NEXTera® · ENERGY~ 

U.S. Nuclear Regulatory Commission 

Attention: Document Control Desk 

Washington, DC 20555-0001 

Seabrook Station 

Reply to a Notice of Violation; EA-16-101 

SEABROOK 

June 6, 2016 

Docket No. 50-443 

SBK-L-16076 ' 

Reference: Seabrook Station, Inspection Report 05000443/2016008 Related to AlkaliSilica Reaction Affects on Safety-Related Concrete Structures and Notice of 

Violation 

NextEra Energy Seabrook, LLC (NextEra Energy Seabrook), has reviewed the subject 

Notice of Violation and files the attached Reply to Notice of Violation EA-16-101 

pursuant to 10 CFR 2.201. 

If there are any questions regarding this letter, please contact Mr. Michael Ossing, 

Licensing Manager, at (603) 773-7512. 

cc: NRC Region I Administrator 

NRC Project Manager 

NRC Senior Resident Inspector 

Sincerely, 

NextEra Energy Seabrook, LLC 

Eric McCartne)T 

Site Vice President 

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 
Attachment 1 to SBK-L-16076 
SBK-L-16076 

Attachment 1 

Page 1 of 3 

Statement of Violation: 

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

violation ofNRC'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. 

N extEra 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, I ODs 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, 

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

quality in accordance with its procedure. Specifically, NextEra received information 

from vendors identifying non-conforming 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 ofrecord) 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 

Contairu:llent Enclosure Building (CEB), a condition not conforming with ACI 

318-71. 

This violation is associated with a Green Significance Determination Process finding. 
SBK-L-16076 

Attachment 1 

Page 2of3 

NextEra Energy Seabrook's Reply to the Notice of Violation 

I. Reason for Violation 

The reason for the violation is that the reviewer of the vendor reports did not 

follow the requirements of EN-AA-203-1001, Operability Determinations I 

Functionality Assessments. The cause for the violation was determined to be an 

over-reliance on the site's subject matter expert for both technical and oversight 

roles. The subject matter expert was focused more on the potential impact on the 

structures, versus comprehensively documenting and dispositioning newly 

identified potential non-conforming conditions. 

II. Corrective Steps Taken and Results Achieved 

• On February 12, 2016, a Prompt Operability Determination for RHR 

Equipment Vault concrete cracking addressing the information contained 

in WJE report entitled "Condition Assessment of the Cracking in the RHR 

and CS Equipment Vault," was approved. (AR 1977456) 

• On February 19, 2016, a Prompt Operability Determination for 

Containment Enclosure Building deformation was approved. (AR 

2094762) 

• Established the expectation via a read and sign that a cross-discipline team 

will be utilized to review new vendor documentation for ASR and 

building deformation issues. 

III. Corrective Steps That Will be Taken including a comprehensive and integrated 

ASR corrective action plan for resolving ASR induced non-conformances with 

the current licensing basis and the date when the structures monitoring program 

will be revised to monitor the progression of ASR degradation related to bulk 

expansion and deformation: 

1. Reinforce the lessons learned from this event and the requirements ofEN-AA203-1001, including entry requirements and the need for timely and 

comprehensive I ODs and PODs, with Design Engineering. 

2. Revise the Building Structures Monitoring Program to capture the use of the 

cross-discipline team to review new vendor documentation for ASR and 

building deformation issues. 

3. A comprehensive and integrated ASR corrective action plan for resolving 

ASR-induced non-conformances with the current licensing basis has been 

developed and is provided in Attachment 2. 

4. The date the structures monitoring program will be revised to monitor the 

progression of ASR degradation related to bulk expansion and deformation is 

provided in Attachment 2. 
SBK-L-16076 

Attachment 1 

Page 3 of3 

IV. Date When Full Compliance Will Be Achieved 

Full compliance for the cited violation was achieved on February 19, 2016 when 

the second POD discussed in the notice of violation was approved by the Shift 

Manager. The schedule for the additional comprehensive corrective actions 

required by the NRC's notice of violation is provided in Attachment 2. 
Attachment 2 to SBK-L-16076 
SBK-L-1607 6 

Attachment 2 

Page 1of1 

A comprehensive and integrated ASR corrective action plan for resolving ASR induced nonconformances with the current licensing basis and the date when the structures monitoring 

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

and deformation: 

1. Submit a License Amendment Request to reconcile current licensing basis to address 

ASR impacts on structures inclusive of a methodology change for evaluating structural 

deformation of Seismic Category 1 structures. Due Date: July 31, 2016 

2. Revise ASR Structures Monitoring Program to include ASR induced deformation effects 

monitoring and methodology. Due Date: August 19, 2016 

3. Conduct Core Bore Sampling and Installation of extensometers to monitor out of plane 

expansion in various plant locations to be representative of plant structures' conditions 

and to allow monitoring of levels of ASR. Due Date: December 31, 2016 

4. Perform Susceptibility Evaluations on all Seismic Category 1 structures in a risk ranked 

progression order. Due Date: June 30, 2017 

5. Complete Final Detailed Analysis Calculations of record for all Required Structures for 

ACI Code 318-71 Compliance. Due Date: July 31, 2017