ML12054A712

DRAFT- from James Clifford to Robert Nelson Request for Technical Assistance Seabrook Station ALKALI-SILICA Reaction, Draft 7 (2)

ML12054A712
Person / Time
Site:	Seabrook
Issue date:	02/16/2012
From:	Clifford J Division Reactor Projects I
To:	Nelson R Division of Policy and Rulemaking
References
FOIA/PA-2012-0119
Download: ML12054A712 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

( ) *REGION I 475 Allendale Road King of Prussia, PA 19406 MEMORANDUM TO: Robert A. Nelson, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: James Clifford, Deputy Director Division of Reactor Projects

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE SEABROOK STATION ALKALI-SILICA REACTION Region I requests technical assistance from the Office of Nuclear Reactor Regulation (NRR) to evaluate the potential consequence of alkali-silica reaction (ASR) degradation of a safety related concrete structure at Seabrook Station. More specifically, based on NRR review for adequacy of a NextEra prompt operability determination (POD) and its associated open issues, NRC staff should be able to identify what additional information is needed in order to fully evaluate the impact of the degradation on the current licensing and design basis in the final operability determination for impe.trnt structures important-to-safety at the plant. As a-estthe primary case for review, the NextEra evaluation was for the Seabrook Control Building ("B" Electrical Tunnel and Penetration Room) in light of the recently discovered degradation mechanism. Other impe.tant strucutures important-to-safety within the scope of the maintenance rule are-have also been affected by the ASR problem. and they aro within the ccope of the mainte.nan,*e ru-. Accordingly, additional Task Interface Agreements may be necessary such as for a review of the final operability determination results for other buildings also exhibiting the ASR problem.

Background

NextEra (the licensee) analyzed concrete core samples from the interior surface of exterior walls of the Control Building as part of their assessment to support renewal of their license. In August 2010, tests undertaken as a part of the core sample analysis reported a change in material properties. The analysis reported the presence of an-(ASR)--de radation in core samples taken from chronically wet walls below grade, with reductions reported in the concrete compressive strength and modulus of elasticity from that expected. NextEra evaluated these parametric reductions to determine the impact on the design basis of the Control Building. By their process, the licensee performed an immediate and prompt operability determination (POD) and concluded, preliminarily, that the Control Building (CB) was operable but with reduced strength reserves to design capacity.

NextEra continued to evaluate the extent of this condition for five other safety related concrete buildings. The other five buildings for which concrete core samples were taken were:

Equipment Vault (housing ECCS equipment including that for Residual Heat Removal (RHR)],

RCA (Radiological Controls Area) Walkway, Emergency Feedwater Building (EFW), Emergency

R. Nelson 2 Diesel Generator (EDG) Building, and the Containment Enclosure Building (CEB). As of June 30, 2011 there are two open prompt operability determinations, one for the Control Building and one for the other five buildings collectively. The licensee found additional evidence of ASR in four of the five other buildings and they evaluated that information in a separate immediate and prompt operability determination using the same evaluation techniques as for the Control I Building. -the This evaluation is also considered preliminary or open. Based on NRC internal discussions, it appears that the calculation methods and correlations that NextEra used in their I prompt operability determination may not be fullyvalid-appropriate in light of the ASR problem.

NextEra's planned actions are two-fold: 1) to follow their operability determination process; and,

2) to follow the guidance in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," to develop an aging management program to support the license renewal application. Possible outcomes to the PODs are: 1) restored conditions (which may not be possible); 2) resolved conditions (use "as is" by procedure change incorporated or Action Request (AR) disposition approved); or 3) current licensing basis (CLB) revised (e.g., 10 CFR 50.59 evaluation)-. The licensee has posted on the Certrec internal website their operability determination process for reference (EN-AA-203-1001_005, No. 1 on Certrec Document Tab List)

NextEra's proposal related to license renewal was described in a letter dated April 14, 2011, under the response to NRC request for additional information B.2.1.31-1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11108A131). This letter describes periodic reviews for operability as information is developed to support the aging management review. At the time, the proposal included another analysis (termed "final" by NextEra) of the impact of ASR on the current licensing and design basis, including the extent of the condition, to be completed by June 2011. Since that letter and as noted above, the control building POD was kept open and a new immediate and POD were completed for the other five building core sample results. The subject NextEra letter also commits to an Engineering Evaluation to be completed in March 2012.

On June 29, 2011, the NRR Division of License Renewal issued another "Request for Additional Information" (ADAMS Accession No. ML11178A338) related to key aspects of NextEra's comprehensive plan for assessing the ASR problem for the Structures Monitoring Program including that for the Fuel Handling Building and Containment ("Followup RAI B2.1.31-1, B2.1.31-4, and B2.1.28-3). The response to this letter is due on or about August 13, 2011 and we expect it to reflect a comprehensive plan for determining operability/functionality of affected buildings along with plans for the development flo-of aging management review and program.

With respect to Part 50 requirements, Region I reviewed the NextEra current Structures Monitoring Program and found a violation of the maintenance rule for the control building. The finding is described in detail in NRC Inspection Report 05000443/2011002 (ADAMS Accession No. ML111330689). More details related to the newly discovered ASR issue were also documented in NRC Inspection Report 05000443/2011007 (ADAMS Accession No. ML111360432) as part of a license renewal inspection. The cover letter for the latter report notes that the aging management review for the ASR issue is not complete and that there is a need for a continuing review in the Part 50 and 54 areas. The staffs of Region I and NRR (Division of Engineering and Division of License Renewal) have been discussing actions since January 2011 to ensure that the Part 50 and 54 reviews are coordinated.

R. Nelson 3 The below listed documents were made available for review on the licensee's "Certrec" internal website. These documents reflect current NextEra view of operability for the Control Building and the associate tunnel and penetration room. The "Certrec' system was set up in order to facilitate NRC staff access to NextEra's intemal documents. please inform Region I and Comment [gt]: GEM: The document we NextEra if the document is to be printed, for review purposes, prior to doing sc. .......... review and any that are reviewed to form a staff decision need to be docketed.

1. (No. 2 on Certrec Document Library Tab List) C-S-1-10159 CALC 000, Rev. 0, 'B' Conme*t [6T21: Documents wi need to be printed for review- So pleae relect that need.

Electrical Tunnel Transverse Shear Evaluation Supplement to Calculation CD-20

2. (No. 4 on Certrec Document Library Tab List) C-S-1-10150 CALC 000, Rev. 0, Effects of Reduce Modulus of Elasticity - 'B' Electrical Tunnel Exterior Walls

3. (No. 5 on Certrec Document Library Tab List) CD-20-CALC, UE Control and Dieisel Generator Building Design of Material and Walls below grade for Electrical Tunnel and the Control Building (Original Design Calculation)

4. (No. 6 on Certrec Document Library Tab List) Action Request (AR) 581434 Prompt Operability Determination Reduced Concrete Properties Below Grade in B' Electrical Tunnel Exterior Walls.

Also, before the startup of Seabrook from a refueling outage in May 2011, on April 27, 2011, NRR Division of Engineering provided support by Performing an initial review ofing the following aIgdqocument - AR No. 1644074 which documents NextEra's basis for acceptabi-lity of the---- -- Commwn [GT3]: The document reviewed reduction in modulus of elasticity in light of concrete core testing using a [10 CFR 50.59 l seemed inomplete. not of an Appendlx B quality, and did not have any aignaturea or screening process without prior NRC staff review and approval._ This document has been ........ names of preparer, reviewer and approver.

uploaded to the Certrec file and it is related to a design change document which accepts the Comment [rT4j: NRR/DE d not provided reduced parameters of compressive strength and modulus of elasticity for the Control Building support for reviewing the 50.59 screening[

and the Containment Enclosure Building as a potential disposition for the operability determination (No. 10 on Certrec Document Library Tab List, Enclosure Bldg and Control Bldg MSP - Design Change Package Description No. EC-272057, Rev. 000, Concrete Modulus of Elasticity Evaluation). 0A**4Ie screening process was questioned by NRCELRM staff-,

SubouenlL. -NRR DE provided an iritial list of questions as noted in the attachment (with one question being withdrawn - question No. 7.j....................................... ................ .. Comment [TUJ: NRRIDE did no review Ithe 50.59 screenin. What Isthe relatdionship between quetin of the sreenink process The licensee is also planning an apparent cause review for the maintenance rule violation noted by ??? and th NRRIDE technica Msons for above. Corrective actions include a comprehensive walkdown of all ipoP,tant structures Sthen to be stated Inthe samne sentence here?

important-to-safetv with suspected ASR condition in accordance with a revised structures Please Mephras to put tings In fthcorrect monitoring program procedure that meets the latest ACI standard in the area (ACI 349.3R-02). perspective.

This has been completed for the control building, containment enclosure building, and the containment but the completion dates for the other buildings is tentatively August to September 2011. Further, they-the licensee plans to conduct a root cause evaluation of the ASR issue and it-which should be completed in time for incorporation into the planned March 2012 Engineering Evaluation as noted above.

Licensee Position To date, within the limitations of their testing and analysis, NextEra determined that none of the seismic category I structures tested have been found to be outside their design basis and were, therefore, operable with extent of conditions questions needing be addressed. The Seabrook design and licensing basis to which the licensee made these determinations was documented in UFSAR Section 3.8. NextEra is willing to address the attached questions from DE; but, it is uncertain if those questions will be addressed in the final operability determination currently

R. Nelson 4 scheduled for September 30, 2011. NextEra will be providing a comprehensive plan on or about August 13, 2011, in response to NRC letter of June 29, 2011, as noted above.

In light of the newly discovered ASR issue, it appears that NextEra technical -eviewers personnel are developing new insights for what key aspects must be addressed in the final operability determination for any building with evidence of ASR. NextEra is considering NRC staff questions to date and has hired consultants in this area. These consultants also will be developing a new model for the Containment Enclosure Building load analysis.

Reauested Actions In order for Region I to independently determine operability of the control building or any other important-to-safety structure affected by the ASR problem; and, as a toct primanycase, we need a review for adequacy of the control building prompt operability determination and any related open issues as identified by NextEra. This information would be applied to the any final operability for the control building and any other affected important-to-safety structures. The important-to-safety structures ar-theee-affected by the ASR problem aKIl-are within the scope of the maintenance rule whiGh-and_are also consistent with-these-within the scope fer-of license renewal. More specifically we need to independently develop a comprehensive set of issues to be applied to any final operability determination as a part of our oversight of the licensee's process and any new insights gained from NextEra's technical research.

Accordingly, Region I requests that NRR evaluate the adequacy of NextEra's control building prompt operability determination and its related open issues with particular focus, but not limited to, the below listed key technical questions. The licensee has provided a set of documents as noted on the reference Certrec website above but the NRR review should not be limited to those documents. Region I will facilitate ensuring that additional documents, as needed, are on the website or, as necessary, by an onsite inspection. NRR's determination should enable the staff to confirm that there is reasonable assurance of continued operability given the concrete degradation identified due to ASR for the control building once the final operability determination are made by NextEra for this or any other important structure affected by the ASR problem.

In the course of this review, Region I requests that NRR specifically identify any concerns with the assumptions, methodologies, or calculations, etc., along with the regulatory or other basis of each concern; and, notify Region I immediately if NRR finds that any of the reviewed documents for the control building do not provide reasonable assurance of continued operability of that building. As a minimum, the response to the TIA should include an independently developed comprehensive set of issues to be addressed in the final operability determination for the Control Building in order for us to further assess the licensee's process and their new insights gained for all important-to-safety structures with evidence of ASR.

1. Do the referenced questions represent a comprehensive list of issues that need to be addressed in the final operability determination for the Control Building, given the current view of operability by NextEra as reflected in the prompt operability determination?

Discussion: The reference questions are those listed in the attachment of this document and those questions posted in the NRC RAI request for additional information [(ADAMS Accession No. ML11178A338) dated June 29, 2011, related to key aspects of NextEra's comprehensive plan for assessing the ASR problem for the Structures Monitoring Program including that for the Fuel Handling Building and Containment (Followup RAI B2.1.31-1,

R. Nelson 5 B2.1.31-4, and B2.1.28-3)]. Ifthe issues are initially considered comprehensive, please give consideration to the below additional views produced by the regional technical staff. If the issues are not considered comprehensive, then identity those additional issues to be included with consideration to those listed below along with regulatory or other basis for the concern. An example would be the need for Poisson ratio calculations on core samples because there are assumed numbers in the UFSAR or the need for stiffness damage tests because of applicable ACI standard requires it in the current licensing basis.

2. What is the impotanc ofAre tensile strength measurements reguired on core samples from the ASR affected structure?, and distinguish its o inted.t thp ContrAl building vs. the containment strurture?If so. provide the iustification and technical basis for its significance ql with regard II to the design I I basis of the affected structure.

Discussion: No tensile strength testing is being performed on the concrete core samples and this question was raised in the RAI request for information in terms of how shear capacity is being determined. However, the Region I staff believe that the specific parameter of tensile strength of concrete may not be sufficiently accurate and therefore relevant in a constrained structure as the ASR pressure load is transferred to the rebar.

Available research in this area appears to be conflicting. For example, usiRg ASTM

• A researche.r sai, G.can hardly be assumed to be a material P t r t pressure contrtibution appears to be minim~al (on the order Of lass than 594 of the Izabal: yield based On preimin.ary research Of litrature.). Other papers including the The UFSAR for containment assume concrete in reinforced systems provide no tensile strength.

Considerable research mnay be needed inorder to 'ndependent establish a regulator,' 9F other basis in this aFea.

1"Re-viewh o-fthe splitting test standards frem a ffrature mnechanicS point of view!, G. Reeso, G. V.

Guiea,7 j. Planas, and M.Qeliss Facultad de Ingenieria, Univercidad Nacional de la Plata, La Plata, Argentina, Departamento de Giencia de Materiaoes, Univcrsidpd PelItAcnica doe Madrd, Madrid, Spain, 5 September 2000 13.

What is the importance, if any. of obtaining key parameter test data by conducting confined (tri-axial) core testing of samples from ASR affected structure? -------------------

I C-MMe E[Trr]: lent thi question Implicitly included In question 6?

Discussion: j, core sample with ASR does not represent the forces contained inthe structure because for this tes(.!n particular, elastic rebound is not considered. Fors ........ Cowmn rt [6rT]: What Is the test being tensile tests on core samples, the frictional influences inthe test itself are not [referred here?I accommodated. The frictional losses are further exacerbated by the standard laboratory practice of placing plywood on opposing faces of the tensile specimen to stop it from rolling off the test stand, thus restraining axial expansion of the sample. ------------------------------------- Consen [GTS]: I don't realy understand this discusslon Inthe contest of the question. This

4. Because the original design basis assumes no ASR is present during the design life of the discussion needs to be clarfled. Tdai testing of cores ts very rarety performed. The design structure, what. if any. are the specific original design assumptions affected by the presence philosophy In the codes based on parameters of ASR that are not clearly evident in the UFSAR design basis? obtained from normal core or cylinder tests do factor in confining or other 2D and 3D effects because the equations and prisions In the Discussion: For example several calculation methods such as the relationship between codes were developed based on extuensive compressive strength and modulus of elasticity to shear capacity and shear force are used testing Including reatstructural elemernt such as beams, slabs, columns, wall panels, frames in the seismic analysis. These assumed relationships may not be valid with ASR present in etc.

the structure.

R. Nelson 6

5. What is the appropriate ACI standard to be used for degraded concrete core sampling assessing in-situ ASR degradation for the control building (locations, numbers, frequency of sampling in the future, etc)?

Discussion: While this is an issue raised in the attachment, we need to know the regulatory or other basis for the use of either of two applicable standards or other more appropriate standard. One standard is ACI 228 used by NextEra for correlation to penetration resistance probe data and the other is ACI 214 (version 1965 is referenced in the UFSAR section 3.8.2.4). It should be further noted that a later revision of ACI 214 (ACI-214.R-03) provides for additional sampling in order to achieve a 95% confidence level. The ACI 228 appears to be met by NextEra but it requires less sampling. These standards were developed for general design and construction of concrete structures for non-nuclear applications. Technical research may be needed in order to determine their relevance for nuclear application in which the structures are heavily reinforced with rebar. This leads to the next set of questions.

Did NextEra adeauatelv Perform adeauate W.hat *9 the "m.plote ect of laboratory tests for

6. core sampling,_-including appropriate parameters obtained along with laboratory test conditions?

Discussion: Also, during the course of this review, please identify the need for any in situ testing of control building conditions including appropriate parameters to be obtained such as temperature and humidity along with test conditions for now and in the future. Also, provide guidance on where and how much rebar should be exposed in order to assess the effect on rebar from the ASR issue.

7. What is the effect-imgact of the alkali-silica reaction degradation o- the cu'.eAt anAd futre with regards to the ability of the control building to respond to design basis loads, including seismic events?

Discussion: NextEra is planning new modeling of the building loads including seismic. A review of the seismic analysis codes-is beyond the current capability of the Region I technical staff. This review should include an assessment of the need to analyze the foundations alone vs. the response of a whole structure when just the foundation is degraded.

8. Mew-welI-id NextEra adeau improve the structures monitoring program [n order to ----- - Com mIt [16T91: Ha. NextERa Issued a sufficiently characterize the buildings for an initial assessment in light of the ASR problem? revhed Inproved .tnr M. monft"rg progrM (SMP)? Is the asseset of the ASR Issue at Seabrok being petfomoed under the SMP Discussion: During the negotiations for this TIA it has become increasing important for the (which l a codWon montoring program) or technical reviewer to have the initial set of building assessments. To date three are done for under the Corrective Action Progrm?

the following buildings: control building, the containment, and the containment enclosure building and are available on site. Since the focus of this TIA is the control building that assessment would be sampled in an upcoming inspection to follow-up on this open issue.

An opportunity may exist to actually observe the initial assessments being done on the other seismic structures from mid August to mid September 2011.

R. Nelson 7 Coordination This request was discussed between Richard Conte and his staff and Meena Khanna and her staff and Rakmd Auluck with his staff along with Barry Miller (NRR) Ouring a final conference camm-et Earrl: Does DIR neWs to be call on . The TIA was accepted with an agreed upon response date within 90 days from the Indluded hwe?

last day of the technical reviewer's onsite review of the building initial assessments (item No. 8 above) and no later than 90 days from September 30, 2011. Region I will ensure the upcoming inspection is scheduled to end before September 30'. An additional TIA may be needed for the final operability for the control building and other buildings as they are completed. A final response would be dependent on the successful completion of the September 2011 inspection, otherwise, response dates will need to be renegotiated.

References http:Hims.certrec.com (No. 2 on Certrec Document Library Tab List) C-S-1-10159 CALC_000, Rev. 0, 'B' Electrical Tunnel Transverse Shear Evaluation Supplement to Calculation CD-20 (No. 4 on Certrec Document Library Tab List) C-S-1-10150 CALC_000, Rev. 0, Effects of Reduce Modulus of Elasticity - 'B' Electrical Tunnel Exterior Walls (No. 5 on Certrec Document Library Tab List) CD-20-CALC, UE Control and Deiesel Generator Building Design of Material and Walls below grade for Electrical Tunnel and the Control Building (Original Design Calculation)

(No. 6 on Certrec Document Library Tab List) Action Request (AR) 581434 Prompt Operability Determination Reduced Concrete Properties Below Grade in 'B' Electrical Tunnel Exterior Walls.

http://portal.nrc.,ov/edo/r/EBl /Shared%20Documents/Forms/Allltems.aspx Docket No. 50-443 CONTACT: Michael Modes, DRS (610) 337-5198

R. Nelson 8 ML111610530 SUNSI Review _ Complete DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- MModes\TIA Seabrook ASR Draft docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To recei a COp of the -M irsniate m the ooncorwene box 'C' = Copv thou attah/endE Copy th attactdVend*WN=No co OFFICE RI I DRS RI I DRS RI DRP RI DRS RI DRP NAME MModes; RConte ABurritt d PWilson DRoberts DATE 06/ /11 06/ /11 06/ /14 , 06/ /11 06/ /11

R. Nelson 9 Attachment DE/EMCB Comments on AR1644074 Evaluation of Containment Enclosure Buildinq (CEB)

(4-27-11)

1. An important effect of reduction in elastic modulus (Ec) of concrete due to ASR is a reduction in stiffness (axial, flexural, shear) of the affected areas relative to the stiffness of the unaffected areas. This would result in redistribution of forces in the global response of the structure under design loads due to changes in the relative stiffness of the affected and unaffected areas from that considered in the original global structural analyses of the CEB using the SAG computer code. Further, since the ASR degradation is in the lower areas of the CEB, the reduction in elastic modulus could affect the boundary conditions assumed in the original analysis at the junction of the basemat and the CEB wall. Note that FSAR Section 3.8.4.4.a states, in part, that "Lateralforces are transferred to the foundation mats primarilyby the action of shear walls; some load is also transferredby means.of flexural action of the wall, all of which are rigidly attachedat the mat." Also refer to pages 11 and 12 of Calculation C-S-1-10150. The AR1644074 Evaluation does not address the effect of the reduced modulus on the global response of the structure. It assumes that the forces and moments in the different elements of the structure under design loads remains the same and only evaluates the local sections (concrete stresses, strains and flexural capacity) for the reduced modulus, which are based on forces and moments from the original structural analysis.

2. The AR1644074 Evaluation does not evaluate the effect of the reduced modulus on the shear capacity of the affected area.

3. The AR1644074 Evaluation does not address the effect of the reduced modulus on the potential changes in the natural frequencies of the CEB structure, which could have effect the response of the structure to seismic load.

4. The AR1644074 Evaluation of the local section does not evaluate the effect of reduced modulus on stress and strain in the rebar. The strain in the rebar could go beyond the yield strain. From page 47 of Calc CE-4 referenced in the evaluation for element 255, the stress in the hoop reinforcement is 61.493 ksi, which is already beyond yield.

5. The AR1644074 Evaluation of the local section is based on element 255, which is 27" thick and appears to be outside the area affected by ASR. The areas affected by ASR appear to be at the lower elevations of the CEB which are 36" thick. A critical element in the affected area needs to be evaluated. Further, note that the forces and moments in element 255 could increase based on Comment 1 above, and thereby further affect concrete and rebar stresses and strains in element 255.

6. The AR1644074 Evaluation does not explicitly evaluate the effect of the reduced modulus on the flexural capacity of affected local sections, but makes reference to Calc

.i R. Nelson 10 C-S-1-10150 performed for the electrical tunnel. The effect on flexural capacity of the affected Section of the CEB should be explicitly evaluated since the effect of the reduced modulus on moment capacity of a section is a function of the amount of reinforcement in the section, the section dimensions and material properties. The CEB wall reinforcement, dimensions and material properties appear significantly different from that of the electrical tunnel.

7. On page 2 ef the AR16144074 Evaluation, it is stated that "The reduction in Ec causes the nueu-tral axis of the balancaed conrGete and reinforc~ing stool1 sec-tio-n to-shift toward the tensc.ion reinforcingfstool." It appears tht red,uctin in EcGwo'uld tend t c-ause the neutral axis to shift toward the e~dreme comnpression fiber that the tension reinforcing steel eF T Per George Thomas telecon of June 9, 2010 with R. Conte.

8. To have any level of statistical validity, the number of cores used in an evaluation should be at least 3. The AR1644074 Evaluation uses results based on only 2 core tests of the ASR affected area.

9, What are the strain levels at the reported values of concrete compressive strength and elastic modulus from core tests reported in Table 1 of AR1644074? Does petrographic examination of the cores indicate ASR through the thickness of the wall.

10. The AR1644074 evaluation should include a problem statement description of the condition being evaluated and its preliminary extent (at least based on visual inspection) for the structure in question so that an outside reviewer can understand what is being evaluated.