ML14076A033

NRC Response Letter to Don Tilbury Regarding Remarks at the December 18, 2013 Public Meeting for Seabrook Station (W/Enclosures)

ML14076A033
Person / Time
Site:	Seabrook
Issue date:	03/13/2014
From:	Glenn Dentel Reactor Projects Branch 3
To:	Tilbury D - No Known Affiliation
Barkley R
References
Download: ML14076A033 (54)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 March 13, 2014 Mr. Don Tilbury 15 Bride Hill Drive Hampton, NH 03842

Dear Mr. Tilbury:

I am responding to questions you raised in your letter dated December 23, 2013, following the December 18 meeting in Hampton, New Hampshire held to discuss the concrete degradation experienced at Seabrook Station due to an Alkali-Silica Reaction (ASR) between the cement and the stone aggregate. Due to the number and range of concerns provided, I am addressing them in an enclosure to this letter. I have also provided documents from our Office of Public Affairs as well as other sources that directly related to your concerns.

I trust this is responsive to the concerns you raised. If you have additional questions or concerns about Seabrook Station, please do not hesitate to contact Richard Barkley of my staff at (610) 337-5328.

Sincerely,

/RA/

Glenn T. Dentel, Chief Reactor Projects Branch 3 Division of Reactor Projects

Enclosures:

1) Response to Questions Provided by Mr. Tilbury

2) Fact Sheets on Emergency Preparedness, License Renewal, and Dry Cask Storage and Waste Confidence

3) Decommissioning Funding Status Report for FP&L and NextEra

ML14076A033 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DRP RI/DRS RI/ORA RI/DRP MGray/MG via DScrenci/DS via NAME mmt RBarkley/RSB GDentel/GTD phone/email phone/email DATE 03/07/14 03/12/14 03/12/14 03/13/14 Response to Concerns Raised by Don Tilbury

1) Seabrooks Plant Life Extension Request

Response

10 CFR 54.17 allows a power plant licensee to file for a renewed licensee up to 20 years in advance of the expiration of the current operating license. The NRC has determined that 20 years of operating experience is sufficient to assess aging and environmental issues at the site. Additionally, this affords the licensee the opportunity to perform long-term planning regarding the retirement and replacement of large power generation facilities. A major consideration for seeking license renewal so far in advance of the expiration date of the current license is that it takes about 10 years to design and construct major new generating facilities, and long lead times are also required by energy planning decision-makers. In addition, a request for license renewal for two or more units on the same site that entered service as much as a decade apart can be made as one consolidated application.

The NRC staffs safety review of the Seabrook license renewal application is ongoing and no regulatory decision has been made on the application. The original safety review schedule was revised, in part, to address the staffs concerns associated with the applicants proposed plant-specific ASR monitoring program and to add a second meeting with the Advisory Committee on Reactor Safeguards, plant license renewal subcommittee. The NRC will ensure that the ASR monitoring program includes methods and/or techniques to adequately monitor the performance or condition of the affected structures in a manner that provides reasonable assurance that the ASR aging effects will be adequately managed before making a license renewal decision.

The NRC continues its efforts to better understand the impact of ASR on reinforced safety-related concrete structures at Seabrook Station. Our inspections and assessments to date have determined the ASR-affected structures at Seabrook remain capable of performing their intended safety function with margin from additional design and construction. Long-term resolution of this issue will require a thorough understanding of the effects of ASR and additional testing, monitoring and potential compensatory actions by NextEra. The NRC will continue to carefully assess NextEras actions to resolve this issue under their current operating license and conduct inspections at Seabrook Station to ensure corrective actions are effective.

2) ASR in the Concrete of Reactor Foundations and Other Buildings at Seabrook

Response

As noted during the meeting on December 18, 2013, NextEra staff and the NRC continue to review the impacts of ASR identified in various concrete buildings at Seabrook Station. Concrete is a composite of cement, aggregate (e.g., crushed rock and sand), water and, in some cases, small amounts of admixtures. For the reaction to take place in concrete, there must be a high alkali in the cement, reactive silica in the aggregate, and for ASR to proceed in cured concrete, it must also have sufficient water present. In an effort to reduce the amount of water impacting on the structures in question, Seabrook has undertaken several actions to dewater key areas of concern.

NextEra has also taken actions to help ensure the water in contact with the concrete contains less salt and other chemicals that can accelerate ASR by terminating the use Enclosure 1

2 of chemical deicers near the facility. The source of the water intrusion on the structures of concern at Seabrook is not salt water from the tidal estuary nearby, but rather fresh water from the prevailing water table inland. The facility itself rests on bedrock.

As discussed at the December 18 meeting, our staff will continue to review NextEras monitoring and analysis of the ASR at Seabrook Station. The NRC staff is also following NextERAs large-specimen testing program underway at the University of Texas Ferguson Structural Engineering Laboratory. Should NextEra elect to use the results of this test program to resolve the ASR non-conforming condition, the testing methodology and results will be subject to NRC review pursuant to the applicable regulatory processes described in 10 CFR 50.59 and/or 50.90. If NextEra decides to use another approach, the NRC will likewise implement these regulatory review processes.

As stated at the December 18 meeting, the safety-related concrete structures at Seabrook continue to remain operable and capable of performing their design function even with the ASR degradation noted to date.

As documented in NRC Inspection Reports 05000443/2012009 (in the agencys document management system ADAMS at Accession No. ML12338A283) and 05000443/2012010 (ML13221A172), the NRC summarized extensive reviews and hundreds of hours of detailed inspections, meetings and internal deliberations to understand and ensure a clear engineering and safety basis had been established by NextEra for the current structures operability determination. These operability determinations are based upon detailed structural evaluations that are independent of the large scale specimen testing being conducted by NextEra. The NRC plans to periodically inspect NextEras ASR monitoring program and testing activities at FSEL.

NextEra is obligated, consistent with their existing license, to maintain reasonable assurance of operability of Seabrook Station ASR-affected structures.

3) Nuclear Power Plant Waste

Response

As you noted, at this time there is no permanent disposal site for spent nuclear fuel.

In the interim, the Waste Confidence rule codifies the Commission's generic deter-mination of the environmental impacts associated with the storage of spent fuel during and after the end of a reactor's licensed life for operation. This generic analysis is found in 10 CFR 51.23. The Waste Confidence Rule is currently undergoing revision in light of a court ruling in 2012, but the draft Environmental Impact Statement (EIS) describes the environmental impacts of continuing to store spent nuclear fuel during and beyond the licensed life for operation of a reactor, and is the regulatory basis for the proposed rule.

As for dry cask storage, the NRC developed cask licensing requirements through a public process to provide a sound basis for ensuring protection of public health and safety and the environment. NRC staff conducts thorough reviews and only approves designs that meet those requirements. The NRC periodically inspects the design, manufacturing and use of dry casks. These inspections ensure licensees and vendors are following safety and security requirements and meeting the terms of their licenses and quality assurance programs. NRC inspectors also observe practice runs before licensees begin moving their spent fuel into dry casks.

Enclosure 1

3 Since the first casks were loaded in 1986, dry storage has released no radiation that affected the public or contaminated the environment. Tests on spent fuel and cask components after years in dry storage confirm that the systems are providing safe and secure storage. NRC also analyzed the risks from loading and storing spent fuel in dry casks. That study found the potential health risks are very small. Spent fuel is currently in dry storage at more than 65 sites around the country. Further information regarding spent fuel storage and dry casks is provided in the attached fact sheets.

4) Emergency Planning/Evacuation

Response

In accordance to the NRC Code of Federal Regulations, 10 CFR 50.54(q), all licensees must maintain an Emergency Plan. Those plans must be approved by the NRC prior to the issuance of an operating license. The Federal Emergency Management Agency (FEMA) is the lead authority for reviewing and approving all offsite State emergency plans, including the states evacuation plans.

All nuclear power plants conduct a variety of exercises and drills on a recurring basis, including a required full-scale participation emergency exercise on a biennial basis. These biennial exercises test the capability of both the onsite and offsite emergency response organizations to ensure adequate emergency response actions will be taken to adequately protect the safety of the public. The NRC evaluates the onsite portion of these exercises and FEMA evaluates the offsite portion. If you would like to view the FEMA exercise reports from previous Seabrook exercises, they can be found on the following public website: http://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-action-reports.html. These reports will provide you a good description of the numerous of activities that are conducted and evaluated during these exercises for testing the approved emergency plans.

5) Seabrook Decommissioning Funding Payments

Response

The NRCs focus is to ensure that licensees provide reasonable assurance that sufficient funds will be accumulated for decommissioning to NRC standards regardless of whether a license renewal is granted. Whether or not a renewal is granted, the licensee is required to demonstrate that there is adequate funding for decommissioning. The NRC regulates radiological decontamination as defined in 10 CFR 50.2. As explained in the regulations in 10 CFR 50.75, the table of minimum amounts focuses on the minimum amount of money a licensee is required to accumulate for radiological decommissioning.

As long as a licensee is providing reasonable assurance that sufficient funds will be accumulated for decommissioning to NRC standards, the licensee is complying with NRC regulations.

The table of minimum amounts (sometimes referred to as the Decommissioning Funding Amount, or DFA) assumes that there is an increase in decommissioning expenses and decommissioning funds over time. Therefore full payment of all costs into the decommissioning fund in advance of decommissioning is not required. So as long as the licensee meets the DFA formula amount, the NRC considers the licensee to be in compliance with our regulations.

Enclosure 1

4 As of the end of 2012, approximately $460 million has already been set aside in decommissioning funds for Seabrook Station. NRC received this information as part of the biennial decommissioning report review and found reasonable assurance that adequate decommissioning funds exist; a copy of that report is attached. The NRCs decommissioning funding requirements are separate and independent of any state Public Utility Commission (PUC) requirements or the oversight of state boards, such as the NH Nuclear Decommissioning Financing Committee.

6) The If Factor - Reactor Safety Post-Fukushima

Response

The NRC has taken significant action to enhance the safety of reactors in the United States based on the lessons learned from earthquake and tsunami that extensively damaged four nuclear power reactors at the Fukushima Dai-ichi facility. I urge you to visit the NRCs webpage at: http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html This page is intended to serve as a navigation hub to follow the NRC's progress in implementing the many different lessons-learned activities in response to this event.

Enclosure 1