ML16127A155
| ML16127A155 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/06/2016 |
| From: | Mel Gray Engineering Region 1 Branch 1 |
| To: | Dean Curtland NextEra Energy Seabrook |
| Gray M | |
| References | |
| EA-16-101 IR 2016008 | |
| Download: ML16127A155 (24) | |
See also: IR 05000443/2016008
Text
[Type here]
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD.
KING OF PRUSSIA, PA 19406-2713
May 6, 2016
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 Commissions 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 NextEras 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
NextEras 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 NextEras 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 Seabrooks 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 non-
cited 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 NRCs Enforcement Policy. The current Enforcement Policy is available for
review on the NRCs Website http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-
pol.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 NRCs 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 NRCs Public Document Room or from the Publicly
Available Records component of the NRCs document system, Agencywide Documents Access
and Management System (ADAMS). ADAMS is accessible from the NRCs 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
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 non-
cited 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 NRCs Enforcement Policy. The current Enforcement Policy is available for
review on the NRCs Website http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-
pol.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 NRCs 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 NRCs Public Document Room or from the Publicly
Available Records component of the NRCs document system, Agencywide Documents Access
and Management System (ADAMS). ADAMS is accessible from the NRCs 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
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
JVazquez, DRP, Actg RI
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
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.
Report No.
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
NextEra Energy Seabrook, LLC
Docket No. 50-443
Seabrook Station
License No. NPF-86
During an NRC inspection conducted between February 1 and March 24, 2016, a violation of
NRCs 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 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 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 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 reports 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 NRCs
document system (ADAMS), accessible from the NRCs Website at http://www.nrc.gov/reading-
rm/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 NRCs 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 vendors 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 vendors 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 NextEras 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 NextEras commitments to address ASR-
affected 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
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
NextEras activities to investigate, monitor and affirm the structural capability of Seabrook
structures affected by ASR.
NextEras testing of large scale ASR-affected test specimens at FSEL commenced in late 2013
and was planned to be completed under NextEras 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 FSELs 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 NextEras
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 NextEras 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 NextEras 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 NextEras Prompt Operability
Determinations (PODs) and associated evaluations and corrective actions to these non-
conforming conditions and NextEras 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 NextEras
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 vendors 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 NextEras 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 staffs 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 non-
conforming 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 teams
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 NextEras staff accepted their vendors 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 NextEras 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 staffs 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 NextEras 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 in-
plane 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 As-
Deformed 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 teams 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 teams 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 teams 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 ASR-
induced 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
teams 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 NRCs 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 NextEras 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 NextEras engineering
evaluations and operability assessments of the CEB and RHR/CS Vault. NextEras
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 teams review of the POD, Revision 00, it was unclear how NextEras
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 inspectors 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 teams 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 non-
conforming 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 NextEras 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 NextEras 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
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 NextEras current understanding of the cracking
mechanism. However, the team questioned NextEras conclusion that the structure is
operable but nonconforming. NextEras 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 NextEras 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 NextEras 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 NextEras 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 NextEras 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
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
Action Request
Apparent Cause Evaluation
American Concrete Institute
Alkali-Silica Reaction
American Society of Mechanical Engineers
CB
Control Building
CEB
Containment Enclosure Building
CEVA
Containment Enclosure Ventilation Area
CFR
Code of Federal Regulations
Current Licensing Basis
CR
Condition Report
Containment Spray System
Division of Reactor Safety
EC
Engineering Change
EN
Procedural Notice for Engineering Department
FEA
Finding
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
License Amendment Request
Management Review Committee
Non-Cited Violation
NRC
U.S. Nuclear Regulatory Commission
Office of Nuclear Reactor Regulation
Performance Deficiency
Prompt Operability Determination
Pounds per square inch (gage)
Radiological Controlled Area
Root Cause Evaluation
Residual Heat Removal System
Significance Determination Process
SG&H
Simpson, Gumpertz & Heger Associates
Severity Level
SR
Safety-related
Structure, System, or Component
Task Interface Agreement
TS
Technical Specification
Updated Final Safety Analysis Report
Unresolved Item
WJE
Wiss, Janney, Elstner Associates