ML16354A312

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Incoming Letter Seabrook License Amendment Request on Concrete Degradation
ML16354A312
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Site: Seabrook  NextEra Energy icon.png
Issue date: 12/14/2016
From: Lochbaum D
Union of Concerned Scientists
To: Dennis Bley
Advisory Committee on Reactor Safeguards
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Download: ML16354A312 (2)


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December 14, 2016 Dennis Bley, Chairman Advisory Committee on Reactor Safeguards United States Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Seabrook License Amendment Request on Concrete Degradation

Dear Chairman Bley:

On behalf of the C-10 Research and Education Foundation (C-10) 1 and the Union of Concerned Scientists (UCS),2 I am respectfully requesting that the Advisory Committee on Reactor Safeguards (ACRS) formally review and comment on a license amendment request regarding managing the risk of concrete degradation due to alkali-silica reaction (ASR).

By letter dated August 1, 2016,3 NextEra Energy Seabrook LLC (NextEra) submitted a license amendment request seeking Nuclear Regulatory Commission (NRC) approval of proposed revisions to the current licensing basis at Seabrook for ASR.

Because concrete degradation due to ASR is not explicitly covered by existing codes and standards, such as American Concrete Institute standards, the license amendment request seeks to manage ASR using a mix of existing codes and standards supplemented by site-specific monitoring and maintenance measures.

A formal review of this license amendment request by the ACRS can add tangible value to the process.

This is not to suggest inadequate performance on the part of the licensee staff or by the NRC staff reviewing the request. The material submitted by NextEra in the license amendment request and the request for additional information submitted by the NRC staff clearly demonstrate that both parties have applied considerable resources and skills to this matter. The value to be added by the ACRS is either in confirming that the proposed measures will very likely achieve the intended outcomes or in pointing out where those measures can be enhanced.

Ensuring that ASR is properly managed at Seabrook has the collateral benefit of establishing a solid precedent should other NRC-licensed facilities encounter this degradation mechanism.

1 For information about this organization, see http://www.c-10.org 2

For information about this organization, see http://www.ucsusa.org 3

Available in ADAMS using accession number ML16216A250.

For full disclosure, both C-10 and UCS have submitted comments on the license amendment request in response to the notice published in the Federal Register. But neither C-10 or UCS has formally intervened with the NRC contesting the amendment being sought. We have not enclosed our comments with this letter to avoid biasing the ACRSs review; but we would be glad to provide them upon request.

Sincerely, David A. Lochbaum Director, Nuclear Safety Project Union of Concerned Scientists PO Box 15316 Chattanooga, TN 37415 423-468-9272, office dlochbaum@ucsusa.org