-scale specimen testing program, and CAL ltem

8 is closed.

As documented in NextEra's ASR Project CAP (ML 13151A328, Enclosure 2), and assuming

satisfactory outcomes, the acceptance of the testing results to resolve ASR concerns

associated with design basis structural calculations may follow the regulatory process for

approval and would include evaluations pursuant to 10CFR50.59 and 10CFR50.90. The

submitted test plans satisfy NextEra's commitment to explain the scope and depth of the largescale specimen testing program,

7.0 Review of Structures Monitoring Program (CAL ltem 9)

Inspection Scope

CAL ltem 9 committed NextEra to implement an update to the Maintenance Rule (10CFR50.65)

Structures Monitoring Program (SMP) to include monitoring requirements for selected locations

in areas that exhibit ASR by July 15, 2012. NextEra issued Revision 2 to Structural Engineering

Standard 36180, "Structural Monitoring Program," effective July 12,2012. The primary changes

incorporated in Revision 2 to the SMP were: 1) performing periodic (every six months) crack

indexing measurements at 26 locations to collect quantitative information on the progression of

ASR expansion/degradation; 2) establishing crack width (1.0 mm or greater) and Combined

Crack lndex (1.0 mm/m or greater) thresholds for conducting structural evaluations (reference

Foreign Print 100716, Seabrook Station: lmpact of ASR on Concrete Structures and

Attachments); and 3) the addition of Federal Highway Administration (FHWA) document FHWAHIF-09-004, "Report on the Diagnosis, Prognosis, and Mitigation of Alkali-Silica Reaction in

Transportation Structures," dated January 2010, as a reference.

Enclosure
7

The team reviewed the adequacy of these changes to the SMP to monitor ASR in Seabrook

reinforced concrete structures. While not endorsed by the NRC or committed to by NextEra in

Seabrook's licensing basis, the team used the American Concrete lnstitute (ACl) Committee

Report 349.3R-96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures," as a

reference to assess the adequacy of the revisions made to the SMP for monitoring the

progression of ASR.

Based in part on NRC observations, NextEra issued Revision 3 to the SMP on April 30, 2013.

The SMP enhancements are: 1) the addition of periodic (every 30 months) combined crack

indexing (CCl) measurements at 72 discrete locations identified as Tier ll (Acceptable with

Deficiency) areas (CCl values between 0.5 mm/m and 1.0 mm/m, or crack widths greater than

0,2 mm, but less than 1.0 mm) to collect quantitative information on the progression of ASR

expansion/degradation (this monitoring was being performed, but not documented in the SMP);

and, 2) inclusion of the periodic groundwater sampling program for monitoring of chemical

attributes detrimental to concrete structures. During a follow-up discussion with the NextEra

staff, the team noted that NextEra is considering additional SMP revisions, dependent upon the

results of the large specimen test program and further engineering evaluation. One of the

revisions involves the installation of deep pins for monitoring of expansion in the out-of-plane

direction (reference NextEra's May 1 ,2013, Response to Confirmatory Action Letter

(M113151A328) Enclosure 2, ASR Project Corrective Action Plan).

Findinos and Observations

The team identified no findings in this area. CAL ltem 9 is closed.

The team noted that changes made to the SMP to address ASR were generally consistent with

the evaluation and monitoring methods outlined in ACI 349.3R-96. The team confirmed that

NextEra had incorporated a three-tiered visual inspection criteria, as outlined in Sections 5.1

through 5.3 of ACI 349.3R-96. NextEra has also augmented this visual inspection criteria with

periodic (six-month and 3O-month interval) CCI measurements and associated structural

evaluation thresholds based upon direct measurement (CCl) results. The CCI monitoring,

performed at 98 selected locations (including containment), was implemented by NextEra based

upon this method being a readily measurable indicator of ASR-related progression and based,

in part, upon endorsement by FHWA as outlined in FHWA-HIF-09-004.

The crack growth monitoring provides a visual indication of the progression of ASR within a

reinforced concrete structure, The relative width and number of visible cracks may be

correlated to the overall progression of ASR and may be used to evaluate ASR impact on

structural performance. However, ASR cracking and crack propagation is closely associated

with the specific reinforcement design and structural loading. Accordingly, the adequacy of CCI

measurement as a long-term structures monitoring methodology for Seabrook structures is

being further evaluated by NextEra as part of the UT-Austin FSEL testing program. The results

of the UT-Austin testing program are intended to be used to validate this methodology for

application at Seabrook.

Enclosure
8

With respect to the evaluation of infiltration water chemistry and groundwater monitoring, ACI

349.3R-96 discusses environmental monitoring and related effects of aggressive water

chemistry, including the potentialfor leaching. Accordingly, NextEra has integrated the periodic

monitoring of groundwater chemistry into the SMP (reference Revision 3, dated 413012013,

Attachment 4). NextEra plans to investigate the expansion of the water chemistry monitoring

program (reference AR No. 1758920-40) to include periodic analysis of infiltrated water (i.e.,

water that has migrated through below-grade reinforced concrete walls). The establishment of

an initial baseline analysis and continued periodic monitoring could provide some relative trend

data for further evaluation and follow-up actions, as appropriate.

The team concluded that the implemented and planned SMP enhancements provide NextEra

with an improved program to assess the extent and degree of ASR progression and to more

thoroughly monitor the environmentalfactors contributing to ASR. NextEra's initial SMP

revision (Revision 2) was adequate; however, the SMP Revision 3 enhancements include

multiple activities that are more closely aligned with ACI 349.3R guidance.

8.0 Review of Anchor Testing Program (CAL ltem 11)

lnspection Scope

The micro-cracking caused by ASR may adversely impact the structural capacity of anchors that

support safety-related piping, cable trays and other components. NextEra's initial operability

determinations were supported by anchor performance testing conducted on available ASRdegraded specimens previously fabricated at or obtained by FSEL, UT-Austin (reference FP

100718). As documented in lnspection Report 05000443/2012009, the initialtesting

demonstrated satisfactory performance of the anchors in ASR-affected concrete during the

earlier stages of ASR progression. NextEra's evaluation also stated that the eventual reduction

in capacity due to ASR was sufficiently offset by established anchor manufacturer's design

margins (FP 100716). However, based upon the limitations of the testing performed (on ASRaffected test specimens of different composition and compressive strength than Seabrook

reinforced concrete structures), NextEra planned to conduct additionaltesting. The planned

testing involves anchors installed (both during specimen fabrication and post-fabrication) in

ASR-affected test specimens that more closely replicate the reinforced concrete structures and

anchor configurations at Seabrook.

By licensee letter dated December 13, 2012 (ML123624323), NextEra requested a revision to

CAL ltem 11 to address a schedule challenge to the targeted anchor testing program

completion date. NextEra also proposed redefining CAL ltem 11 to be consistent with the

wording of CAL ltem 8, regarding large-scale specimen testing. Specifically, NextEra revised its

commitment to read, "Submit technical details of the anchor test program planned at the

contracted research and development facility by February 28,2413." The original commitment

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

review approximately 30 days after testing is complete." Based upon unexpected specimen

fabrication delays and the slow progression of accelerated ASR aging, NextEra identified that it

would not be possible to complete the anchor testing per the original commitment date.

Enclosure
9

The NRC accepted NextEra's revised commitment, as documented in NRC letter dated

January 1 4, 2013 (ML1 301 4A555).

The team reviewed the details and adequacy of NextEra's anchor testing program as outlined in

the proprietary "Anchor Testing Program Overview," dated February 26,2013. The anchor

testing program overview and associated testing specifications were docketed for NRC review

via NextEra letter dated February 28,2013 (ML13088A218 redacted and ML13088A229 unredacted, dated March 15,2013). The technical overview document and accompanying

specifications outline the major elements of the proposed anchor testing program, including the

key attributes of the fabrication of the test specimens, monitoring of the specimens as

accelerated ASR aging progresses, and the details of the testing of individual anchor bolt

configurations.

Findinqs and Observations

The team identified no findings. Based upon the team's review, CAL ltem 11 is closed.

During the team's visits to the UT-Austin FSEL, the team observed the conditions and controls

implemented for the aging of the test blocks and testing of concrete sample cylinders for

compressive strength and modulus of elasticity. The team witnessed appropriate

implementation of the testing procedures by FSEL staff and proper oversight of these activities

by the MPR staff.

At the conclusion of this inspection, the desired level of ASR progression in the test blocks had

not been achieved to conduct the first round of ASR-affected anchor testing. The team

reviewed the results of the control specimen anchor testing completed in November 2012. The

purpose of the control specimen testing was to establish a baseline to determine the potential

reduction in anchor bolt capacity due to ASR. Review of the test data (reference MPR

Memorandum DRN 0326-0058-163, dated June 18, 2013) identified that all anchor bolt test

results were in agreement with calculated capacities, and an appropriate baseline had been

established for comparison during future testing.

9.0 Review of Previously ldentified lssues of Interest

9.1 Structural Evaluations for 13 Locations

As documented in Inspection Report 05000443/2012009, NextEra identified 26 locations

(including containment) as having patterned cracking with a CCI of greater than 1.0 mm/m. In

accordance with the SMP, Revision 2, structures with a CCI of >1.0 mm/m require a structural

evaluation. NextEra's lnterim Assessment documented an engineering judgment that biased

the performance of detailed structural evaluations to the 1'l locations with a CCI > 1.5 mmlm.

The locations with a CCI of between 1.0 and 1 .5 mm/m (13 locations) were considered bounded

by the 11 areas subjected to a detailed evaluation. The lack of a documented structural

evaluation for the 13 locations with a CCI of between 1.0 and 1.5 mm/m was a minor

Enclosure
10

performance deficiency which NextEra entered into its Corrective Action Program (AR 1804477

and AR 1819080). During this inspection, the team reviewed Calculation C-S-10168,

Revision 1, and FP 100716, "Seabrook Station: lmpact of Alkali-Silica Reaction on Concrete

Structures and Attachments," Revision 2, which incorporated the additional evaluations for the

13 locations.

The evaluation methodology included reviewing the original calculations that govern the design

of the structures to determine the design parameters associated with the general area of ASR

degradation. The structural member's load demand and capacity were then noted and the

margin calculated for comparison against the potential reductions in load capacities caused by

ASR. The assumed reductions in capacity were determined based on lower-bound values

established in industry literature. A summary of the evaluation results was provided in Table 3

of FP100716, Revision 2. For areas where design margins were insufficient to offset assumed

lower-bound reductions in capacity due to ASR, further review was performed to determine if

analysis could show that there was additional margin. For each of these areas, the analysis

either reduced load factors that were applied to the demand loads in the original design basis

calculations, or used the 28-day compressive strength (based on field testing performed at the

time of construction) to obtain a higher as-built structural capacity value. The analysis is

described in Calculation C-S-1-10168, Revision 1. The team found the approach of reducing

load factors to establish more representative demand loads in order to demonstrate additional

margin to assure structural integrity acceptable for the current state of ASR degradation.

NextEra plans to credit the load factors in the load demand calculation to establish full

qualification per the Final Safety Evaluation Report (FSAR) licensing basis in the final operability

determination, following completion of the testing program at UT-Austin.

The team concluded that NextEra's initial approach to perform a bounding analysis for areas

with CCI >1.5 mm/m was not conservative, because the design margins vary in each structural

member of each reinforced concrete structure. Once the impact of the ASR degradation on

structural capacities is determined from the UT-Austin FSEL test program, NextEra plans to

review the design calculations for each ASR impacted area to assure margins remain

acceptable. The team concluded that the revised assessment appropriately completed the

engineering evaluations for the 13 locations.

9.2 Review of Core Sample Material Property Testing

As documented in Inspection Report 05000443/2012009, Section 3.2.9, the NRC planned to

reexamine the need of additional core sampling of Seabrook structures for the purpose of

monitoring and assessing the condition of ASR-affected reinforced concrete. For the long-term,

NextEra has elected to evaluate structural performance (operability) of the Seabrook ASRaffected reinforced concrete structures by developing a testing program involving large

specimens that are fabricated to closely replicate the Seabrook concrete and reinforcement

design. NextEra has pursued this method, instead of conducting detailed material properties

testing of core samples, based upon available laboratory testing and data that indicates that

measurable material properties of removed cores do not, under all circumstances, accurately

represent the "in situ" mechanical properties of the concrete. The reason for the difference is

that prior to removal of the core sample, that concrete specimen is subjected to the specific

structural compressive stresses (dead loads, live loads, and hydrostatic loads) and inherent

Enclosure
11

restraint due to reinforcement bars. When removed from the structural member, that concrete

specimen is unrestrained. In addition, as identified in the associated core sampling standard

(ASTM C42, "Standard Test Method for Obtaining and Testing Drilled Cores and Sawed Beams

of Concrete"), core sample test results may be "...affected by many factors such as the strength

level of the concrete, the in-place temperature and moisture histories, the degree of

consolidation, batch-to-batch variability, the strength-gain characteristics of the concrete, the

condition of the coring apparatus, and the care used in removing cores."

The team's review of this issue has identified two general approaches to gaining an informed

understanding of the impact of ASR on reinforced concrete structures. One approach is that

being taken by NextEra to assess the overall structural performance of an ASR-affected

structural member, much like (but not the same) as the performance of a load test prescribed by

ACI 318, "Building Code Requirements for Structural Concrete," Chapter 20, "Strength

Evaluation of Existing Structures." Whereas, the alternative approach involves analytical

evaluations using as an input the measureable steel and concrete material property values

derived from samples from the affected structure, also recognized by ACI 318, Chapter 20.

NextEra is challenged to appropriately correlate the FSEL test program results to the Seabrook

structures. Accordingly, NextEra plans to take additional core samples from both the test

specimens and the Seabrook structures to better correlate the large specimen test results using

petrography and mechanical testing. The team viewed additional core sampling as a positive

means to better correlate FSEL test data to the plant structures.

9.3 Containment Prompt Operability Determination (POD) and Pre-stressing Effects

of ASR

As discussed in Inspection Report 0500044312012009, the team noted that the confinement

provided by the steel reinforcement bar (rebar) cage restrains ASR expansion resulting in ASRinduced or "chemical" pre-stressing of affected structural members. The team observed that

NextEra had provided a qualitative explanation of this condition in the Interim Assessment (FP

100716), and in the containment POD and structural evaluation (reference AR 1804477). The

team had concluded that a quantitative evaluation of this condition may be warranted to address

this aspect of the non-conforming ASR condition.

During this inspection, the team discussed the impact of ASR-induced pre-stressing on

reinforced concrete structures with NextEra and reevaluated NextEra's assessment in AR

1804477, The effect of "chemical" pre-stressing is to both increase the compressive stresses in

the concrete (within the rebar cage) and to increase the tensile stresses in the rebar, as long as

the rebar cage restraint is sustained (i.e., the concrete remains anchored to the rebar). Similar

to fabricated pre-stressed concrete structural members, the ultimate load carrying capacity of

the reinforced member is not significantly changed by the ASR-induced pre-stress. Some

studies have identified that the tensile stress in the reinforcing steel caused by the ASR

expansion results in a corresponding compressive stress on the concrete that balances the

added load and initially results in reduced deflections under load and a stiffer structural

behavior. However, without the ability to quantify the effect and account for the chemical prestressing in engineering evaluations, the team concluded that even though the ASR-induced

Enclosure
12

pre-stressing may result in some beneficial effects in terms of structural stiffness, this cannot

and should not be credited for the purpose of structural evaluation. lt is possible that more

advanced ASR conditions could result in the steel reinforcement strain limits being exceeded

that could compromise the overall structural performance.

The team noted that although the combined crack index (CCl) had been measured at three

locations on the outside surface of containment, absent quantitative analyses, NextEra had not

shown that the containment reinforcements were below yield. Further, the team noted that the

current design code for containment does not allow containment reinforcement strains to be

above yield. The Seabrook containment was designed to ASME Section lll, 1975 edition and

used allowable stress design methodology. This methodology does not allow for stresses to

exceed the elastic limit. Specifically, "in order to keep the containment basically elastic under

service load conditions and below the range of general yield under factored primary loads, the

allowable stresses and strains in this subsection shall not be exceeded." This issue was

discussed with NextEra representatives who stated actions would be taken (reference AR

1804477) to determine the effects of ASR relative to the containment design code requirements.

As this issue has been documented in the Seabrook CAP with an open operability

determination, resolution of the issue will be monitored via the ROP baseline inspection

activities.

The team concluded there was no significant safety concern with containment reinforcement

strain at this time because: (1) the containment is heavily reinforced and ASR is highly localized

affecting a small percentage of containment area; (2) the concrete strain (crack index)

measured at the surface may not reflect the condition of the reinforcement; and, (3) the

integrated leak rate test in 2010 showed the containment returning to pre-existing conditions.

As documented in NextEra's containment POD, primary containment is fully operable and

capable of meeting all its design basis functions, with some reduced margin.

9.4 Assessment of the Need for Further Rebar Examinations

As documented in Inspection Report 05000443i2Q12009, Section 3.2.9, the NRC reviewed the

potential for ASR having an adverse impact on rebar. NextEra and its engineering consultants

had concluded that rebar is unaffected by ASR-degraded concrete unless the cover concrete is

severely damaged and the rebar is exposed. NextEra concluded that ample alkali remains in

the concrete to maintain rebar passivity and to preclude a corrosive environment.

The team determined that NextEra's position was acceptable. Based upon the examination of a

limited number of Seabrook rebar, and the review of available industry operating experience

associated with concrete degradation mechanisms, the team concluded that at the current level

of ASR there is no evidence to suggest that the reinforcing steel bars at Seabrook are

corroding. ln accordance with the Seabrook SMP and the referenced American Concrete

lnstitute 349.3R-96, "Evaluation of Existing Nuclear Safety Related Concrete Structures,"

periodic visual inspections (signs of leaching, staining, spalling and pop outs) coupled with soil

and groundwater testing for aggressive chemistry conditions (i.e., chlorides, sulfates and pH)

provide appropriate monitoring and industry recommended detection methodology. Inspections

conducted have not identified any iron oxide staining attributed to rebar corrosion on any ASREnclosure
9.5

13

affected concrete structures at Seabrook. Consequently, the team has concluded that no

additional rebar examinations (i.e., removing the cover concrete to expose rebar for visual

inspection) are currently warranted.

Use of Combined Crack Indexing for Structures Monitoring Program

As previously documented in Inspection Report 05000443/2012009, Section 6.0, the team

planned to examine NextEra's basis for using Combined Crack Indexing (CCl) as the primary

SMP method to monitor the progression of ASR in Seabrook structures. The team noted that

the basis for NextEra's selection of CCI for monitoring, as endorsed by the FHWA, is that CCI

provides a direct visual and measurable method for the detection and monitoring of ASR

progression. Although the objective of NextEra's UT-Austin testing program is to establish and

correlate the degree of ASR progression to overall structural performance, the interim use of the

CCI method and the 6-month interval measurements taken, to date, provide reasonable

assurance that the level of degradation due to ASR remains essentially the same and that the

progression rate is low. As such, the bounding engineering calculations and associated prompt

operability determinations remain valid.

Best available information concerning the impact of ASR on a structural member indicates that

the formation of ASR gel within the concrete matrix, and subsequent absorption of water by that

gel, results in gel expansion that generates stresses within the concrete matrix. These

expansion stresses are transferred to the concrete and relieved by cracking that is present in

both the exterior cover concrete and inside the rebar cage. For structures that are not triaxially

reinforced (this includes the majority of the walls at Seabrook Station that have no through-wall

shear reinforcement), the potential exists for some undetected out-of-plane crack formation that

could result in an adverse impact on structural performance. As documented in Section 6.0, the

large-scale testing program is intended to provide additional insights to the overall performance

of non-triaxially reinforced wall structures.

In support of the use of CCl, which is a two-dimensional concrete surface measurement,

NextEra is developing plans to install deep pins in ASR-affected walls at Seabrook to better

monitor ASR progression. The large-scale test specimens fabricated at the UT-Austin facility

include three-dimensional through-wall pin placements which will provide a more

comprehensive measurement of the ASR expansion and associated impact on structural

performance. NextEra plans to install similar deep pins at the site in order to better correlate the

UT-Austin testing results and the two-dimensional CCI data to actual structural performance.

As stated above, within the confines of the reinforcement cage, the ASR expansion is restrained

and some of the expansion stresses are transferred to the reinforcing bars. The added stresses

are carried by the steel rebar. As a result, within a reinforced concrete structure, the visible

ASR patterned cracking will be smaller and finer since the rebar is carrying the load and

providing restraint to the concrete. The amount of restraint provided by the rebar is dependent

upon the type, size and design of the concrete section. More heavily reinforced structures

would more readily resist ASR expansion and may depict a different level of CCI compared to a

lightly or non-reinforced structure with a similar degree of ASR progression. The team

concluded that the use of periodic CCI measurements to monitor ASR progression appears

appropriate, pending the outcome of the UT-Austin testing.

Enclosure
14

9.6 Planned Regulatory Actions

As discussed in Section 6.0 of this report, and in NextEra's ASR Project CAP, the crediting of

the FSEL test results for demonstrating current and longer term operability of ASR-affected

reinforced concrete structures may be evaluated by NextEra pursuant to 10CFR50.59 (changes,

tests, and experiments) and 10CFR50.90 (license amendment requests). The team concluded

that this approach is appropriate and consistent with existing regulatory processes. The team

notes that CCI may become the principle method used by NextEra for monitoring the

progression of ASR in affected structures. Pending the results of the FSEL testing program,

NextEra may propose the use of this methodology for assessing current and future operability of

ASR-affected structures.

10.0 Review of Six-Month Combined Crack Indexing Data

Inspection Scope

The team reviewed the periodic concrete expansion measurements and observed field

measurements for ASR-impacted Seabrook structures. Specifically, the team examined the

supporting documentation for the ASR Crack lndex Report, dated March 18, 2013 (FP 10081 1 ),

and the ASR Expansion Measurements Report, dated March 18,2013 (FP100812). The team

also conducted interviews and discussions with the responsible NextEra engineering staff. The

team used 10CFR50, Appendix B, Criterion XVl, "Corrective Action," and Criterion Xl, "Test

Control," as the regulatory guidance to assess the adequacy of NextEra's actions to address

AS R-affected rei nforced concrete structu res.

Findinqs and Observations

No findings were identified. The combined crack index (CCl) data indicated that there was

some evidence of expansion caused by the ASR; however, the CCI data was inconsistent with

the pin-to-pin measurements that indicated no measurable expansion, at the same monitored

locations. There was no change in the CCI data for the containment, but the Electric Tunnel

and the Primary Auxiliary Building/Residual Heat Removal (PAB/RHR) vault both showed an

increasing trend in CCI value in the six months since June 2012. While this may be the result of

seasonal effects, ASR degradation appears to be ongoing in some Seabrook structures as

indicated by minor incremental crack groMh. Collectively, the CCI measurements indicate

essentially no structural changes, and therefore no challenges to the conclusions in the current

ASR-affected structures' prompt operability determinations. The team noted NextEra's plans to

continue the 6-month CCI measurements to establish a stable trend in observable ASR

expansion for each uniquely ASR-affected structure. Continued periodic measurements should

eliminate the potential influence of seasonal ambient temperature changes from the trend

results.

CCI Measurements

ln the ASR Crack Index Report (FP10081 1), NextEra measured CCI values lor 26locations in

the monitoring program and compared the results to the data taken in June 2Q12. The

December CCI data shows an apparent increase in most (19 of 26) of the monitored locations.

Enclosure
15

NextEra concluded the apparent increase in CCI values may be due to seasonal temperature

variations because the concrete (in December) was significantly colder, which may cause the

concrete to contract between the cracks, increasing the apparent crack widths,

As reported by NextEra, uneven cracking (total crack width in one direction is much larger than

in the other direction) and measured larger cracks were identified in the horizontal direction

compared to the vertical. The team observed that, over the long{erm, averaging the horizontal

and vertical CCI values may be an adequate representation of overall changes due to ASR of

the specific structural member. However, the practice of averaging the horizontal and vertical

CCI values is different than outlined by available industry guidance (FHWA-HlF-09-004) that

recognizes the influence of reinforcements on crack growth. Thus, reporting an averaged CCI

vice directional CCI values separately could mask the expansion in a preferred direction and

hamper the identification of a trend in the short term. NextEra acknowledged this team

observation and initiated a Condition Report (CR 1758920-41) to evaluate this issue.

The team also noted that NextEra revised the method of calculating CCI in the recent 6-month

measurement report (December 2012). The CCI measurement reporting method was changed

to account for the use of rectangular grids to determine crack index and thereby normalize index

to the total number of lines in the both directions. In so doing, NextEra recalculated the CCI

values for the December 2011 and June 2012 data to eliminate potential biasing errors. The

team concluded that NextEra's more consistent use of a calculation method would aid the

identification of apparent trends.

Structure Expansion Measurements

In the Expansion Measurement Report (FP100812), NextEra performed measurements

between pins embedded in the surface of plant buildings at the 26 established CCI monitoring

locations. The 26 monitored locations were selected from the 131 locations identified in the

ASR Walkdown Report (reference FP100705) which exhibited the highest visible ASRassociated distress. NextEra noted a null result for expansion measurements between pins in

most of the 26 monitored locations. Specifically, data recorded in most (436) measurement

lines showed no significant changes compared to the baseline data. However, for 5 of the 436

measurement lines, NextEra noted length changes that were unexpected. NextEra plans to

evaluate these locations further.

The team noted that the crack index data shows an apparent increase when expansion data in

2-dimensions shows no change. lt appears that the CCI data better reflects expansion in the

structure compared to the expansion measurements in only two dimensions, which may not be

a complete indicator of changes in the structure. The team noted that NextEra plans to add

deep pins to ASR-impacted walls in the monitored locations that will allow expansion

measurements in the out-of-plane direction (reference CR 1758920-39).

Enclosure
16

11.0 Review of Adequacy of Revisions to the Phase 3 Walkdown Plans and Schedule

lnspection Scope

During the previous inspection, the team reviewed the overall thoroughness of NextEra's

completed and planned ASR walkdown activities conducted in accordance with FP 100642,

"ASR Walkdown Scope," Revision 1, and documented in FP 100705, "Seabrook Station:

Summary of Alkali Silica Reaction Walkdown Results," Revision 0. At the time of the inspection,

not all of the potentially affected structures had been examined and NextEra had drafted a

tentative schedule for the completion of the Phase 3 (areas not readily accessible) walkdowns.

During this inspection, the team assessed NextEra's final Phase 3 schedule for completeness

and to ensure a timely examination of the extent of condition of ASR-affected structures.

Findinqs and Observations

No findings were identified.

NextEra's ASR extent of condition structures walkdown is being conducted in three phases.

Phase 1 involved examination of readily accessible areas of interest; Phase 2 included

examination of coated surfaces identified during Fhase 1 inspections (coatings had to be

removed to expose the concrete surfaces); and Phase 3 examines normally inaccessible

structures and areas (e.9., high radiation, manholes, etc.) which have or will be inspected at the

earliest opportunity (e.9., routine maintenance or outage activities). Team examination of the

Phase 3 walkdown areas identified a minor documentation issue (in addition to the previously

documented containment IWL inspection oversight) that the spent fuel pool (SFP) reinforced

concrete walls were not included in the planned Phase 3 walkdown list even though NextEra

was planning to do these inspections. The SFP walls pose a particular challenge to NextEra

due to the limited accessibility of the concrete surfaces. At the conclusion of this inspection,

NextEra was working to complete its evaluation of various methods to assess the SFP concrete

walls (reference ASR Project Corrective Action Plan, revised April 2013). NextEra had already

initiated plans to perform one shallow core bore in an area that was continuously wetted (SFP

telltale sump) from borated water. This core will be examined for concrete degradation and to

look for any degradation of rebar (reference ML 1227A023, Commitment No. 67).

The team assessed the Phase 3 walkdown schedule and concluded the target dates for

completion were reasonable. With respect to completing a comprehensive examination of the

containment structure, the team concluded that performing this inspection concurrent with the

scheduled 2015 refueling outage IWL examination was appropriate and commensurate with the

safety significance of the issue. The balance of the Phase 3 extent of condition walkdowns are

scheduled for completion in mid-to-late 2013 and during the April 2014 refueling outage. In

summary, the team concluded that NextEra's completed and planned extent of condition

reviews for identification of ASR-affected reinforced concrete structures was appropriate.

Enclosure
17

12.0 Aircraft lmpact Review

lnsoection Scope

The team reviewed NextEra's evaluation of the aircraft impact study performed in response to

the identification of ASR. The aircraft impact study for Seabrook containment is described in

UFSAR Section 3.8.1.3 and Appendix 2P. As noted in the Updated Final Safety Analysis

Report (UFSAR), the postulated aircraft impact load is not combined with any other containment

transient design loading. Further, the study assumes the impact area to be on the dome just

above the spring line.

Findinqs and Observations

No findings were identified.

The effects of an aircraft impact were found not to be controlling for overall containment design

considerations. Also, the analysis assumes that the enclosure building fails when struck by the

aircraft and deforms until the aircraft contacts the containment structure. The containment

enclosure building design and analysis is described in UFSAR Section 3,8.4. NextEra's

evaluation states that ASR has only been identified in below-grade elevations of the

containment and containment enclosure buildings, where sufficient moisture has contributed to

ASR progression. To date, no above-grade (or vicinity of the anticipated aircraft impact area)

evidence of ASR has been identified on containment. Accordingly, NextEra has concluded that

the Seabrook aircraft impact study remains valid and unaffected based upon engineering

evaluations of other ASR-affected reinforced concrete structures completed to date.

13.0 UT-Austin Ferguson Structural Engineering Laboratory Visits

Scope of Review

On two separate occasions, members of the team visited the UT-Austin testing facility to

observe ongoing activities and inspect general facility quality assurance and control measures.

The team noted that NextEra has contractual agreements with MPR Associates and the UTAustin Ferguson Structural Engineering Laboratory to oversee and conduct, respectively, the

ASR large-scale testing program. The team toured the facility, including: main fabrication and

testing areas with overhead crane lifting capabilities; outside exposed and protected (green

house) specimen curing areas with continuous or cyclic wetting and drying capability; aggregate

and sand storage yard; and office and laboratory spaces for storage and use of calibration and

test equipment, as well as, environmentally controlled storage units for a variety of mortar bar,

prism, and concrete cylinder test specimens. The team examined the large block anchor bolt

test specimens, including the control specimen block which had been tested. The team also

witnessed fabrication of the second large shear and lap splice test beam, and some testing of

cylinders for compressive strength and Modulus of Elasticity determination.

Enclosure
18

Findinqs and Observations

No findings were identified. The team observed appropriate oversight and quality control

practices being implemented. Direct oversight by both UT-Austin supervisory staff and MPR

engineers was evident and effective.

14.0 Meetings, Including Exit

On June 27,2013, the team conducted an exit meeting to discuss the preliminary findings and

observations with Mr. Kevin Walsh, Site Vice President, and other members of Seabrook

Station staff. The inspectors verified that no proprietary information was retained by the

inspectors or documented in this report.

Enclosure
A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Brown, Design Engineering Manager

A. Chesno, Performance lmprovement Manager

K. Chew, License Renewal Engineer

R. Clich6, License Renewal Project Manager

M. Collins, Design Engineering Manager

J. Connolly, Site Engineering Director

R. Noble, Project Manager

M. O'Keefe, Licensing Manager

T. Vassallo, Principal Design Engineer

M. Ossing, Licensing Manager

K. Walsh, Site Vice President

P. Willoughby, Licensing Engineer

Updated

None

Opened

None

Closed

None

Procedures

Maintenance

EDS 36180,

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

LIST OF DOCUMENTS REVIEWED

Rule Scoping Document, Revision 0

Structures Monitoring Program, Revisions 1, 2, 3

Corrective Action Documents (AR)

1651969,1629504,574120,581434,1636419,1673102,1647722,1664399,1677340,

1687932, 1692374, 1 698739, 1755727, 1757861, 1 81 9080, 1804477, 1 81 9069

Drawinqs

Licensinq and Desion Basis Documents and Calculations

Seabrook Station UFSAR, Revision 14

ACt 318-71

Calculation CD-20; Calculation CD-18; and Calculation C-S-1-10168

Attachment
A-2

Miscellaneous Documents

FP 1 00348, Statistical Analysis-Concrete Compression Test Data (PTL)

FP 100642, Scope for Alkali-Silica Reaction Walkdowns

FP 100641, Procedure for ASR Walkdowns and Assessment Checklist

FP 100661, Compression Testing Concrete Cores (WJE)

FP 100696, Material Properties of ASR-Affected Concrete

FP 100700, Field lnvestigation

FP 100705, Structure ASR Walkdown Report (MPR 0326-0058-58)

FP 100714, Three Dimensional Dynamic Analysis of Containment Enclosure Building

FP 100715, ASR lmpact Study on Containment Enclosure Building

FP 100716, lnterim Assessment: lmpact of ASR on Structures (MPR-3727)

FP 100717, ACI 318-Tl Perspectives

FP 100718, AnchorTest Report (MPR-3722)

FP 100720, Crack lndex and Expansion Measurement

FP 100738, Measurements for ASR Crack lndexing on Concrete Structures

FP 100697, MPR 0326-0058-53, White Paper on Structural lmplications of ASR:

State of the Art, Revision 1

MPR 0326-0058-83, Shear Screening Criteria Used in MPR-3727

FHWA-HlF-09-004, Federal Highway Administration, "Report on the Diagnosis, Prognosis, and

Mitigation of Alkali-Silica Reaction in Transportation Structures."

ASME lll, Division 2, 1975 Edition, Winter'77 Addenda

Documents Reviewed at FSEL

Purchase Order No. 0326 - 0058 -25, dated December 1, 2011 and change order Nos. 1, dated

March 21,2012; No. 2,dahed March 27,2012; No.3, dated July23,2Q12; and No.4, August2,

2012 betvreen MPR Associates lnc. and Ferguson Structural Engineering Laboratory as applied

to Anchor Testing Program

Contract No. 02293285, dated June 6, 2011, and Amendment Nos. 1, dated October 25,2011:

No.2, dated December 17,2011; No.003, dated January 3,2012: No.004, dated February27,

2012; Amendment 6, dated July 26, 2012, between NextEra and MPR Associates Inc.

MPR Letter to Ferguson Structural Engineering Laboratory, dated December 1, 2011, Notice of

Intent to Contract for Testing of Anchors in ASR-affected Concreter - authorizing FSEL to

develop project-specific quality system manual, implementing procedures for testing and

perform initial characterization of the ASR degradation on girders.

MPR Letter to Ferguson Structural Engineering Laboratory, dated December 1, 2011, Research

on Performance of Anchors in ASR-affected Concrete

MPR Letter to Ferguson Structural Engineering Laboratory, dated March 27,2012, Research on

Performance of Anchors in ASR-affected Concrete

Attachment
A-3

MPR Letter to Ferguson Structural Engineering Laboratory, dated July 23, 2012, Research on

Performance of Anchors in ASR-affected Concrete

MPR Letter to Ferguson Structural Engineering Laboratory, dated August 2,2012, Research on

Performance of Anchors in ASR-affected Concrete

MPR Letter to Ferguson Structural Engineering Laboratory, dated October 26,2012, Research

on Performance of Anchors in ASR-affected Concrete

Purchase Order No. 0326 - 0063 -01, dated June 4, 2012, between MPR Associates Inc. and

Ferguson Structural Engineering Laboratory as applied to Beam Testing Program

Contract No. 02207204, dated April27, 2012, NextEra and MPR Associates Inc., related to ASR

Concrete Beam Testing Program (for Shear and Lap-splice anchorage)

Project Plan 0326 - 0062 -01, Revision 0, dated May 1 , 2012, by MPR Associates Inc. as

applied to Beam Testing Program

Attachment
A-4

LIST OF ACRONYMS

ACI American Concrete Institute ADAMS Agencywide Documents Access and Management System

AR Action Request ASME American Society of Mechanical Engineers ASR Alkali-Silica Reaction ASTM American Society for Testing and Materials CAL Confirmatory Action Letter CAP Corrective Action Plan CCI Combined Crack lndex CFR Code of Federal Regulations CR Condition Report DLR Division of License Renewal DRP Division of Reactor Projects DRS Division of Reactor Safety FHWA Federal Highway Administration

FP Foreign Print FSAR Final Safety Analysis Report FSEL Franklin Structural Engineering Laboratory MPR MPR Associates, Inc. NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PAB Primary Auxiliary Building PARS Publicly Available Records POD Prompt Operability Determination RCE Root Cause Evaluation RHR Residual Heat Removal SFP Spent Fuel Pool SMP Structures Monitoring Program SRI Senior Resident Inspector UFSAR Updated Final Safety Analysis Report

UT-A University of Texas at Austin

Attachment
ffi UNITED STATES

NUCLEAR REGULATORY COilM|sSloN

REGIOI{ |

21 00 Renaissance Boulevard

KING OF PRUSSIA, PENNSYLVANIA 1940G1415

May 16,2012

CAL No. 1-2012-002

Mr. PaulFreeman

Site Vice President, North Region

Seabrook Nuclear Power Plant

NextEra EnergY Seabrook, LLC

c/o Mr. MichaelO'Keefe

P.O. Box 300

Seabrook. NH 03874

SUBJECT:

Dear Mr.

CONFIRMATORY ACTION LETTER, SEABROOK STATION, UNIT 1 -

INFORMATION RELATED TO CONCRETE DEGMDATION ISSUES

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

to pranneo actions forih; degr;dation of concrete in certain structures due to an Alkali'silica

n"..tion (ASR). The ASR iJa chemical reaction in concrete, which occurs over time in the

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

found in some common coarse aggregates. In tlie 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 comiritments will ensure important information is

piouiolJ to the NRC staff to determine if the ticensee is taking adequate corrective actions for a

significant condition adverse to quality.

ln June 2OOg, NextEra initially identified concrete degradation of below grade concrete

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

petrogianic evaluation, comprissive strength, andrnodulus of elasticity. Theseanalyses

identified a change in materiat properties d-ue'to ASR for the "B" electrical tunnel in the control

briidi;g (CB), wi[h reouatons i"pdtt"o in the concrete compressive strength and modulus of

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

n" irnpi"t on the design basis of the "8" electrical tunnel. By its process, the licensee

performed both an imriediate and a prorfiopgrability determination and concluded that the "8"

electricaltunnel*"r-op"r"ule. As aioitiohat information was obtained, including observed

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

opErability determinations concludeo ttrat the'8" electricaltunneland other structures were

operable but degraded.

Encl osure
P. Freeman 2

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

tnJii satbty-related functions. This determination was based in part.by the following:

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

in Oesign provide reaionable expectation that iffected structures can perform their safety

functioi, despite the current licensing and design bases design margln being reduced by the

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

iigniic"nt deformationf Oirtortion, or displacement of structures, or rebar coqqsion; 3) ASR

id6ntified timited 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 fetters dated May 3 and May 10,2012 (Agencywile _Do^cuments and Management system

(nonrvrs) Accession Numbers M]12125AOZZ anlML12131A479, respectively), you described

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

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

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

ASR-affected buildingsLs 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 Rioperiies'Aelow Grade in "8" Electrical Tunnel Exterior Wall,' by May 25,2012'

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

this action.

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

at Seabrook Station and relatedlorrective 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 EquipmentVaults' E:.FW Pump

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

scope'buildings r"itt U" included in this POD. NextEra Energy Seabrook will notlfy the site

NRb Resident Inspector upon completion of this action'

6. Complete short term aggregate expansion testing -(ASTIV! 

C 1260 Mortar Bar Expansion

resti by -lune sd, ioii-Cjsuns,niill ue availablJfor NRC review approximately 30 days

after testing is comPlete.

Encl osure
P. Freeman 3

7. Gomplete tong term aggregate expansion testrlg (ASTM C 1293 Concrete Prism Test) by

June'30, 201d. nesu[Jwiir be av'ailable for NRC ieview approximately 30 days after testing

is complete.

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

development facility by June 30,2012.

g. 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 wiff notity the site NRC Resident lnspector 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 iniervals until a reliable treni of ASR progression is established'

NextEra Energy SeanrooX 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 2232 you 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 ac'tions and commitments

within the specifie'd 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 ' 

addrissed in this Confirmatory Action Letter (CAL)'

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

commitments or requiiing othei actions on the part of NextEra, nor does it preclude the NRC

from taking enforcemeniaaion for violations oi ttRC 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 "grr"n"" oi ne protection of public health and safety or the common defense and

security.

This cAL will remain in effect untilthe NRC has concluded that all actions listed above have

been satisfactorily completed. we note that, regarding the 4SR issue, license renewal is a

separate licensing action before the Commissio-n anOIhe NRG may require the submittal of

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

response to this CAL.

Encl osure
P. Freeman

Docket No. 50-443

License No. NPF-86

cc: Distribution via ListServ

In accordance with 10 cFR 2.390 0f the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your r"rpont" tif 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 Aicess and Management Syltg1 (ADAMS)'

accessibte from the rvn-c w6o 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, Fropri"tiw, or safeguard's informaiion so that it can be made available to the

pubtic witi.rout r6Oictibn. f proprietary information is necessary to provide an. acceptable

',"rponr", 

then please pruiJ"'a Orac-t<eteO copy of your response that identifies the information

that should be protected and a redacted copy oi your response that deletes such information' lf

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

iesponie that you r"tito 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 irivacy dr proviO6 the information required by 10 CFR 2.390(b) to support a request

forwithholding 

"onn6ehtial 

commercial or financial information)- lf safegyards 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 comptiance wiin'regutitory requirements. lf you hav_e any questions, please contact

Richard J. ionte at (010) 337-5183 or e-mail richard.conte@nrc.gov.

Sincerely, M

Regional Administrator

Encl osure
-o|9^" 

ttur,r,

+t -oa

5\ UL-^ -'l E -L\I O

6 !l!nnF.r.. I

-9- \ {flS}! ^re

CAL No. 1-2012-002 (Revision 1)

Mr. Kevin Walsh

Site Vice President, North Region

Seabrook Nuclear Power Plant

NextEra Energy Seabrook, LLC

c/o Mr. MichaelO'Keefe

P.O. Box 300

Seabrook. NH 03874

REVISION TO CONFIRMATORY ACTION LETTER, SEABROOK STATION,

UNIT 1 - INFORMATION RELATED TO CONCRETE DEGRADATION ISSUES

Dear Mr.

This letter confirms receipt of your letter of December 13,2012, related to the NRC

Confirmatory Action Letter (CAL) issued to NextEra Energy Seabrook, LLC (NextEra) on

May 16, 2012 (ADAMS Accession Number ML12125A172). The CAL confirmed actions

planned to be taken by NextEra in regard to the degradation of concrete in certain structures

due to an Alkali-Silica Reaction (ASR). In the December 13,2012,letter, you requested

changes to two of the commitments (CAL ltems Nos. 7 and 1'1). We accept your proposed

changes as discussed below:

CAL ltem No. 7 - You requested the deletion of this commitment, which required that NextEra

conduct a long term aggregate expansion test (ASTM C 1293 Concrete Prism Testing) by

June 30, 2013. Your letter states that the Mortar Bar Expansion testing conducted in

accordance with CAL ltem No. 6 identified that the coarse aggregates contain sufficient reactive

silica for the ASR reaction and expansion to continue long-term under existing environmental

conditions. Therefore, the results of the Mortar Bar Expansion Testing have obviated the need

to conduct additional aggregate expansion testing. Further information regarding this issue is

provided in NRC Inspection Report No. 0500044312012009, Section 5 (ADAMS Acc,ession

Number ML12338A283). Accordingly, the NRC has concluded that NextEra's commitment to

complete long term aggregate expansion testing by June 30, 2013, may be deleted.

CAL ltem No. 11 - You requested that the NRC change this commitment from completing the

anchor test program by December 31,2012, to "submit the technical details of the anchor test

program planned at the contracted research and development facility by February 28,2013."

You requested this change because the anchor testing program, while in progress, would not be

complete by December 31, 2012. NextEra's committed date for completing the anchor testing

was based on the best available projected test schedule in May 2012, and did not fully

anticipate allthe complexities involved in completing the test program. NextEra has completed

some limited testing of anchor performance of ASR-affected concrete as described in

UNITED STATES

NUCLEAR REGULATORY COM]'|SSION

REGION I

21 00 Renaissance Boulevald

KING OF PRUSSIA, PENNSYLVANIA 1940G1415

January 14, 2013

Encl osure
K. Walsh 2

Section 2.3.6, of NRC Inspection Report No. 0500044312012009. These tests results

demonstrated satisfactory performance of the anchors and were used to support NextEra's

prompt operability evaluation. Based on our findings regarding anchor performance, the NRC

finds the requested commitment change acceptable.

The originalConfirmatory Action Letter 2O12-AO2 issued May 2012 remains in effect except as

modified for CAL ltems 7 and 11, above.

fn accordance with Title 10 of the Code of Federal Regulafions (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 NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). To the extent

possible, your response, if you choose to provide one, 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.

lf you have any questions, please contact Richard J. Conte at (610) 337-5183 or e-mail

richard. conte@nrc. gov.

Sincerely,

Regional Administrator

Docket No.: 50443

License No,: NPF-86

cc: Distribution via ListServ

Encl osure