SBK-L-12088, Response to Request for Additional Information NextEra Energy Seabrook License Renewal Application Supplemental Response - (RAI) Follow-up B.2.1.31-1 Item 1
| ML12110A407 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/18/2012 |
| From: | Freeman P NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-12088 | |
| Download: ML12110A407 (7) | |
Text
NEXTera ENERGYC-SEABROKO April 18, 2012 SBK-L-12088 Docket No. 50-443 U.S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 Seabrook Station Response to Request for Additional Information NextEra Energy Seabrook License Renewal Application Supplemental Response - (RAI) Follow-up B.2.1.31-1 Item 1
References:
- 1. NextEra Energy Seabrook, LLC letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010. (Accession Number ML101590099)
- 2. NextEra Energy Seabrook, LLC letter SBK-L-11154, "Seabrook Station Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application - Set 15", August 11, 2011. (Accession Number MLI 1227A023)
- 3. NextEra Energy Seabrook, LLC letter SBK-L-12061, "Seabrook Station Response to Request for Additional Information, NextEra Energy Seabrook License Renewal Application - Supplemental Response - Alkali Silica Reaction (ASR) March 30, 2012 (Accession Number MLI 2094A364).
In Reference 1, NextEra Energy Seabrook, LLC (NextEra) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.
In Reference 2, NextEra provided response to Request for Additional Information Follow-up B.2.1.31-1, Item 1.
In Reference 3, NextEra provided supplemental information related to staff RAls regarding the ongoing analysis of Alkali Silica Reaction. Since this submittal, NextEra has determined the information to be provided in response to Follow-up RAI B.2.1.31-1 Item I was inadvertently omitted. Enclosure 1 contains an updated response to this RAI. This issue has been entered into the Station's corrective action system.
There are no new or revised regulatory commitments contained in this letter.
Nit B L NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 IL* /*
United States Nuclear Regulatory Commission SBK-L-12088/Page 2 If there are any questions or additional information is needed, please contact Mr. Richard R.
Cliche, License Renewal Project Manager, at (603) 773-7003.
If you have any questions regarding this correspondence, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.
Sincerely, NextEra Energy Seabrook, LLC.
Paul 0. Freeman Site Vice President
Enclosures:
- Revised Response to Request for Additional Information, Follow-up RAI B.2.1.31-1 Item 1
United States Nuclear Regulatory Commission SBK-L-12088/Page 3 cc:
W.M. Dean, J. G. Lamb, W. J. Raymond, A.D. Cunanan, M. Wentzel, NRC Region I Administrator NRC Project Manager, Project Directorate 1-2 NRC Resident Inspector NRC Project Manager, License Renewal NRC Project Manager, License Renewal Mr. Christopher M. Pope Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399
United States Nuclear Regulatory Commission SBK-L-12088/ Page 4 NEXTera ENERGYI I, Paul 0. Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.
Sworn and Subscribed Before me this day of April, 2012 Paul 0. Freeman Site Vice President Notary Public to SBK-L-12088 Revised Response to Request for Additional Information (RAI) Follow-up B.2.1.31-1 Item 1 NextEra Energy Seabrook License Renewal Application
United States Nuclear Regulatory Commission Page 2 of 3 SBK-L-12088 / Enclosure 1 Request for Additional Information (RAI) Follow-up B.2.1.31-1:
Background:
By letter dated April 14, 2011, the applicant responded to a staff RAI regarding concrete degradation due to groundwater in-leakage and the occurrence of Alkali-Silica Reaction (ASR) in the concrete. The applicant stated that an extent of condition investigation regarding the ASR degradation was on-going, along with the development of a long range aging management plan. The applicant explained that the plan would not be fully developed and implemented until December 2013. The applicant's response also listed several American Society for Testing and Materials (ASTM) standards that would be used to estimate the ASR reaction rate.
Issue:
The applicant provided no specific information about the applicability of the original operability determination conducted when ASR was initially identified. The response also lacked specific information about what tests (laboratory and in-situ) would be conducted and when. The response also made no mention of how possible reductions in concrete shear strength were being estimated and addressed. In addition, the RAI response stated that cores were being taken in accordance with American Concrete Institute (ACI) 228.1R-03; however, it did not address the statistical validity and size of core samples taken or planned at each location.
Request:
- 1. Explain if the current operability determination remains valid until the long term aging management plan is developed and implemented.
NextEra Energy Seabrook Response
- 1. Initial response:
The current operability determination is expected to remain valid but may require modification, as discussed below. A comprehensive plan to evaluate and address ASR concrete degradation, and develop and implement a long term monitoring plan is ongoing, (See Item 2 response below).
As required by 10 CFR § 54.30(a), if information / results are identified, that impact the current operability determination, they will be evaluated and addressed accordingly. If the reviews show that there is not reasonable assurance that during the current license term, concrete affected by Alkali Silica Reaction is in compliance with applicable design codes, then NextEra Energy Seabrook will take measures under its current license, as appropriate, to ensure that the intended function of those systems, structures or components will be maintained in accordance with the current licensing basis ("CLB") throughout the term of its current license. Thus, by regulation, compliance with the CLB must be maintained until the long term aging management plan is developed and implemented.
As noted in the current operability determination, the areas of concrete affected by Alkali Silica Reaction are in compliance with the applicable design codes stated in the CLB. Structural integrity of the affected structures is fully qualified and all system, structures, and components housed within the structures are capable of performing their design function. The long term effects of the ASR condition are being monitored by the Structures Monitoring Program and the status of the condition is included in the Structures Health Report which, reports the results of subsequent investigations and testing to the Plant Health Committee. Should the condition degrade further, a higher level of
United States Nuclear Regulatory Commission Page 3 of 3 SBK-L-12088 / Enclosure I qualification analysis will be employed to demonstrate that significant margin exists for operability.
Additional response:
As discussed in NextEra's initial response above, the operability determinations for the structures affected by ASR may require revision if information / results are identified that impact the current operability determination. Under this process, on October 14, 2011, the two operability determinations associated with ASR were revised. These operability determinations address the following:
" Reduced Concrete Properties Below Grade In "B" Electrical Tunnel Exterior Wall Reduced Concrete Modulus In Containment Enclosure Building, RHR Equipment Vaults, EFW Pump House and Diesel Generator Fuel Oil Tank Rooms.
The revised operability determinations concluded that the above structures affected by ASR are fully capable of performing their intended safety function and are operable with reduced margin.
Following the guidance of RIS 2005-20 and NRC Inspection Manual, Part 9900, the affected structures are considered operable but degraded, and below full qualification. Full qualification will be attained when the testing and analysis plans developed through the corrective action process to address the ASR issues are completed and the long term resolution is incorporated into the UFSAR and/or other applicable design documents.