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UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713

May 6, 2016

EA-16-101

Mr. Dean Curtland

Vice President, Seabrook Station 

c/o Mr. Michael Ossing

NextEra Energy Seabrook, LLC 

626 Lafayette Rd. 

Seabrook, NH 03874

SUBJECT: SEABROOK STATION - INSPECTION REPORT 05000443/2016008

RELATED TO ALKALI-SILICA REACTION AFFECTS ON SAFETY-RELATED 

CONCRETE STRUCTURES AND NOTICE OF VIOLATION

Dear Mr. Curtland:

On March 24, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection 

at Seabrook Station. The enclosed inspection report documents the inspection results, which 

were discussed at the exit meeting, with you and other members of your staff.

The 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. 

The inspectors reviewed selected procedures and records, examined structures in the field, and 

interviewed personnel related to your actions to address the effects of Alkali-Silica Reaction 

(ASR) on safety-related concrete structures at the Seabrook Station. Specifically, a team of 

inspectors assessed NextEra’s performance to identify, evaluate and resolve ASR effects 

involving discrete wide cracking and deformation (which is different than the micro-cracking 

typically associated with ASR). These conditions were previously described in NRC findings 

over the past two years involving the Containment Enclosure Building, Residual Heat Removal 

Equipment Vault and Fuel Storage Building. The inspection focused on the adequacy of 

NextEra’s reviews and evaluations to ensure ASR-affected structures remain capable of 

performing their intended safety functions. 

During the exit meeting, the inspection team conclusions and observations were summarized 

regarding NextEra’s corrective actions to resolve the ASR non-conforming condition. The team 

concluded, based on review of NextEra recently completed operability determination 

documents, that ASR-affected structures are capable of performing their safety-related functions 

considering the observed cracking and deformation. The team further indicated that additional 

attention by NextEra staff is warranted to implement Seabrook’s structures monitoring and 

operability screening processes to ensure conclusions regarding structural capability are

updated and technically supported.
D. Curtland - 2 -

One violation of very low safety significance (Green) is cited in a Notice of Violation (Notice) and 

the circumstances surrounding it are described in the enclosed inspection report. The violation 

describes two examples where initial and prompt operability determinations were not completed 

by NextEra staff when additional information regarding the effects of ASR on safety-related 

concrete structures was identified. Prompt operability determinations have since been 

developed and were reviewed during this inspection. The violation is similar to several noncited violations (NCVs) of very low safety significance identified by the NRC within the past two 

years for which corrective actions have not been fully effective. The violation was evaluated in 

accordance with the NRC’s Enforcement Policy. The current Enforcement Policy is available for 

review on the NRC’s Website http://www.nrc.gov/about-nrc/regulatory/enforcement/enforcepol.html. This violation meets the criteria in Section 2.3.2a of the Enforcement Policy to 

disposition it as an NCV. However the NRC is issuing a Notice of Violation because corrective 

actions have not been effective in addressing ASR-related structural issues. Specifically, 

corrective actions to address NRC findings involving identification and evaluation of ASR effects 

on structures over the past two years were not effective to ensure prompt operability 

determinations were maintained with the latest information. Accordingly, the NRC is issuing the 

Notice of Violation and requiring a response regarding your plans to address this concern. 

You are required to respond to this letter and follow the instructions specified in the enclosed 

Notice when preparing your response. Your response in accordance with the instructions 

should describe your actions to address the violation and your plans and milestones to resolve 

the non-conforming condition involving ASR-affected Seabrook structures. If you have 

additional information that you believe the NRC should consider, you may provide it in your 

response to the Notice. The NRC’s review of your response to the Notice will determine 

whether additional enforcement action is necessary to ensure compliance with regulatory 

requirements.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's 

"Rules of Practice," a copy of this letter, its enclosure, and your response, will be available 

electronically, for public inspection, in the NRC’s Public Document Room or from the Publicly 

Available Records component of the NRC’s document system, Agencywide Documents Access 

and Management System (ADAMS). ADAMS is accessible from the NRC’s Website at 

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

Sincerely,

/RA/

Mel Gray, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-443

License No. NPF-86

Enclosure:

1. Inspection Report No. 05000443/20160008

w/Attachment: Supplemental Information

2. Notice of Violation

cc w/encl: Distribution via ListServ
D. Curtland - 2 -

One violation of very low safety significance (Green) is cited in a Notice of Violation (Notice) and 

the circumstances surrounding it are described in the enclosed inspection report. The violation 

describes two examples where initial and prompt operability determinations were not completed 

by NextEra staff when additional information regarding the effects of ASR on safety-related 

concrete structures was identified. Prompt operability determinations have since been 

developed and were reviewed during this inspection. The violation is similar to several noncited violations (NCVs) of very low safety significance identified by the NRC within the past two 

years for which corrective actions have not been fully effective. The violation was evaluated in 

accordance with the NRC’s Enforcement Policy. The current Enforcement Policy is available for 

review on the NRC’s Website http://www.nrc.gov/about-nrc/regulatory/enforcement/enforcepol.html. This violation meets the criteria in Section 2.3.2.a of the Enforcement Policy to 

disposition it as an NCV. However the NRC is issuing a Notice of Violation because corrective 

actions have not been effective in addressing ASR-related structural issues. Specifically, 

corrective actions to address NRC findings involving identification and evaluation of ASR effects 

on structures over the past two years were not effective to ensure prompt operability 

determinations were maintained with the latest information. Accordingly, the NRC is issuing the 

Notice of Violation and requiring a response regarding your plans to address this concern. 

Accordingly, the NRC is issuing the Notice of Violation and requiring a response regarding your 

plans to address this concern. 

You are required to respond to this letter and follow the instructions specified in the enclosed 

Notice when preparing your response. Your response in accordance with the instructions 

should describe your actions to address the violation and your plans and milestones to resolve 

the non-conforming condition involving ASR-affected Seabrook structures. If you have 

additional information that you believe the NRC should consider, you may provide it in your 

response to the Notice. The NRC’s review of your response to the Notice will determine 

whether additional enforcement action is necessary to ensure compliance with regulatory 

requirements.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's 

"Rules of Practice," a copy of this letter, its enclosure, and your response, will be available 

electronically, for public inspection, in the NRC’s Public Document Room or from the Publicly 

Available Records component of the NRC’s document system, Agencywide Documents Access 

and Management System (ADAMS). ADAMS is accessible from the NRC’s Website at 

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

Sincerely,

/RA/

Mel Gray, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-443

License No. NPF-86

Enclosure:

1. Inspection Report No. 05000443/20160008

w/Attachment: Supplemental Information

2. Notice of Violation

cc w/encl: Distribution via ListServ
D. Curtland - 3 -

Letter to Mr. Dean Curtland from Mr. Mel Gray dated May 6, 2016

SUBJECT: SEABROOK STATION - INSPECTION REPORT 05000443/2016008 

RELATED TO ALKALI-SILICA REACTION (ASR) AFFECTS ON 

SAFETY-RELATED CONCRETE STRUCTURES

DISTIRBUTION w/encl: (via e-mail)

DLew, actg RA

SFlanders, actg DRA

MScott, DRP

DPelton, DRP

RLorson, DRS

BSmith, DRS

FBower, DRP 

RBarkley, DRP

MDraxton, DRP

RVadella, DRP

PCataldo, DRP, SRI

JVazquez, DRP, Actg RI

ACass, DRP, Resident AA

MGray, DRS

NFloyd, DRS

ABuford, NRR

BLehman, NRR

JBowen, RI, OEDO

BBickett, RI, ORA 

WCook, RI, DRS

RidsNrrPMSeabrook Resource

RidsNrrDorlLpl1-2 Resource

RidsNrrDLR Resource

ROPreports Resource

DOCUMENT NAME: G:\DRS\Engineering Branch 1\ -- Gray M\Seabrook Standalone Report 2016-008.docx

ADAMS Accession Number: ML16127A155 

 SUNSI Review

 Non-Sensitive

 Sensitive

 Publicly Available

 Non-Publicly Available

OFFICE RI/DRS NRR/DLR RI/DRP RI/DRS RI/ORA

NAME WCook/ WC ABuford / concurred by 

e-mail FBower/ FLB MGray/ MG BBickett/ BB

DATE 05/03/2016 05/05/2016 05/05/2016 05/06/2016 05/05/2016

OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No. 50-443

License No. NPF-86

Report No. 05000443/2016008

Licensee: NextEra Energy Seabrook, LLC 

Facility: Seabrook Station

Location: Seabrook, NH 03874

On-Site Dates: February 1 – 5 and March 21 – 24, 2016

Inspector: William A. Cook, Senior Reactor Analyst

Region I

Accompanied by: Angela Buford, Structural Engineer

Office of Nuclear Reactor Regulation (NRR)

Bryce Lehman, Structural Engineer, NRR

Approved by: Mel Gray, Chief

Engineering Branch 1

Division of Reactor Safety
Enclosure 1

NOTICE OF VIOLATION

NextEra Energy Seabrook, LLC Docket No. 50-443

Seabrook Station License No. NPF-86

EA-16-101

During an NRC inspection conducted between February 1 and March 24, 2016, a violation of 

NRC’s requirements was identified. In accordance with the NRC Enforcement Policy, the 

violation is listed below:

10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” states, in part, 

that activities affecting quality shall be prescribed by documented instructions, procedures or

drawings, of a type appropriate to the circumstances, and shall be accomplished in accordance 

with these instructions, procedures or drawings.

NextEra Nuclear Fleet Administrative Procedure, EN-AA-203-1001, “Operability 

Determinations/Functionality Assessments,” identifies the responsibilities and requirements for 

preparation and approval of Immediate Operability Determinations (IOD) and Prompt Operability 

Determinations (POD) for establishing the acceptability of continued operation of a plant 

structure, system, or component that is suspected to be degraded or nonconforming. Per 

Section 2.0, Terms and Definitions, IODs are performed by the Shift Manager without delay 

(within 8 hours of discovery), using best available information to make an operability declaration. 

Upon request of the Shift Manager, a POD is performed as a follow-up to an IOD when 

additional information is needed to confirm the declaration of operability.

Contrary to the above, on two occasions between March 17, 2015, and January 22, 2016, 

Energy Seabrook, LLC (NextEra) did not accomplish an activity affecting quality in accordance 

with its procedure. Specifically, NextEra received information from vendors identifying nonconforming conditions adversely impacting two reinforced concrete structures at Seabrook 

Station, and did not complete an appropriate IOD or initiate a follow-up POD to evaluate the 

impact of that non-conforming condition on structural performance. In particular,

1) On March 17, 2015, NextEra entered a WJE report, entitled “Condition Assessment 

of the Cracking in the RHR and CS Equipment Vault,” into the station document 

tracking system and added the report’s recommendations into the Corrective Action 

Program under Action Report (AR) 01977456, without completing an appropriate IOD 

or initiating a POD. The report identified structural loading (a load not considered by 

ACI 318-71, the design and construction code of record) due to ASR as the cause for 

the excessive bulk expansion and cracking of the RHR/CS Vault interior and exterior 

support walls; and

2) On December 2, 2015, NextEra initiated AR 02094762 to track recommendations 

from SG&H report entitled “Evaluation and Design Confirmation of As-Deformed 

CEB,” without completing an appropriate IOD or initiating a POD. The report also 

identified structural loading due to ASR as the cause for deformation of the 

Containment Enclosure Building (CEB), a condition not conforming with ACI 318-71.
2

This violation is associated with a Green Significance Determination Process finding. 

Pursuant to the provisions of 10 CFR 2.201, NextEra is hereby required to submit a written 

statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control 

Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region I, and a 

copy to the NRC Resident Inspector at Seabrook Station, within 30 days of the date of the letter 

transmitting this Notice of Violation (Notice). This reply should be clearly marked as a “Reply to 

a Notice of Violation” EA-16-101 and should include: (1) the reason for the violation, or, if 

contested, the basis for disputing the violation or severity level; (2) the corrective steps that 

have been taken and the results achieved; (3) the corrective steps that will be taken including a 

comprehensive and integrated ASR corrective action plan (ACAP) for resolving ASR-induced 

non-conformances with the current licensing basis (CLB) and the date when your structures 

monitoring program will be revised to monitor the progression of ASR degradation related to 

bulk expansion and deformation; and (4) the date when full compliance will be achieved. Your 

response may reference or include previous docketed correspondence, if the correspondence 

adequately addresses the required response. If an adequate reply is not received within the 

time specified in this Notice, an Order or a Demand for Information may be issued as to why the 

license should not be modified, suspended, or revoked, or why such other action as may be 

proper should not be taken. Where good cause is shown, consideration will be given to 

extending the response time.

If you contest this enforcement action, you should provide a copy of your response, with the 

basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory 

Commission, Washington, DC 20555-0001. Because your response will be made available 

electronically for public inspection in the NRC Public Document Room or from the NRC’s 

document system (ADAMS), accessible from the NRC’s Website at http://www.nrc.gov/readingrm/adams.html, to the extent possible, it should not include any personal privacy, proprietary, or 

safeguards information so that it can be made available to the public without redaction. If 

personal privacy or 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. 

If 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 of your claim of 

withholding (e.g., explain why the disclosure of information required by 10 CFR 2.390(b) to 

support a request for withholding confidential commercial or financial information). 

If Safeguards information is necessary to provide an acceptable response, please provide the 

level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working 

days of receipt.

Dated this 6th day of May 2016
Enclosure 2

SUMMARY

IR 05000443/2016008; 2/01/2016 – 3/24/2016; Seabrook Station (Problem Identification and 

Resolution; Follow-up on Operability Determinations).

This report covers an inspection by a regional Senior Reactor Analyst, with assistance from 

Office of Nuclear Reactor Regulation (NRR) structural specialists. One Green finding was

identified. The significance of most findings is indicated by their color (Green, White, Yellow, 

Red) using Inspection Manual Chapter (IMC) 0609, “Significance Determination Process”

(SDP). The cross-cutting aspects for the findings were determined using IMC 0310, 

“Components Within Cross-Cutting Areas.” 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

Green. The team identified a violation of Appendix B, Criterion V, “Instructions, Procedures, and 

Drawings,” and NextEra Nuclear Fleet Administrative Procedure, EN-AA-203-1001, “Operability 

Determinations/Functionality Assessments,” involving Seabrook Station staff failing to perform 

operability evaluations for identified non-conforming conditions. Specifically, the team identified 

that following receipt of a vendor’s structural assessment of the RHR/CS Vault on March 17, 

2015, the Seabrook staff failed to complete an appropriate immediate operability evaluation or 

initiate a Prompt Operability Determination (POD) for an identified structural load (ASR induced) 

not considered by ACI 318-1971, the design and construction code of record. The team also 

identified that following receipt of another vendor’s report, “Structural Evaluation and Design 

Confirmation of the CEB,” on December 2, 2015, that the Seabrook staff failed to complete an 

immediate and follow-on POD to address ASR induced loads (due to internal expansion and 

externally applied by ASR-affected concrete backfill) that are causing CEB structural 

deformation.

The team determined that the two examples of failure to identify structural loading due to ASR 

expansion as a non-conforming condition and to then promptly evaluate the impact of this 

condition on the operability of the affected structures is a performance deficiency. This 

performance deficiency is considered to be more than minor because the non-conforming 

condition adversely impacts the structural integrity design attribute of the reactor safety barrier 

integrity and mitigating systems objectives. In addition, the finding is similar to more than minor 

Example 3.i of Appendix E of IMC 0612. The finding was evaluated in accordance with IMC 

0609, Appendix A, “The Significance Determination Process for Findings At-Power,” Exhibit 3, 

“Barrier integrity Screening Questions,” and screened as very low safety significance (Green) 

because the finding only represents a degradation in design margin and did not impact the 

radiological barrier function of the affected structures. The finding had a cross cutting aspect in 

the area of problem identification and resolution, P3, timely resolution of issues. Specifically, 

NextEra did not fully evaluate conditions adverse to quality, including evaluating the effects of 

the ASR expansion-induced loads on operability of certain structures, in a timely manner 

following identification by an engineering analysis. (Section 4OA5)
REPORT DETAILS

Background

The alkali-silica reaction (ASR) is a chemical reaction in concrete, which occurs over time in the 

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

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

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

including compressive and tensile strength, modulus of elasticity, and Poisson Ratio. At 

Seabrook Station, reinforced concrete structures have shown evidence of ASR degradation. 

In the summer 2010, NextEra performed an Immediate and Prompt Operability Determination 

(POD) for the control building “B” electrical tunnel structure based on core samples taken from 

the building. NRC inspection Report 05000443/2010004, issued November 1, 2010, ADAMS 

Accession No. (ML103050447) documented the NRC review of the POD with no findings. From 

2010-2012, the NRC completed further inspections (ML111330689; ML112241543; 

ML120480066) of NextEra’s activities to investigate, evaluate and monitor Seabrook structures 

affected by ASR. These inspections resulted in the NRC issuing Confirmatory Action Letter 

No. 1-2012-002 dated May 16, 2012, to document NextEra’s commitments to address ASRaffected Seabrook structures (ML12125A172). The commitments involved NextEra establishing 

a bounding prompt operability determination for all ASR-affected buildings as well as interim 

monitoring actions to ensure ASR related degradation is effectively managed. Additional 

commitments included the commencement of test programs at the Ferguson Structural 

Engineering Laboratory (FSEL), University of Texas at Austin to validate monitoring methods, to 

assess structural performance, and to enhance the Seabrook Structures Monitoring Program 

(SMP) to manage ASR.

NextEra concluded that ASR-affected structures remained operable, but were non-conforming 

with the site design and licensing basis. The NRC completed team inspections to verify 

NextEra staff completed their commitments and documented the results in inspection reports 

dated December 3, 2012, and August 9, 2013 (M112338A283 and ML13221A172). The NRC 

documented how each commitment was determined to be met and closed the CAL via NRC 

letter dated October 9, 2013 (ML13274A670). 

The NRC continued to conduct inspections approximately every six months to evaluate 

NextEra’s activities to investigate, monitor and affirm the structural capability of Seabrook 

structures affected by ASR. 

NextEra’s testing of large scale ASR-affected test specimens at FSEL commenced in late 2013 

and was planned to be completed under NextEra’s direction by February 2016. In 2014-2015, 

the inspectors documented findings of very low safety significance associated with discrete, 

large horizontal cracks in an internal wall of the residual heat removal and containment spray 

(RHR/CS) Vault (ML14212A458); cracks associated with the fuel storage building 

(ML15037A172); and global relative deformation of the containment enclosure building (CEB) 

(ML15217A256). The staff concluded these findings were of very low safety significance 

because the safety function of these structures was not affected.

Based on FSEL’s large scale testing program developments in 2015, NextEra revised their 

structures monitoring/ASR monitoring aging management program to include through-wall 

expansion monitoring. This expansion will be monitored by devices installed in 2016 in several 

dozen representative locations.
2

In the fall 2015, the inspectors completed an inspection to follow-up on the results of NextEra’s 

evaluations and monitoring of the CEB and RHR/CS Vault. In an NRC inspection report dated 

February 12, 2016, (ML16043A391) the inspectors documented unresolved item (URI) 

05000443/2015-01, regarding NextEra’s implementation of the Seabrook SMP. The inspectors 

determined that structural evaluations, performed by contractors and accepted by NextEra staff 

via their “foreign print” document control process, included discussions that identified the 

potential to exceed limits in the applicable design and construction code (ACI 318-71) for 

specific locations in the CEB and RHR/CS Vault walls. The evaluations further recommended 

actions to determine whether this was the case. The inspectors noted that the Seabrook staff 

screened or reviewed these evaluations without documenting a justification in a revision or 

update to the open prompt operability determination (PODs) for these structures. The 

inspectors requested additional information (ML15357A326) and identified that follow-up 

inspection was necessary to determine whether there was a performance deficiency. This 

report documents a follow-up inspection conducted to close this unresolved item 

05000443/2015004-01 utilizing NRC Inspection Procedure 71152, “Problem Identification and

Resolution.”

4. OTHER ACTIVITIES

4OA2 Problem Identification and Resolution (71152)

.1 Annual Sample: Review of Corrective Actions for Alkali-Silica Reaction Affected Structures

a. Inspection Scope

A Senior Risk Analyst from the NRC Region I Office and two structural engineers from 

the NRC Office of Nuclear Reactor Regulation (NRR) conducted in-office reviews and 

two onsite inspections (weeks of February 1 – 5, 2016 and March 21 – 24, 2016) at the

Seabrook Station to review NextEra’s root cause evaluation and corrective actions 

related to the identification of differential movement, or deformation, of the containment 

enclosure building (CEB). This condition was previously described in an NRC inspection 

report dated August 25, 2015 (ML15217A256). NRC inspectors also reviewed 

evaluations related to discrete cracks identified in below grade, internal walls in the 

residual heat removal and containment spray (RHR/CS) equipment vault. This condition 

was previously described in an NRC inspection report dated August 5, 2014, 

(ML14212A458).

The inspectors performed an in-depth review of NextEra’s Prompt Operability 

Determinations (PODs) and associated evaluations and corrective actions to these nonconforming conditions and NextEra’s response (ML16117A312) dated April 14, 2016, to 

related questions communicated by the NRC staff on December 23, 2015

(ML15357A326).

The inspectors also assessed the problem identification threshold, extent of condition 

reviews, and the prioritization and timeliness of corrective actions to determine whether 

NextEra personnel were appropriately identifying, evaluating ASR-related problems 

associated with the CEB, RHR/CS Vault and other ASR-affected structures at Seabrook 

Station. The inspectors compared actions taken by the Seabrook staff to NextEra’s 

Corrective Action Program (CAP) implementing procedures and 10 CFR 50, Appendix B.
3

b. Findings

Residual Heat Removal and Containment Spray (RHR/CS) Vault 

Introduction. The team identified a violation of Appendix B, Criterion V, “Instructions, 

Procedures, and Drawings” involving Seabrook Station staff failing to perform an 

operability evaluation for an identified non-conforming condition. Specifically, the team 

identified that NextEra staff accepted their vendor’s structural assessment report of the 

RHR/CS Vault on March 17, 2015, which identified an ASR induced structural load not 

considered in the design code of record. However, Seabrook staff did not complete an

appropriate immediate operability evaluation, initiate a new Prompt Operability 

Determination or revise their POD for the RHR/CS Vault to evaluate this information.

Description. The team reviewed the following Action Reports (ARs) and corrective 

action program documents to assess NextEra’s response to observed ASR-related 

structural deformation and bulk expansion and cracking of the RHR/CS Vault:

 ARs 01664399 and 01757861 – These two ARs address a Prompt Operability 

Determination, dated June 25, 2012, that concluded the RHR/CS Vault, along 

with a number of other ASR-affected structures at Seabrook Station, were

operable but degraded. NextEra staff identified that the presence of ASR 

adversely affected the mechanical properties of concrete. The basis for 

concluding that the ASR-affected structures remained operable was the result 

of re-evaluating design basis calculations for these structures assuming a 

bounding value for critical limit state degradation and confirming sufficient 

margin remained between design capacity and design demand/loads to 

account for the assumed worst-case ASR degradation. The inspectors 

determined that Revision 2 to this POD has remained in effect and valid since 

mid-2012, but did not address the bulk expansion associated with ASR and 

the consequential impact of structural cracking and deformation.

 AR 01929460 – Initiated on December 23, 2013, to address concerns 

expressed by the NRC resident inspectors that the observed macro-crack at 

the minus 26-foot elevation of the RHR/CS Vault may have adverse structural 

implications and may degrade the fire barrier rating of the wall separating the 

RHR and CS equipment trains. The Operability Notes stated that NextEra 

engineering staff’s review concluded the cracks do not cause an 

unacceptable condition for either a fire barrier or structural consideration. 

This immediate operability evaluation was later supplemented by a Condition 

Evaluation, dated December 23, 2013, and then revised on January 13, 

2014.

Assignment 03 was initiated to have a vendor complete a condition 

assessment of the RHR/CS Vault using ACI 349.3R guidelines. The 

“Completion Notes” for Assignment 03 stated that the follow-up actions 

(recommendations) from the Wiss, Janney, Elstner Associates (WJE) 

Condition Assessment (FP100903) have been added to AR 01977456.

 AR 01977456 – Initiated on July 10, 2014, to address the NRC resident 

inspectors having identified a Green finding involving the failure to have 

appropriately addressed the RHR/CS Vault macro crack in accordance with 

Seabrook Station Structures Monitoring Program (SMP).
4

Specifically, the observed macro crack exceeded the SMP Tier 2 criteria 

(reference ACI 349.3R) and warranted a structural evaluation, but NextEra 

staff had failed to complete the structural evaluation. The inspectors 

determined the Operability Notes used a “template” operability assessment 

statement that identified that the issue (failure to adhere to the SMP) did not 

directly relate to the functionality of system, structure or component.

The inspectors determined NextEra staff processed and accepted the WJE “Condition 

Assessment of the Cracking in RHR and CS Equipment Vault,” dated March 5, 2015, 

into the Seabrook documentation tracking system under Foreign Print (FP) 100903 on

March 17, 2015. Included in this document was a limited structural analysis 

(Section 5.2) which described the cracks as likely resulting from an ASR-related load not 

previously accounted for in the design basis structural calculation. The inspectors 

determined that this statement represented a non-conforming structural loading 

condition and was not identified by NextEra staff as new information which impacted 

their RHR/CS Vault prompt operability determination (POD). The inspectors observed 

the FP100903 recommendations (Section 7) were added to this AR (01977456) under 

Assignments 13, 17 and 18, for tracking purposes. 

In response to NRC inspectors’ questions, NextEra staff issued a POD (Action 20) under 

AR01977456 on February 12, 2016, for the RHR/CS Vault to address the nonconforming condition identified in FP100903. The POD concluded the RHR/CS Vault 

was “operable, but nonconforming.” Based upon NRC inspector review, the more 

correct characterization, per EN-AA-203-1001, should be “operable, but degraded.” This 

non-compliance with EN-AA-203-1001 is considered a minor issue, but is documented 

for assessment purposes (reference AR 02120109, Assignment 04). The team’s

technical review of the RHR/CS Vault POD is documented in Section 4OA2.2 of this 

report. 

 AR 02085029 – Initiated on October 23, 2015, following an NRC resident 

inspector briefing of plant management. The inspectors questioned the 

timeliness of implementation of recommendations NextEra staff accepted as 

outlined in the WJE Condition Assessment. The inspectors identified that 

implementation dates of June 2015 were revised to December 2015, without 

NextEra staff receiving approval from their internal management review 

committee (MRC). The Operability Notes for this AR was a “template”

operability statement (same as used for AR01929460 above). See Section 

4OA2.3 below for disposition of this observation.

Containment Enclosure Building (CEB)

Introduction. The team identified a violation of Appendix B, Criterion V, “Instructions, 

Procedures, and Drawings involving NextEra staff at the Seabrook Station failing to 

perform an operability evaluation for an identified non-conforming condition. Specifically, 

the team identified that NextEra’s staff accepted their vendor’s report related to the CEB 

which described ASR induced loads from internal expansion not considered in the 

design code of record (ACI 318-71). Further, Seabrook staff did not complete an 

appropriate immediate operability evaluation, initiate a new POD or revise their current 

POD for the CEB to evaluate this information.
5

Description. The team reviewed the following ARs and corrective action program 

documents to assess NextEra’s response to observed ASR-related structural 

deformation of the CEB:

 ARs 01664399 and 01757861 – These two ARs address a Prompt Operability 

Determination, dated June 25, 2012, that concluded the CEB, along with a 

number of other ASR-affected structures at Seabrook Station, were operable, 

but degraded. The inspectors observed Revision 2 to this POD remained in 

effect and valid since mid-2012, but does not address the bulk expansion 

associated with ASR or the consequential CEB deformation.

 AR 02004748 – Initiated on November 4, 2014, as a result of the NRC 

resident inspectors identifying a degraded mechanical seal in the mechanical 

penetration area of the Containment Enclosure Ventilation Area (CEVA) 

building. Follow-up examination by NextEra staff identified that the fire seal 

and associated seismic gap was degraded due to differential movement or 

deformation of the CEB wall relative to the CEVA building walls. This AR

resulted in the Seabrook staff initiating a POD (AR 02044627) to ensure the 

CEB seismic gaps were being maintained. In addition, NextEra staff initiated

an Apparent Cause Evaluation (ACE) to evaluate the causes and effect of the 

CEB deformation. 

 AR 02014325 – Initiated on December 19, 2014, as a result of the findings 

from the engineering staff’s preliminary CEB walkdowns (required or initiated 

per AR 02004748). The title of AR 02014325 is “Assess potential aggregate 

impact of CEB movement,” and listed seven separate ARs identifying 

impacted systems or components. The Operability Notes for this AR stated 

that “This AR is written to evaluate the overall impact of an observed plant 

condition. The results will need to be evaluated for operability as they come 

up. This AR by itself has no impact on operability of TS or SSCs.” Per 

Assignment 02 of this AR, the Seabrook Management Review Committee 

(MRC) approved a charter to complete a root cause evaluation (RCE) of the 

observed CEB deformation and canceled the ACE assigned via AR 

02004748. The inspectors noted that a CEB structural evaluation was 

integral to the RCE efforts.

 AR 02044627 – Initiated on April 30, 2015, following the completion of 93 

measurements completed by NextEra’s contractor Simpson, 

Gumpertz & Heger Associates (SG&H) of the CEB seismic gaps. During 

MRC review of this AR on May 5, 2015, a POD was assigned (02) due by 

May 7, 2015, and completed on June 11, 2015. In addition, assignments 

were initiated to revise the SMP (04), perform periodic (six month frequency) 

seismic gap measurements (07), and complete a revision to the Updated 

Final Safety Report (UFSAR) (08).

 CEB RCE Report entitled “Containment Enclosure Building Local 

Deformation,” was issued August 5, 2015, and approved August 31, 2015. 

The RCE used the following Problem Statement: “Structural movement of 

the seismic Category 1 CEB structure, which has resulted in damage to fire 

seals and movement in flexible conduit connections, could result in future 

adverse impact to the CEB ventilation function and adjacent structures and 

components.”
6

NextEra identified two major causal factors, as follows:

RC1 – “Internal expansion (strain) in the CEB concrete produced by ASR in the inplane direction of the CEB shell and ASR expansion in the backfill concrete, 

coincident with a unique building configuration.”

RC2 – “Due to an organizational mindset that conditions such as concrete cracks, 

water infiltration and misalignment issues were acceptable and inconsequential, the 

Organization failed to formally perform and document comprehensive evaluations of 

building conditions. These building conditions could have potentially revealed more 

significant underlying conditions affecting other structures, such as localized 

deformation of the CEB.”

Multiple corrective actions were initiated by NextEra staff, including several PODs for 

systems impacted by the CEB deformation. However, NextEra staff did not initiate a 

POD or re-evaluate the current open PODs (AR 01664399/AR 1757861) to assess CEB 

structural performance with the newly identified ASR deformation mechanism. Further, 

the assignment to complete a structural evaluation per AR 02014325 was not 

implemented. The team viewed this as a missed opportunity by the NextEra staff to 

have assessed CEB structural performance, following the identification of a new and 

different ASR impact (load) on affected structures.

 AR 02094762 – Initiated on December 2, 2015, as a result of NextEra receipt 

of SG&H report (FP100985) titled “Evaluation and Design Confirmation of AsDeformed CEB.” This evaluation was completed coincident with the CEB 

RCE. The AR was initiated to track the implementation of recommendations 

from the SG&H structural evaluation involving the performance of additional 

engineering reviews and monitoring. The team identified that the Operability

Notes documented a “template” operability paragraph, stating that an 

operability determination was not required. The team’s review of FP100985 

identified that the vendor had concluded that the CEB deformation was a 

result of structural response to both internal loading due to ASR expansion 

and external loading due to expansion of ASR-affected concrete backfill. 

Review of CAP records by the team identified that the MRC reviewed this AR 

on December 8, 2015, and assigned an action to complete a Condition 

Evaluation by December 30, 2015. The Condition Evaluation was entered 

into the CAP on December 30, 2015, and provided a qualitative basis for the 

continued operability of the CEB. Per the December 30, 2015, Condition 

Evaluation, AR 02094762 Assignment 02 was initiated to update the current 

CEB POD (AR 01664399) by February 29, 2016. These assignments were 

made in the timeframe when NRC inspectors were questioning NextEra staff 

regarding the POD process and the information in FP100985.

On February 19, 2016, NextEra approved a POD (under AR 02094762) that addressed 

the CEB nonconforming conditions identified in FP100985 involving ASR bulk expansion 

loading of the structure resulting in building deformation. The POD concluded the CEB 

was “operable, but degraded.” The team’s detailed technical review of the CEB POD is 

documented in Section 4OA2.2 of this report. 
7

 AR 02109229 – Initiated on February 10, 2016, as a result of an onsite NRC 

PI&R inspection debrief with station management. The inspectors 

questioned whether NextEra staff had defined ASR induced deformation in 

the context of the current licensing basis and ACI 318-71. The team’s review 

concluded that the results of the SG&H structural evaluation of the CEB and 

WJE condition assessment of the RHR/CS Vault independently identified that 

the deformation (and macro-cracking) caused by ASR expansion represented

a structural load not considered by ACI 318-71. Accordingly, this ASRinduced structural loading is a non-conforming condition.

Summary – NRC Team Reviews of the RHR/CS Vault and CEB 

The team determined that NextEra staff did not complete an appropriate review of the 

WJE report (FP100903) for the purpose of assessing the implications of the report 

conclusions on current RHR/CS Vault structural performance and operability. The 

team’s review of the WJE Condition Assessment identified that the report contained 

sufficient information to conclude that ASR generated loads (internally generated by the 

structure) were causing the RHR/CS Vault wall displacement and cracking, and that no 

design basis loads could have conceivably caused the observed condition. 

Consequently, it was reasonable to conclude that the ASR imparted structural loading 

constitutes a non-conformance with ACI 318-71, the building and construction code of

record, which does not consider ASR-induced loads.

The team also concluded, based upon their review of the SG&H structural evaluation 

(FP100985), that sufficient information was documented in the evaluation for NextEra to 

have concluded that a new or updated operability determination for the CEB was 

warranted. Specifically, the ASR-induced loads resulting in the deformation of the CEB 

were not considered in the original design loading calculations (non-conforming 

condition), and based upon the preliminary finite element analysis (FEA) results, design 

margins were potentially impacted due to ASR expansion induced loading.

From review of the above ARs and follow-up interviews with Seabrook staff, the team 

determined that NextEra did not consider the results of either the WJE condition 

assessment (FP100903) or SG&H structural evaluation (FP100985) as representing 

significantly new or different information that would change their engineering judgment 

(albeit undocumented) regarding the continued operability of either the RHR/CS Vault or 

CEB. However, the inspectors concluded NextEra staff did not adhere to their Fleet 

Procedure EN-AA-203-1001 in documenting this operability determination until identified 

by the NRC.

Analysis. The team determined that the two examples of failure to identify structural 

loading due to ASR expansion as a non-conforming condition and to promptly evaluate 

the impact of this condition on the operability of the affected structures is a performance 

deficiency. This performance deficiency is considered to be more than minor because

the non-conforming condition adversely impacts the structural integrity design attribute of 

the reactor safety barrier integrity and mitigating systems objectives. In addition the 

finding is similar to more than minor Example 3.i of Appendix E of IMC 0612. The finding 

was evaluated in accordance with IMC 0609, Appendix A, “The Significance

Determination Process for Findings At-Power,” Exhibit 3, “Barrier Integrity Screening 

Questions,” and screened as very low safety significance (Green) because the finding 

only represents a degradation in design margin and did not impact the radiological 

barrier function of the affected structures. The finding had a cross cutting aspect in the 

area of problem identification and resolution, P3, timely resolution of issues.
8

Specifically, NextEra did not fully evaluate conditions adverse to quality, including 

evaluating the effects of the ASR expansion-induced loads on operability of certain 

structures, in a timely manner following identification by a vendor provided engineering 

analysis.

Enforcement. 10 CFR 50, Appendix B, Criterion V, “Instructions, Procedures, and 

Drawings,” states that activities affecting quality shall be prescribed by documented 

instructions, procedures and drawings, and shall be accomplished in accordance with 

these instructions, procedures or drawings. NextEra Nuclear Fleet Administrative 

Procedure, EN-AA-203-1001, “Operability Determinations/Functionality Assessments,” 

Sections 4.2 thru 4.4 identify the responsibilities and requirements for preparation and 

approval of Immediate Operability Determinations (IOD) and Prompt Operability 

Determinations (POD) for establishing the acceptability of continued operation of a plant 

structure, system, or component that is suspected to be degraded or nonconforming. 

Contrary to the above: (1) no immediate operability determination (IOD) was performed 

on March 17, 2015, (or Prompt Operability assigned) when NextEra entered the WJE 

condition assessment recommendations into Assignment 03 of AR 01977456; and (2) no 

IOD was performed on December 2, 2016, (or Prompt Operability assigned) when the 

NextEra staff entered the SG&H structural evaluation recommendations in to the CAP 

per Assignment 01 of AR 02094762. Operability determinations were not initiated for the 

RHR/CS Vault or CEB until prompted by the NRC staff (on or about December 23, 2015) 

following a conference call between the NRC and NextEra staffs to convey questions 

regarding the NRC’s review of the CEB RCE and FPs 100895 and 100903.

Because this performance deficiency is a repeat problem and representative of an 

organizational insensitivity to the need for prompt identification and evaluation of an 

ongoing ASR degradation mechanism (a unique structural performance challenge), this 

violation is being cited and warrants a docketed response to address the corrective 

actions taken or planned to prevent recurrence. (NOV 5000443/2016008-01 Failure to 

Complete Operability Determinations for ASR-Affected Structures)

c. Observations

The team conducted in-office reviews and follow-up discussions with the Seabrook staff 

and contractors regarding NextEra’s response to the questions posed during a 

December 23, 2015 conference call (ML14014A378). The team considered the 

responses to better understand the technical bases for NextEra’s engineering 

evaluations and operability assessments of the CEB and RHR/CS Vault. NextEra’s 

revised response was provided to the NRC on April 14, 2016 and is publicly available in 

(ML16117A312).

1) The team re-examined the Containment POD (AR 1804477), Revision 00, dated 

November 1, 2012, to re-assess the validity of the operability evaluation based upon the

recent identification of ASR induced bulk expansion and deformation of other safety 

related ASR-affected structures. Based upon NRC staff and licensee walkdowns, no 

evidence of ASR-related bulk expansion has been identified on the containment 

structure. As documented in the POD, the accessible outer surface of containment 

(the inner surface is inaccessible due to the stainless steel liner/fission product barrier) 

exhibits evidence of localized ASR micro-cracking in three areas in the annulus region 

and one location in the mechanical penetration area. The micro-cracking in the 

mechanical penetration area exceeded the ACI 349.3R Tier 2 criteria and prompted the 

structural evaluation accompanying the POD. Team review of the containment POD 

concluded that the operability evaluation remains valid and that the ASR-affected 
9

concrete remains non-conforming with ASME Section III, Division 2, (the design and 

construction code of record for the containment). The team noted that the five-year 

ASME Section XI, IWL-2410 in-service inspection of the entire outer containment 

surface is scheduled by NextEra to be completed later in 2016.

Based upon the team’s review of the POD, Revision 00, it was unclear how NextEra’s 

staff classified the ASR-affected concrete of containment. Specifically, the POD used 

Revision 1 of Form EN-AA-203-1001-F01 of the NextEra Fleet Procedure EN-AA-203-

1001, and classified the ASR impact on containment as “Operable and above Full 

Qualification.” This classification also considered that “the degraded SSC meets Full 

Qualification as described in the Current Licensing Basis.” The inspector’s review of the 

current revision to EN-AA-203-1001-F01, Revision 09, identified that the comparable 

POD classification would be “Operable and Fully Qualified with Reduced Margin.” The 

Revision 09 classification implied that the subject SSC meets all CLB and qualification 

requirements. However, the team’s review of the Seabrook Updated Final Safety 

Analysis Report (UFSAR), Sections 3.8.1.6.a (page 45) and 3.8.4.6 (page 146) identified 

that “ASR is considered to be a degraded nonconforming condition pursuant to 

Regulatory Issue Summary (RIS) 2005-20.”

UFSAR Revision 13-011, dated March 4, 2013, updated the description of the 

containment structure and all other Category 1 structures. NextEra acknowledged this 

observation and took action to revise their containment POD to ensure that the nonconforming condition is addressed in their planned license amendment request submittal

(Reference AR 02120109, Assignment 10).

2) The team reviewed the results of a December 18, 2015, concrete core removed from the 

Spent Fuel Pool telltale drain sump. This core was removed in accordance with a 

license renewal commitment (No. 67) and was tracked via AR 00392697. Petrographic 

examination of the core specimen (designated FSB-1) identified no evidence of boric 

acid degradation, but did reveal “minor ASR features.” The examination was 

documented in Laboratory Report 151303-LR-1, Revision 0, “Microscopic Examination 

of a Concrete Core Removed from Seabrook Station for Deterioration Mechanisms,” 

(Foreign Print 101052).

In conjunction with the review of the SFP sump core results, the team reviewed a series 

of ARs and associated evaluations completed to assess structural movement 

(deformation) of the reinforced concrete in the Fuel Storage Building (FSB). Dating back 

to 2009 (reference AR 00196973) movement of FSB structural elements around the 

spent fuel pool caused deformation of deck plates above the fuel transfer canal and 

around the new fuel vault. Since 2010, NextEra, utilizing a contractor, has performed

periodic laser measurements of the FSB to monitor the deformation. Team review of the 

measurement data taken between December 2010 and February 24, 2016, concluded 

that the measurement trends are not attributable to building settlement or thermal 

expansion and contraction. Instead, the trends indicate a bulk expansion affect,

attributable to ASR, in spite of the absence of the more typical signs of ASR, such as 

patterned cracking and associated ASR gel surface extrusions. NextEra staff 

acknowledged this observation and indicated that the FSB would be one of a number of

additional structures to receive a comprehensive Finite Element Analysis (FEA) to 

evaluate the impact of ASR on structural performance and possible POD (Reference AR

02120109, Assignment 09).
10

3) The team confirmed through their detailed review of the associated ARs involving 

structural deformation, that assignments were initiated to revise the UFSAR to reflect 

this newly identified ASR attribute.

4) New PODs were documented for the structural deformation impacting the RHR/CS Vault 

and the CEB. The team observed that for both of these reinforced concrete structures, a 

second POD (ARs 01664399 and 01757861) was in effect addressing the material 

property degradation associated with ASR. Although the respective PODs addressed

different attributes of an ASR-affected structure (one material property and the other 

deformation caused by bulk ASR expansion), in the case of the CEB structural 

evaluation and the supporting FEA, the material property degradation is concluded to not 

have a detrimental impact on structural performance based on tests completed at FSEL. 

Consequently, the team concluded the CEB deformation POD was inconsistent with the 

original material properties POD. NextEra acknowledged this observation and planned 

to conduct a collective review of the open PODs to determine how best to address the 

non-conforming ASR-related attributes (Reference AR 02120109, Assignment 11).

5) For both the RHR/CS Vault and CEB PODs, the team identified that neither POD 

identified a monitoring method to periodically affirm the validity of the operability 

evaluations. The inspectors determined monitoring (either time or measurement based) 

is warranted because ASR appears to be slowly progressing in reinforced concrete 

structures at Seabrook Station. The team noted that an important assumption used in 

the CEB FEA is that the modeling depicted a limited strain value of 0.03% (comparable 

to the most advanced ASR aged large specimens in the FSEL testing program). 

NextEra staff acknowledged this observation and planned to develop appropriate 

monitoring methods and associated evaluation thresholds to ensure operability 

evaluations remain valid and that remediation actions, if necessary, are implemented 

prior to ASR-affected structures becoming compromised (Reference AR 02120109, 

Assignments 03 and 05).

.2 Review of Prompt Operability Determinations

CEB POD Review

The POD for the CEB concluded that deformation in the structure was attributed 

primarily to ASR expansion in CEB concrete and concrete backfill surrounding the CEB. 

The POD concluded that the structure is “operable but degraded.” This conclusion was 

based on the results of an FEA of a model of the CEB that accounted for the deformed 

shape and effects of ASR expansion. The team reviewed the POD and the associated 

FEA, and found the assumptions and conclusions reasonable. The team observed that 

the POD followed NextEra’s criteria for “operable but degraded” in that the CEB does not 

meet all CLB requirements, but is capable of performing specified functions. The team

also affirmed NextEra’s determination that compensatory measures are required. 

NextEra staff indicated that they are in the process of collecting additional information, 

and will update their POD, as necessary, based on additional information. During its 

review, the team noted that NextEra staff made an assumption regarding the yield 

strength of the concrete reinforcing steel that was not fully supported by the available 

construction test results. NextEra staff acknowledged this issue and tracked actions to

revise their POD to include an appropriate steel yield strength value, for operability, 

based on Certified Material Test Results (Reference AR 02120109, Assignment 06).

This issue was considered minor as it did not impact POD conclusions. The team also 

questioned the limits as to which the POD would continue to be applicable and valid
11

considering ASR is an ongoing degradation mechanism. NextEra staff stated they plan 

to revise their POD to include a ‘threshold value’ (either time based or measurement 

based) that will determine the applicability of the POD and will require the POD and 

conclusions to be re-evaluated if the threshold is reached (AR 02120109, Assignment 

05). The team observed that NextEra staff continued to refine their FEA to more 

accurately represent the in-situ conditions in the model: (1) taking more measurements 

of the structure to better represent the actual shape within the model; (2) refining the 

application of the ASR degradation to the model to more accurately represent the ASR 

identified on the actual structure; and (3) developing load factors to use when assessing 

the internal ASR expansion loading in the structure.

NextEra staff stated that developing these load factors would allow them to apply the 

ASR effects to the model in a fashion that is similar to that used in the design code of 

record. NextEra staff further indicated that these updates will be applied to the model 

and the structure will be reanalyzed, and any necessary updates will be made to the 

operability determination. 

RHR/CS POD Review

The POD for the RHR/CS Vault concluded that the observed horizontal macro cracking 

is likely due to internal strain from ASR expansion in the vertical direction and that the 

structure is “operable but nonconforming.” The team reviewed the POD and found the 

assumptions reasonable based on NextEra’s current understanding of the cracking 

mechanism. However, the team questioned NextEra’s conclusion that the structure is 

“operable but nonconforming.” NextEra’s guidance states that an “operable but 

nonconforming” SSC “meets CLB functional requirements, but is nonconforming due to 

inadequate design, testing, construction, modification, or documentation.” The team 

determined that NextEra staff has not shown that the concrete components affected by 

the horizontal cracking meets all CLB functional requirements, and therefore the 

classification level should be “operable but degraded.” NextEra staff acknowledged this 

observation and planned to revise their POD (Reference AR 02120109, Assignment 04). 

The team concluded this issue was minor because, notwithstanding their original 

conclusion, NextEra staff were developing monitoring plans appropriate for a structural

designation of “operable but degraded.” 

NextEra staff indicated that they may revise their POD based on the results of ongoing 

investigations being conducted by their contractor (WJE). These investigations are 

expected to be completed by May 2016. NextEra staff also plan to revise their POD to 

include a ‘threshold value’ (either time based or measurement based) that will limit the 

applicability of the POD and will require the POD to be updated if the threshold is 

reached (Reference AR 02120109, Assignment 03). NextEra staff further indicated that 

they intend to include the RHR/CS Vault in a ‘susceptibility analysis’ to determine how 

likely it is that the vault may undergo additional cracking due to ASR. Depending on the 

results of the analysis, NextEra staff stated that they may develop a finite element model 

to address RHR/CS Vault operability. The team concluded these planned actions were 

appropriate to continue to verify the RHR/CS Vault capability to perform its intended 

safety related functions. 
12

.3 RHR Vault Corrective Action Timeliness Observation

The inspectors determined that NextEra’s implementation of corrective actions 

associated with the NRC identified degradation of the RHR vault concrete structure 

(AR 01977456) was not completed in a timely manner and contrary to NextEra 

Procedure PI-AA-104-1000, ‘Corrective Action,’ Revision 6. Specifically, 

PI-AA-104-1000 provides guidelines to consider when establishing due dates for low risk 

corrective actions and states that routine corrective actions to prevent recurrence should 

be completed within 120 days. In addition, PI-AA-104-1000 states that the Management 

Review Committee (MRC) is responsible for reviewing justifications and approving due 

date extensions for significance level (SL) 1, 2 or 3 AR assignments.

Contrary to this procedural guidance, SL 2 AR 01977456, Assignment 17, “Develop 

design change to implement (FP100903) recommendations,” was initially assigned a 

due date of April 30, 2015, extended to June 30, 2015, and then extended again to 

December 1, 2015, without appropriate justification or MRC approval. Assignment 17 

was extended to January 8, 2016 with MRC approval and closed-out on January 7, 2016

with the issuance of an Engineering Design Change. The elapsed time from corrective 

action assignment to completion was 245 days, well in excess of the 120 day guidance

without MRC justification and approval.

The specific corrective actions associated with this SL 2 AR and incorporated into a 

design change package involve:

 Install crack gauges at 25 locations to monitor progression of RHR vault 

cracking

 Extract 20 concrete cores from the RHR vaults for material testing to identify 

expansion mechanism

 Install large-scale measurement devices to monitor vertical expansion of the 

RHR vault walls

 Install relative humidity and temperature probes at three locations in each

train of the RHR vaults to measure moisture gradient in the wall to better 

understand ongoing behavior of ASR and/or drying shrinkage mechanisms

The inspectors evaluated this performance deficiency in accordance with the guidance in 

IMC 0612, Appendix B, “Issue Screening,” and Appendix E, “Examples of Minor Issues,”

and concluded this performance deficiency was minor in safety significance. 

Additionally, this issue is closely related to NextEra’s inadequate performance in not 

initiating appropriate immediate and prompt operability determinations (PODs) when 

new information was received in FP100903. An appropriate POD would have better 

informed the timing of planned corrective actions. This issue is addressed in the Notice 

of Violation included in this report. Accordingly, this performance deficiency is not 

subject to further enforcement action, but is addressed in the Seabrook CAP (reference 

AR 02085029) and documented for performance assessment purposes.
13

4OA5 Other Activities

.1 (Closed) Unresolved Item 05000443/2015004-01, Issue of Concern Regarding 

Implementation of the Seabrook Structures Monitoring Program and Structural 

Evaluations of the CEB and RHR/CS Vault.

The inspectors had identified potential shortcomings in NextEra’s implementation of the

Seabrook Structures Monitoring Program, acceptance of evaluations via the document 

control (Foreign Print) process, and implementation of the Corrective Action Program as it 

relates to Foreign Print 100895 for the CEB and Foreign Print 100903 for the RHR/CS 

Vault walls. Additional inspection identified a performance deficiency and associated 

violation (cited in this report) with two examples, involving NextEra’s failure to 

appropriately evaluate non-conforming conditions identified in Foreign Print 100895 for the 

CEB and Foreign Print 100903 for the RHR/CS Vault (See Section 4OA2.1.b).

This unresolved item is closed.

4OA6 Meetings, Including Exit

On March 24, the inspectors presented the results of this inspection to 

Mr. Dean Curtland, Site Vice President, and other members of Seabrook Station and 

NextEra Corporate staffs. The inspectors also confirmed with NextEra that no 

proprietary information was retained by inspectors during the course of the inspection.
A-1

Attachment

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

NextEra Personnel

B. Brown, Design Engineer

V. Brown, Senior Licensing Analyst

K. Browne, Special Projects Director

E. Carley, Engineering Supervisor

S. Chesno, Performance Improvement Manager

M. Collins, Engineering Director

D. Curtland, Site Vice President

A. Dodds, Plant General Manager

K. Douglas, Maintenance Director

M. Guth, Licensing Manager, Turkey Point

M. Hanson, Assistant Operations Manager

L. Nicholson, Regulatory Affairs Director

M. Ossing, Licensing Manager

V. Pascucci, Manager, Nuclear Oversight

S. Ramdeen, Civil Engineering Chief

D. Ritter, Operations Director

J. Simons, MPR Associates

C. Thomas, Senior Licensing Engineer

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened

05000443/2016-008-01 NOV Failure to Complete Operability Determinations for 

ASR-affected Structures (4OA2.1)

Closed:

05000443/2015-004-01 URI Issue of Concern Regarding Implementation of the

Seabrook Structures Monitoring Program and

Structural Evaluations of the CEB and RHR/CS

Vault (4OA5)
A-2

LIST OF DOCUMENTS REVIEWED

Procedures

EN-AA-203-1001, Operability Determinations/Functionality Assessments, Revision 21

PI-AA-104-1000, Corrective Action, Revision 6

Engineering Department Standard 36180, Structural Monitoring Program, Revision 06

NexEra Nuclear Policy PI-AA-01, Corrective Action Program and Condition Reporting, 

Revision 03

Plant Engineering Guidelines, PEG-98, CEB Extent of Condition Equipment Walkdown, 

Revision 00

Reports

Seabrook Station Updated Final Safety Analysis Report, Revision 16 Foreign Print (FP100903), 

Wiss, Janney, Elstner (WJE) Associates “Condition Assessment of the Cracking in RHR and 

CS Equipment Vault,” dated March 5, 2015, Revision 0

FP101055, Condition Assessment of Cracking in the RHR and CS Equipment Vault –

Second Visit, dated 2/6/16

Containment Enclosure Building Local Deformation, Event Date December 19, 2014, issued 

August 5, 2015 (reference CR 2014325)

FP100985, Evaluation and Design Confirmation of As-Deformed CEB, dated November 2015

FP100915, CEB Site Visit Report, dated July 14, 2015

Evaluation of OASIS Inspection Data, dated January 2015

OASIS Report, NextEra Energy Services Seabrook, NH, Fuel Storage Building Inspection, 

dated February 23-24, 2016

FP100903, Condition Assessment of Cracking in RHR and CS Equipment Vault, dated 

3/17/2015

Action Request

02016863

00196973

02094762

01804477

02094762

02014325

02044627

02004748

02108728

02085029

02056483

01977456

01929460

02109229
A-3

LIST OF ACRONYMS

AR Action Request

ACE Apparent Cause Evaluation

ACI American Concrete Institute

ASR Alkali-Silica Reaction

ASME American Society of Mechanical Engineers

CB Control Building

CEB Containment Enclosure Building

CEVA Containment Enclosure Ventilation Area

CFR Code of Federal Regulations

CLB Current Licensing Basis

CR Condition Report

CS Containment Spray System

DRS Division of Reactor Safety

EC Engineering Change

EN Procedural Notice for Engineering Department

FEA Finite Element Analysis

FIN Finding

FP Foreign Print

FSB Fuel Storage Building

FSEL Ferguson Structural Engineering Laboratory (At UT-Austin)

IMC Inspection Manual Chapter

IOD Immediate Operability Determination

IP Inspection Procedure

KSI Kilo-pounds per square inch

LAR License Amendment Request

LRA License Renewal Application

MRC Management Review Committee

NCV Non-Cited Violation

NOV Notice of Violation

NRC U.S. Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulation

OD Operability Determination

PD Performance Deficiency

POD Prompt Operability Determination

PSIG Pounds per square inch (gage) 

RCA Radiological Controlled Area

RCE Root Cause Evaluation

RHR Residual Heat Removal System

SDP Significance Determination Process

SG&H Simpson, Gumpertz & Heger Associates

SL Severity Level

SR Safety-related

SSC Structure, System, or Component

TIA Task Interface Agreement

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

URI Unresolved Item

WJE Wiss, Janney, Elstner Associates