ML22136A319
| ML22136A319 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/2022 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, Kent, ACRS | |
| References | |
| NRC-1939 | |
| Download: ML22136A319 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Fuels, Materials, and Structures and Plant Operations, Radiation Protection, and Fire Protection Joint Subcommittees Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, April 27, 2022 Work Order No.:
NRC-1939 Pages 1-153 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 FUELS, MATERIALS, AND STRUCTURES SUBCOMMITTEE 7
and 8
PLANT OPERATIONS, RADIATION PROTECTION, AND FIRE 9
PROTECTION SUBCOMMITTEE 10
+ + + + +
11 JOINT MEETING ON SEABROOK ALKALI-SILICA REACTION 12 (ASR) ISSUE 13
+ + + + +
14 WEDNESDAY 15 APRIL 27, 2022 16
+ + + + +
17 The Subcommittees met via Video-18 Teleconference, at 8:30 a.m. EST, Ronald G. Ballinger 19 and Gregory H. Halnon, Co-Chairs, presiding.
20 COMMITTEE MEMBERS:
21 RONALD G. BALLINGER, Co-Chair 22 GREGORY H. HALNON, Co-Chair 23 JOY L. REMPE, ACRS Chairman 24 WALTER L. KIRCHNER, ACRS Vice Chairman 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 DAVID A. PETTI, Member-at-large 1
VICKI M. BIER, Member 2
CHARLES H. BROWN, JR. Member 3
VESNA B. DIMITRIJEVIC, Member 4
JOSE MARCH-LEUBA, Member 5
MATTHEW W. SUNSERI, Member 6
7 ACRS CONSULTANTS:
8 DENNIS BLEY 9
STEVE SCHULTZ 10 11 DESIGNATED FEDERAL OFFICIAL:
12 KENT HOWARD 13 14 NRC STAFF PRESENT:
15 NIKLAS FLOYD 16 MEL GRAY 17 BRYCE LEHMAN 18 CHRISTOPHER NEWPORT 19 JUSTIN POOLE 20 GEORGE THOMAS 21 MATT YOUNG 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 C-O-N-T-E-N-T-S 1
Page 2
Opening Remarks 3
By Ronald Ballinger, Gregory Halnon....
4 4
Staff Introduction 5
By Mel Gray................ 10 6
Presentation on Background and Status Update 7
of ASR at Seabrook 8
By Justin Poole, Bryce Lehman, 9
Nik Floyd, Chris Newport
......... 14 10 Opportunity for Public Comment 130 11 Adjourn....................
153 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
8:31 a.m.
2 CO-CHAIR BALLINGER: The meeting will now 3
come to order, my name is Ron Ballinger, and I am the 4
subcommittee chairman of the Fuel Materials and 5
Structures Subcommittee. Co-chairing this meeting with 6
me is Greg Halnon, the subcommittee chairman for the 7
Plant Operations Radiation Protection and Fire 8
Protection Subcommittee. This information briefing is 9
part of the ongoing committee oversight of the alkali-10 silica reaction phenomena at the Seabrook Unit One 11 Station.
12 The ACRS has previously evaluated the 13 effective ASR at Seabrook as part of NextEra Energy's 14 license renewal application. In our letter on this 15 subject, we provided the following conclusions. One, 16 NextEra license amendment request 1603 establishes a 17 robust analytical methodology supported by a
18 comprehensive large scale test program for the 19 treatment, and monitoring of alkali-silica reaction 20 affected seismic category one structures at Seabrook.
21
- Two, the NextEra license renewal 22 application includes two new aging management programs 23 to monitor ASR, and building deformation. These 24 incorporate the test program results, and license 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 amendment request methodology, and assure that the 1
effects of alkali-silica reaction will be effectively 2
tracked, and evaluated through the end of the license 3
renewal application period of extended operation.
4 Three, the staff safety evaluations of the 5
license amendment requests, and alkali-silica reaction 6
aging management programs in the license renewal 7
application provide thorough assessments, and 8
findings. We agree with the staff's conclusion that 9
NextEra's programs are acceptable. With respect to 10 conclusion number two, the applicant committed to an 11 extensive inspection program to ensure that 12 requirements specified in the license renewal are met.
13 Among these are quote monitoring of 14 building deformation includes measurement of seismic 15 gaps, and other key dimensions to identify, and trend 16 building deformation, and inspections to identify the 17 impact of building deformation on plant components.
18 During a recent periodic inspection, the staff issued 19 a green finding related to the ASR inspection, and 20 monitoring program.
21 And I quote, the NRC inspectors identified 22 a green finding associated with NextEra's procedure 23 ENAA2031001 revision 37, operability, determinations, 24 functionality assessments. Because NextEra's staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 did not adequately account for the future progression 1
of ASR, IE time dependent mechanism in their POD for 2
several Seabrook structures.
3 Specifically NextEra staff did not trend, 4
and project the periodic threshold monitoring data for 5
the effected structural elements to ensure the 6
structures would remain capable of performing their 7
safety functions to the next scheduled inspection.
8 The Plant Operations Radiation Protection and Fire 9
Protection Subcommittee is therefore interested in ASR 10 monitoring program performance, as well as any changes 11 in updates that may be put in place in light of the 12 findings.
13 Based on these inspection results, the 14 committee decided to hold a joint subcommittee meeting 15 of the Fuel Materials and Structures Subcommittee, and 16 Plant Operations Radiation Protection and Fire 17 Protection subcommittees. The purpose of this 18 information briefing is for the NRC Region I, and 19 Headquarters staff to brief the joint subcommittee on 20 the findings, and subsequent NRC staff actions.
21 Interested members of the public will have 22 an opportunity to make statements in accordance with 23 the published agenda. We are aware that a member of 24 the public representing the public interest group C-10 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 desires to make a public statement. Let me get to 1
that agenda item. ACRS members in attendance are 2
myself, Vicki Bier, Charles Brown, I have to go 3
through this thing.
4 Dave Petti, Greg Halnon of course, Jose 5
March-Leuba, Walt Kirchner, it keeps jumping around.
6 Joy Rempe, our consultant Steve Shultz, Matt Sunseri, 7
Vesna Dimitrijevic, and that probably does it, and 8
that probably means everybody. During today's -- Kent 9
Howard by the way, of the ACRS staff is the designated 10 federal officer for this meeting. During today's 11 meeting, the joint committee will gather information, 12 analyze relevant issues, and facts, and formulate 13 proposed positions and actions as appropriate.
14 However, at the subcommittee's discretion, 15 any matters will be considered for presentation to the 16 full committee if necessary as the members see fit.
17 The ACRS was established by statute, and is governed 18 by the Federal Advisory Committee Act, FACA. The 19 committee only speaks through its published letter 20 reports. Because this is a subcommittee meeting, 21 participants should consider entered remarks by ACRS 22 members as their personal comments, and not committee 23 positions.
24 We hold subcommittee meetings to gather 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 information, and perform preparatory work that will 1
support our deliberations at a full committee meeting 2
if necessary. The rules for participation in all ACRS 3
meetings, including today's, were announced previously 4
in the Federal Register, and included on our website.
5 The ACRS section of the U.S. NRC public website 6
provides our charter, bylaws, agendas, letter reports, 7
and transcripts of all full, and subcommittee 8
meetings, including presented material.
9 As stated on the website, members of the 10 public who desire to provide written or oral input to 11 the subcommittee may do so, and should contact the 12 designated federal officer, which in this case would 13 be Kent Howard, prior to the meeting as practicable.
14 Today's meeting is open to public attendance, and 15 there will be time set aside during the meeting for 16 comments from members of the public attending, and 17 listening to our meetings.
18 Today's meeting is being held over 19 Microsoft Teams for ACRS, NRC attendees, and members 20 of the public. There is also a call in number 21 allowing participation of the public to connect to the 22 Teams session. This information is indicated on the 23 published agenda. A transcript of today's meeting is 24 being kept, therefore we request that meeting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 participants not on the agenda identify themselves 1
when they are asked to speak.
2 And to speak with sufficient clarity, and 3
volume so that they can be readily heard. Before we 4
continue, I'd like to invite Greg Halnon to add any 5
additional comments he would like to make, Greg, are 6
you there?
7 CO-CHAIR HALNON: Yeah Ron, thanks. As 8
you stated, the plant ops subcommittee is interested 9
in the performance, and inspections of the 10 programmatic aspects of the ASR at Seabrook. So given 11 the recent documentation of inspection results, we 12 will discuss some of the facts surrounding the issues 13 found during the inspections, and we look forward to 14 a good interaction. So thanks Ron, back to you.
15 CO-CHAIR BALLINGER: Okay. At this time 16 I'll ask the attendees to put their devices on mute to 17 minimize disruptions, and unmute only when speaking, 18 and via the magic of Teams we have this little thing 19 that raises a hand. So at the end of this meeting 20 when we start having a discussion, and having public 21 comments, my guess is that's a good way to acknowledge 22 people without having people talking over each other.
23 So are there any members of the 24 subcommittee that wish to make an additional comment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 before we begin? Okay, not hearing, and adhering to 1
the five second rule, I'll call on Mel Gray, the 2
Engineering Branch One chief, Division of Operating 3
Reactor Safety Region I to take it away.
4 MR. GRAY: Good morning, just a sound 5
check, can you hear me chairman?
6 CO-CHAIR BALLINGER: I can hear you fine.
7 MR. GRAY: Great, thank you. Good 8
morning, thank you chairman, and subcommittee members 9
for the opportunity to speak with you today. My name 10 is Mel Gray, I'm branch chief of Engineering Branch 11 One in the NRC's Region I Office outside of 12 Philadelphia. We are here to present the results of 13 our inspections, and oversight of the Seabrook station 14 related to the plant owner's performance to monitor, 15 manage, and correct the effects of ASR, and structures 16 at the Seabrook plant.
17 The plant owner is NextEra Corporation.
18 When we last met, as was described by the chairman, 19 and to my recollection on this topic, it was October 20 2018. The NRC staff was completing a multi-year 21 review of a proposed methodology by NextEra to address 22 ASR at the Seabrook plant. At that time, licensing 23 audits, and reviews were at the forefront.
24 With inspections being completed to inform 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 our reviews, and ensure Seabrook structures remained 1
capable of performing their safety functions in the 2
interim. Now that the NRC has issued a license 3
amendment, a renewed license, and license conditions 4
that require the use of that methodology, and 5
monitoring program inspection is indeed at the 6
forefront.
7 We expect NextEra's performance frequently 8
to verify they're implementing the NRC's approved 9
monitoring, and methodology processes, and meeting the 10 important corresponding license conditions. As you 11 will hear, we have identified some gaps in NextEra 12 performance to implement the methodology. But we find 13 the methodology remains sound to provide for the 14 assessment of the effects of ASR.
15 And to drive corrective actions to 16 maintain the capability of Seabrook structures. The 17 technical staff from the Office of Nuclear Reactor 18 Regulation, or NRR, continue to work closely with my 19 Region I inspectors to ensure our safety requirements 20 are met. The resident inspectors, as you know, serve 21 as the eyes, and ears at the plant to identify ASR 22 related activities.
23 Important for inspection, they review 24 corrective action items daily, they do independent 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 plant walk downs, observe meetings, interact with 1
staff, and they are our sounding board to frequently 2
vet what inspections we should focus on. My staff 3
work closely with the resident inspectors, my staff 4
has specialties in materials engineering, and in 5
service examinations.
6 And we accompany the resident inspectors, 7
assist them, or lead inspections, and additionally, 8
and finally you'll find that we pull in very 9
frequently, the structural engineers from NRR that 10 were intimately involved in reviewing the methodology 11 over the years so that we have a robust staff 12 knowledgeable that can readily, and ably examine 13 NextEra's performance.
14 Which leads me to the next slide, Matt 15 Young is a branch chief, he's flipping slides, thank 16 you Matt. That leads me to the NRC presenters. We 17 have Justin Poole, he's a project manager out of the 18 Division of Operator Reactor Licensing. Justin is 19 responsible for all licensing actions related to the 20 Seabrook station. We have Bryce Lehman, structural 21 engineer out of the Division of Engineering and 22 External Hazards.
23 Bryce was intimately involved in reviewing 24 the monitoring, and frequently accompanies us on site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 for in depth inspections. Nik Floyd is out of 1
Engineering Region I out of my branch, Nik is a 2
specialist in materials, and engineering inspections.
3 And finally we have Chris Newport speaking, Chris is 4
the senior resident inspector at Seabrook, and the 5
resident inspector, Travis Daun is here.
6 They are very knowledgeable in the 7
requirements, and focused on this aspect of Seabrook's 8
performance. I would also add we have George Thomas, 9
a senior civil engineer, also from the Division of 10 Engineering and External Hazards available today, and 11 he also accompanies us on many inspections. Chairman, 12 we can take questions any time, but I'll continue 13 unless I hear.
14 So next slide please. The NRC staff 15 presentation, we intend, we decided to do a quick move 16 smartly through the background just to benchmark ASR, 17 subcommittee members if need be, and stakeholders, and 18 attendants, we can move quickly through that, we'll 19 take our cue from the subcommittee members. We then 20 intend to go through the approach to addressing ASR, 21 just to refresh that.
22 It has a number of important aspects, and 23 then we want to discuss our findings we've had in the 24 last year related to ASR, and NextEra's performance, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 and we have certainly the right folks here that are 1
presenting, the actual folks who did the inspection, 2
and I was on site to oversee those inspections. So I 3
hope that meets the needs of the subcommittee, and 4
with that I would go to the next slide.
5 With that, I'll turn it over to Mr. Justin 6
Poole, unless there are questions. Maybe the five 7
second rule. Okay, thank you.
8 MR. POOLE: Thanks Mel. So as Mel stated 9
in the agenda, the staff will begin our presentation 10 with some background materials that will allow, for 11 those less familiar with ASR, specifically ASR at 12 Seabrook, to get up to speed before we get into what 13 has been identified through the inspection process.
14 So for those that are very familiar with the 15 background, please bear with us as we get to that 16 point.
17 So let's start with what is ASR, or 18 alkali-silica reaction. ASR is a type of chemical 19 reaction that occurs in concrete. Concrete consists 20 of three main ingredients, coarse aggregate, rocks 21 such as gravel, fine aggregate, sand, and then cement, 22 the binder that holds it all together. When combined 23 with moisture, moisture reactive silica present in the 24 aggregate reacts with the hydroxyl ions, and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 alkali ions in the cement.
1 The reaction produces an alkali-silica gel 2
that expands as it absorbs moisture, resulting in 3
micro-cracking in the concrete. In order for the 4
reaction to occur, all three of the following 5
conditions must be present. Reactive forms of silica 6
in the concrete aggregate, high alkali cement pour 7
solution, and adequate moisture, typically around 80 8
percent or higher relative humidity.
9 ASR is confirmed by what is known as 10 petrographic analysis of concrete core samples. Next 11 slide please. The gel expansion starts off as micro-12 cracking, and can later be observed as macro-cracking 13 on the surface. The visual appearance is typically in 14 the form of what is known as pattern cracking, or map 15 cracking, where you may see deposits in the crack, and 16 gel staining around the cracks.
17 The expansion cracking of concrete from 18 ASR can potentially impact both structural capacity, 19 IE the load carrying capacity for critical limit 20 states, and the demand, IE load due to internal, and, 21 or external restraint to expansion on a structure.
22 Please note ASR is not new. While Seabrook is the 23 only known nuclear plant in the United States to have 24 identified ASR, there is lots of experience with ASR 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 in other industries.
1 The federal highway and transportation 2
authority, IE the Department of Transportation, both 3
federal, and state, have extensive experience with ASR 4
in transportation infrastructure, but the concrete 5
design of their structures, and the structures found 6
at nuclear power plants are not the same. Next slide 7
please. Now that we've talked ASR in general, let's 8
move on to ASR at Seabrook.
9 In 2009, while preparing their submission 10 of a license renewal application for Seabrook, NextEra 11 identified that the aggressiveness of the groundwater 12 chemistry (audio interference).
13 CO-CHAIR BALLINGER: I'm not sure why 14 that's happening, but it's now stopped, so I guess 15 we're okay.
16 MR. POOLE: Okay. The aggressiveness of 17 the groundwater chemistry, and Seabrook concrete 18 structures in contact with the groundwater needed to 19 be determined. Therefore, testing was performed, and 20 in August
- 2010, NextEra confirmed, through 21 petrographic analysis, the presence of ASR in concrete 22 in below grade walls of several category one 23 structures.
24 As the codes of record in the Seabrook 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 licensing basis at that time did not account for ASR, 1
NextEra then initiated a
prompt operability 2
determination to assess the safety significance of the 3
issue, and the basis for continued operation. NextEra 4
identified several causes for the ASR issue, and 5
several reasons for why it was not identified until 6
the license renewal review.
7 One cause was that the concrete mix for 8
the initial construction unknowingly utilized an ASR 9
susceptible aggregate, this was because the --
10 MEMBER BLEY: Justin?
11 MR. POOLE: Yes.
12 MEMBER BLEY: This is Dennis Bley, you 13 said this all in below grade concrete I think, I don't 14 believe I remember that from previous presentations 15 here. Is that because of that's the source of 16 moisture down there, or can you explain that at all?
17 MR. POOLE: So that is true, it is not 18 currently -- it is currently more than just below 19 grade structures, but it was first identified in below 20 grade structures back in 2010.
21 MEMBER BLEY: Okay, but it's showing up 22 elsewhere?
23 MR. POOLE: Correct.
24 MEMBER BLEY: Okay, thanks.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 MR. POOLE: So one cause was the concrete 1
mix for the initial construction unknowingly utilized 2
an ASR susceptible aggregate. This was because the 3
ASTM standard screening test approved, and used at 4
that time have since been determined to have limited 5
ability to predict slow reacting aggregates for ASR.
6 Because of this, NextEra mistakenly assumed that its 7
original cement, and aggregate selection would 8
preclude ASR development.
9 And therefore did not initially consider 10 that the observed cracking could be from ASR.
11 Instead, NextEra initially characterized this cracking 12 as shrinkage. Please note, new ASTM test standards 13 have since been developed that now detects this type 14 of slow reacting aggregate. Next slide please.
15 NextEra concluded from its extended condition review, 16 and prompt operability determination, that from a 17 regulatory standpoint, the affected structures were 18 operable, but degraded, and non-conforming.
19 The operability determinations were based 20 on material properties, and margin. Regional 21 inspectors and headquarters experts, that you heard 22 Mel describe earlier, reviewed the operability 23 determinations and concluded that ASR-affected 24 structures remain capable of performing their safety 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 functions. The NRC issued a confirmatory action 1
letter in May 2012 to confirm NextEra's actions to 2
address ASR.
3 In the same year, NRC also issued a 4
deviation memo, which allowed the region to increase 5
the amount of oversight beyond the typical inspection 6
activities you would normally see at a nuclear power 7
plant. I'll now turn the presentation over to Bryce 8
Lehman. Next slide please.
9 CO-CHAIR BALLINGER: Excuse me, this is 10 Ron Ballinger.
11 MR. POOLE: Yes.
12 CO-CHAIR BALLINGER: I am remiss in 13 identifying that Dennis Bley, our consultant, is also 14 a member of this meeting. So if I've missed any other 15 members, or consultants, please let me know. Thank 16 you, go ahead.
17 MR. LEHMAN: All right, thanks Justin, and 18 good morning everyone. My name is Bryce Lehman, and 19 as Mel said, I was one of the reviewers of the license 20 amendment request, and I'm now going to provide an 21 overview of the steps that NextEra took to address 22 ASR, and how the staff reviewed the resulting license 23 amendment request. To resolve the open operability 24 determinations, NextEra chose to perform a large scale 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 test program at the University of Texas in Austin.
1 The program lasted from 2013, to 2016.
2 The goal of the testing was to better understand ASR's 3
impact on the load carrying capacity of affected 4
structures. The test specimens were designed to 5
replicate the reinforced concrete walls at Seabrook.
6 Basically, the test was developed to determine how 7
much ASR could occur in a structure before impacting 8
its strength, and to determine the best way to 9
measure, and track ASR progression at Seabrook.
10 During the test program, the NRC conducted 11 several audits, and inspections at the test facility 12 which were focused on assuring quality assurance test 13 standards were followed. This was especially 14 important knowing that the test results would be used 15 to update Seabrook's current licensing basis as part 16 of a future license amendment.
17 MEMBER BROWN: This is Charlie Brown, can 18 I ask a question on that slide?
19 MR. LEHMAN: Sure.
20 MEMBER BROWN: The test specimens, when 21 did Seabrook go critical, what year? How long ago?
22 They're in their first license renewal right now, 23 isn't that correct?
24 MR. LEHMAN: Mid 90s I believe, I'm not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 positive.
1 MEMBER BROWN: Okay, I guess my question 2
is if they went in mid 90s, and they developed these 3
test specimens, how did they account for the aging of 4
the structure over the 20, or 25 year period before 5
they actually developed these test sections?
6 MR. LEHMAN: Great question. The test 7
specimens, they accelerated ASR in the test specimens 8
by using reactive fine aggregate, and additives to the 9
mix. I think the mix design's proprietary, but they 10 basically accelerated ASR to make sure that they got 11 expansions that would mimic, or bound what they were 12 seeing at Seabrook at the time.
13 MEMBER BROWN: So the aggregate that they 14 used had greater quantities of the susceptible 15 aggregate?
16 MR. LEHMAN: Yeah, that's correct. I 17 believe, and maybe George Thomas can correct me if I'm 18 wrong, but the coarse aggregate was the same as 19 Seabrook, it's the fines that they used that were more 20 reactive. And they also added additives that would 21 accelerate the reaction.
22 MEMBER BROWN: Okay, so it's not exactly 23 the same, but it's the best they could do in terms of 24 trying to replicate the circumstances?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 MR. LEHMAN: Correct, as close as 1
reasonably possible.
2 MEMBER BROWN: Okay, thank you.
3 CO-CHAIR BALLINGER:
This is Ron 4
Ballinger, I would add that while Seabrook went 5
critical in the 90s, I guess that's true, the 6
construction period was much, much longer than that.
7 And so this concrete had been in place for a lot 8
longer than the 90s.
9 MEMBER BROWN: Good point, thank you very 10 much Ron.
11 MR. LEHMAN: I would just add that 12 obviously when studying ASR, it's very slow reacting.
13 So when you study it in a lab, it's very common to 14 accelerate it like this, otherwise it would be 15 impossible to get useful data in a reasonable amount 16 of time. So what NextEra did is not uncommon.
17 CO-CHAIR HALNON: This is Greg, the 18 operating license was 1990, just for reference. And 19 that was one of my questions Bryce, you can accelerate 20 this so that the test specimens are representative, 21 where are we with that right now? Are they still 22 monitoring them, or is the test program complete?
23 MR. LEHMAN: Yeah, the test program was 24 completed in 2016, so it's -- there's no more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 expansion, they're done with the test program.
1 CO-CHAIR HALNON: Okay, thank you.
2 MR. LEHMAN: And we'll talk some more as 3
we go, how the limits were developed from that, and 4
where Seabrook is in relation to that.
5 CO-CHAIR BALLINGER: This is Ron Ballinger 6
once again. I would add that NIST had, or has maybe, 7
a pretty extensive program on ASR, and concrete 8
deformation, and the committee, or subcommittee 9
actually visited, and observed that program in past 10 years.
11 MR. LEHMAN: Yeah, that's correct, and if 12 we get into more detailed questions about that test 13 program, I think we've got Jose Pires from research 14 that could possibly answer some of those questions.
15 But that's kind of not specific to what was happening 16 at Seabrook.
17 CO-CHAIR BALLINGER: Thanks.
18 MR. LEHMAN: All right, so I'm going to 19 move on to the next slide. The test program results 20 showed no reduction in structural capacity up to the 21 expansion levels that were tested in the program. So 22 based on that, NextEra determined that the original 23 design code equations and the original material 24 properties could be used to determine the structural 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 capacity of the impacted structures as long as the 1
Seabrook expansion remained below the tested levels.
2 The test program also showed that 3
expansion plateaued in the X Y direction, or the 4
surface of the walls due to the reinforcement in that 5
direction, and then continued in the through-wall 6
direction, which lacks reinforcement. Based on that, 7
it was determined that expansion, specifically 8
through-wall expansion was the best parameter for 9
tracking ASR progression.
10 In order to implement this tracking 11 approach, it was necessary to determine the existing 12 through-wall expansion of Seabrook structures at the 13 time when extensometers would be installed in the 14 wall, and the extensometers are the measuring tool 15 that they use to measure expansion in that through-16 wall direction. So to know the full expansion, 17 obviously you need to know how much occurred before 18 the instrument was installed.
19 Using the results of the test program, 20 NextEra developed a correlation between the measured 21 modulus of elasticity, and the through-wall expansion 22 that had occurred to date. The expansion limits, and 23 monitoring techniques were incorporated into 24 Seabrook's current licensing basis via a license 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 amendment. If the structures go outside these limits, 1
it does not necessarily mean that they've made a firm 2
safety limit.
3 But just that they've gone outside the 4
boundaries of the test program, and what was tested 5
during that program. Seabrook would need to reanalyze 6
the structures, and demonstrate operability if they do 7
go outside those limits. It sounded like there's a 8
question?
9 CO-CHAIR HALNON: Just real quick, this is 10 Greg Halnon. What was the NRC's involvement during 11 the test program?
12 MR. LEHMAN: We, NRR, or Headquarters 13 staff audited the program, and regional staff were 14 inspecting the program. So we were involved in the 15 program, mainly with the focus on quality assurance to 16 make sure that whatever results they got from the 17 program, we would be comfortable with them using in 18 the future license amendment request.
19 CO-CHAIR HALNON: Okay, did you guys do 20 any confirmatory analysis, or did you just kind of 21 stay lock in step with them through the process?
22 MR. LEHMAN: It was mainly following along 23 with them, and seeing the results as they provided 24 them. We didn't want to sort of influence the way 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 they were going with their research.
1 CO-CHAIR HALNON: Thank you.
2 MR. GRAY: This is Mel Gray, hey Matt, if 3
you go back to the previous slide. On the right there 4
-- Mel Gray, my staff at the time, we were on site, 5
that's Nik Floyd out of Region I, and Angie Buford out 6
of NRR there. We were on site, our focus at that time 7
was to ensure they were following safety related type 8
levels of quality assurance with independence between 9
the organizations testing and developing the 10 materials.
11 Mixing it, and that the results were to 12 that standard. So that was our focus, we did not --
13 Seabrook is responsible for developing the basis for 14 their licensing actions they proposed to us, but our 15 role was we wanted to ensure that the outcomes were to 16 standards that were appropriate. Does that help?
17 I'll go back on mute.
18 CO-CHAIR HALNON: Thank you Mel, it does.
19 MR. LEHMAN: Yeah, thanks Mel, and thanks 20 for pointing that out, sorry I didn't call out the 21 staff there, but in the picture, those are NRC staff.
22 Okay I think we can go to slide ten I believe. Yeah, 23 one more, perfect. So the previous two slides that 24 we've discussed covered how Seabrook addressed ASR's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 impact on the material properties of concrete, or the 1
capacity of the concrete.
2 Well, the next couple slides discuss 3
building deformation due to ASR, and how it impacts 4
the demand, or the loads on a structure. So during 5
routine walk downs in 2014, and 15, NRC resident 6
inspectors observed degraded seismic, and fire seals 7
that appeared to have been caused by differential 8
movement between the buildings, and it wasn't 9
specifically these, but you can kind of see some 10 differential movement there in the pictures.
11 And it was determined that ASR had caused 12 this movement through cumulative expansion in ASR 13 affected structures, as well as from expanding 14 structures pushing on adjacent structures. So many 15 structures at Seabrook are surrounded by concrete back 16 fill, which obviously used the same aggregate as the 17 rest of the concrete, so it's also susceptible to ASR, 18 and could expand, and apply additional loads to the 19 structures.
20 And this can kind of complicate things at 21 Seabrook, because there can be cases where the visible 22 structures themselves aren't experiencing any ASR, but 23 there's still some movement due to the backfill 24 expanding, and pushing on those structures. So the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 large scale test program did not address how building 1
deformation would affect the ability of structures to 2
perform their intended functions.
3 Therefore NextEra developed an additional 4
program called the building deformation monitoring 5
program to manage this deformation effect. The 6
program includes a methodology for evaluating ASR 7
affected structures, and the methodology was 8
incorporated into NextEra's license amendment request.
9 So, as I said, the deformation adds additional loads, 10 and you can see there in the photos, it can impact 11 attached equipment obviously.
12 The top photo shows deformed flexible 13 conduit couplings, and the bottom photo shows deformed 14 instrument air piping. Next slide please. NextEra 15 developed a three stage analysis methodology to 16 address the ASR load, and associated building 17 deformations along with the original design loads.
18 The methodology uses field measurements to estimate 19 the ASR load both in the structure itself, and in the 20 surrounding concrete backfill.
21 And then applies that load to the 22 structure, as if it were a design load. The field 23 measurements become more detailed in order to better 24 capture the ASR load as the analysis stage progresses.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 The analysis identifies quantitative acceptance 1
criteria in the form of monitoring parameters, and 2
limits that demonstrate the capacity is greater than 3
the demand, including the ASR loads.
4 These parameters are then monitored 5
against corresponding limits moving forward. If a 6
structure approaches, or exceeds the limit, it is 7
entered into the corrective action program, and may be 8
reevaluated with a
higher stage
- analysis, or 9
structural modifications may be implemented to add 10 additional margin, and I think we'll show some 11 examples of that later in the presentation.
12 A detailed description of how to implement 13 this methodology was captured in the license 14 amendment, and eventually was incorporated into 15 Seabrook's structures monitoring program. Next slide 16 please. So this slide summarizes some of the 17 licensing actions that are associated with ASR at 18 Seabrook. As stated earlier, ASR degradation was not 19 addressed in the Seabrook licensing basis.
20 So to address this, NextEra submitted an 21 LAR to incorporate the expansion limits, and to get 22 approval of the methodology to analyze structures.
23 NextEra also updated their license renewal application 24 to include activities to manage the effects of ASR 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 related aging of structures. The revisions were based 1
on the test results, and the ASR methodology provided 2
in the Lar.
3 Following an extensive review, the NRC 4
approved the license amendment, followed by the 5
renewed license in March of 2019. This review 6
included peer reviews from other offices in the NRC, 7
use of expert contractors from a national lab, as well 8
as reviews by ACRS, and adjudication by the Atomic 9
Licensing and Safety Board.
10 Next slide please. Just here I'll 11 probably go into a little bit of what the staff 12 reviewed, obviously very high level, but the staff's 13 review, and approval of NextEra's approach focused on 14 three main parts. Part one was the original large 15 scale test program, which is sort of the foundation of 16 NextEra's approach, and allows Seabrook to use the 17 original design equations, and material properties for 18 impacted structures.
19 Again, as long as the expansion behavior 20 remains below the limits, and the expansion behavior 21 is similar to that seen in the test program. The 22 staff found it reasonable to apply the test results to 23 Seabrook based on the similarity of the test specimens 24 to Seabrook structures, along with future confirmatory 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 actions to verify that Seabrook structures would 1
expand in a similar fashion as the test specimens.
2 Part two of the review focused on the 3
methodology for evaluating ASR affected structures.
4 The staff found that NextEra's methodology was 5
acceptable, because it is consistent with Seabrook's 6
code of record design philosophy. The approach for 7
estimating the ASR load is reasonable, and it's based 8
on actual measured field data. The load is 9
incorporated into the existing load combinations with 10 reasonable load factors.
11 The methodology accounts for future ASR 12 expansion that can be accommodated by a structure, and 13 identifies quantitative acceptance criteria that can 14 be measured to ensure the structures remain within the 15 bounds of the analysis. Part three of the review 16 focused on the programs developed to monitor impacted 17 structures moving forward. These included programs to 18 monitor the ASR, building deformation, and impacted 19 equipment.
20 ASR monitoring begins with visual 21 inspections of all the structures, and changes to 22 expansion measurements once ASR is identified, and 23 expansion has progressed to predetermined thresholds, 24 which were based on the large scale testing. The 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 building deformation program inspects against the 1
threshold monitoring parameters that have been 2
identified by structural evaluations.
3 These parameters are dependent on the 4
structure, and the analysis, and are different for 5
each structure. Examples of possible parameters 6
include expansion measurements, seismic gap 7
measurements, crack measurements, or measurements of 8
the distances between walls. The staff found that 9
monitoring programs were acceptable because they 10 included reasonable inspection methods, and inspection 11 intervals have become more conservative as ASR 12 progresses, and margin decreases.
13 In
- addition, quantitative acceptance 14 criteria are developed for each structure. Next slide 15 please. Here, two examples of the various monitoring 16 parameters used at Seabrook, and the tools that are 17 used to measure expansion. You can see the picture on 18 the top left is an example of pin to pin measurement 19 location, where the licensee tracks expansion in the 20 X Y direction.
21 In the top right, it just shows example of 22 the seismic gap, and that an area like that could be 23 monitored based on the output of the analysis if the 24 analysis showed that that was one of the areas that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 was critical, and needed to be monitored. The bottom 1
left shows a typical example of an extensometer 2
installed in the field. In this picture the actual 3
extensometer is covered by a plate that protects the 4
instrument.
5 But that's what it would look like in the 6
field. And then the bottom right shows a crack gauge, 7
which is used for monitoring specific crack locations.
8 Next slide please. So, again, due to the importance 9
of the test program, and ensuring that the results of 10 the test program remain applicable to Seabrook, the 11 NRC imposed two conditions on the license.
12 The first requires the licensee to assess 13 the expansion behavior at Seabrook to ensure that it's 14 behaving in the same fashion as the test program. In 15 other words, that the expansion actually is plateauing 16 in the X Y direction at a similar point as the test 17 program, and that is continuing preferentially in the 18 through-wall, or the Z direction.
19 The second condition relates to the 20 modulus of elasticity to expansion correlation that 21 was developed to estimate pre-instrument through-wall 22 expansion. This requires the licensee to verify that 23 the actual measured expansion at Seabrook aligns with 24 the predictive expansion based on the developed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 correlation. NextEra will complete the initial study 1
no later than 2025, with a follow up study 10 years 2
afterwards.
3 MEMBER BLEY: Bryce?
4 MR. LEHMAN: Yes.
5 MEMBER BLEY: Dennis Bley here. On your 6
last slide, I think that was 14, you show the seismic 7
gap in the upper right between buildings. And I don't 8
know if there's anybody here that can address this, 9
Seabrook had a rather extensive PRA performed, and 10 included seismic PRA. Has this information been 11 factored back into that risk assessment? And if so, 12 what are those results showing?
13 MR. LEHMAN: Yeah, unfortunately I can't 14 answer that, I don't know if anybody else on the phone 15 can, on the call, but if not, I'll definitely take an 16 action. It looks like we've got some takers. Mel, 17 you're on mute.
18 MR. GRAY: I got it, I'm on mute there, 19 sorry. Hey, Chris, correct me if I'm wrong, the 20 licensee has been monitoring these, and we certainly 21 focused on inspection space, but their approach has 22 been to ensure that the gaps are sufficient for 23 seismic capability design. I personally, I'm not 24 aware that's been fed back in PRA space, Chris, do you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 have anything different on that?
1 MR. NEWPORT: No, that's correct Mel, 2
yeah, they don't feed the gaps into the PRA model, but 3
they do use traditional engineering to show that 4
those, if there are reductions in the gaps, that 5
during that designed seismic event, that the buildings 6
wouldn't impact each other negatively. So they don't 7
feed into the PRA model, but they do use your 8
standard, traditional engineering approach to evaluate 9
anywhere where they find those gaps are reduced.
10 Like they would at any other plant. At 11 other plants in the country, you sometimes see the 12 gaps reduced for various reasons. They use the same 13 kind of just traditional engineering encapsulation.
14 MEMBER BLEY: So when we're doing that, is 15 the claim that the reduction in the gaps is such that 16 there's no possibility of impact? Because when 17 buildings impact, the damage is kind of uncertain 18 what's going to happen. And I'm kind of surprised 19 they didn't factor this back into the PRA. Chris, I 20 was kind of asking if that traditional engineering 21 analysis shows that there's no possibility of impact?
22 Or is it just that it's meeting some 23 standard criteria, so that there might be a chance of 24 impact?
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36 MR. NEWPORT: Yeah, I wouldn't say there's 1
no possibility. I would say when they do their 2
evaluations, they look at the design safe shutdown 3
earthquake, and they use that earthquake kind of as 4
their line in the sand they analyze to, and they show 5
given that earthquake there wouldn't be -- I wouldn't 6
say there'd be no possibility of impact, I'd say 7
there'd be no possibility of degraded performance.
8 The buildings wouldn't damage each other 9
during that SSE, what they call the SSE earthquake, 10 they don't go above that level though, they're not 11 required to.
12 MEMBER BLEY: Just for reference, the 13 design earthquake is never a big contributor to risk, 14 because we design that out. It's the earthquakes that 15 go beyond the design earthquakes that lead to 16 significant damage. And it's kind of disappointing, 17 do we know for sure that Seabrook has not included 18 that in their Seismic PRA?
19 MR. NEWPORT: Let me -- we can verify 20 that, and we can get that back to you for sure.
21 MEMBER BLEY:
- Okay, it's kind of 22 disappointing that they haven't looked at that, 23 because the possibility of damage, that's the only 24 place you really look at it, is in the PRA. So well 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 I won't say it should have been done, there's no 1
requirement to do it, but it would certainly seem to 2
me to be wise.
3 MR. FLOYD: And I can chime in a little 4
bit, because I've looked at the seismic gap 5
measurements periodically during our site visits, and 6
the areas that do have reduced gaps, they've gone 7
through, they've performed the calculation, looked at 8
the revised gaps needed. Because traditionally, they 9
just develop the standard gap of two, to three inches 10 for most of the structures.
11 With those specific analysis of hey, how 12 much slower can that be, they went back, and refined 13 that number for some of the structures, and it's not 14 such that you won't have contact, it's such that the 15 structures don't interact with one another. So that 16 would be yeah, you're not going to have contact with 17 structures, and otherwise invalidate the original 18 seismic analysis.
19 So they do have refined numbers in some 20 scenarios, and for the others, they just use the 21 standard two to three inch seismic gap.
22 MEMBER BLEY: Okay, thanks for that.
23 MR. FLOYD: Yeah.
24 MR. LEHMAN: All right, thanks Chris, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 Nik. Maybe it's just me, but on my side it looks like 1
we've lost the slides.
2 MEMBER BLEY: It looks that way to me too.
3 CO-CHAIR BALLINGER: Yeah, I can see your 4
picture, but I can't see the slides, so we ought to 5
try to fix that. I don't know who does the fixing.
6 MR. YOUNG: I will stop sharing, and try 7
to reshare the slides.
8 MR. LEHMAN: Okay, perfect, just give him 9
a second. Perfect.
10 CO-CHAIR BALLINGER: There we go.
11 MR. LEHMAN: All right, excellent. Then 12 if we can go to the next slide, slide 16. Perfect.
13 Okay, so as I mentioned earlier, the license was 14 adjudicated by the Atomic Safety and Licensing Board, 15 and the ASLB concurred with the NRC staff that 16 NextEra's proposed method to evaluate ASR is 17 acceptable, and provides reasonable assurance that 18 these structures will continue to meet the relevant 19 requirements.
20 However, the board did require four 21 additional license conditions, and I'll just go over 22 them very high level, quickly. The first requires 23 NextEra to conduct a volumetric expansion check of 24 control extensometers every six months. The second 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 requires NextEra to develop a monitoring program to 1
detect rebar yielding if the structural evaluations 2
indicate that stresses in the rebar may exceed rebar 3
yield strength.
4 The third condition requires NextEra to 5
evaluate the acceptability of a six month inspection 6
interval if through-thickness ASR expansion exceeds 7
.02 percent per year. And finally, the fourth 8
condition requires NextEra to use petrographic 9
analysis on all cores to detect internal micro-10 cracking, or delamination. So this is my last slide, 11 with that I'll turn it over to Nik to discuss the next 12 section.
13 MEMBER REMPE: Before you go on, I had a 14 question, this is Joy Rempe. And when I looked at the 15 inspection reports, it said the inspectors identified 16 findings associated with not adhering to a particular 17 procedure developed by NextEra to implement these 18 license conditions, and the approach. Could you talk 19 a little bit about how or when NextEra developed that 20 procedure?
21 Did they start off with one and then 22 modify it to consider the ASLB license conditions?
23 And when it first became available to the NRC 24 inspectors, and did they see that it was modified, or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 give us a little perspective about this in the future.
1 MR. LEHMAN: Yeah, that's a great segue, 2
because I believe that's basically what Nik was going 3
to go through in his next few slides.
4 MEMBER REMPE: Okay, I looked at the next 5
slides, and I did not -- I mean they just said that 6
they did these inspections, and I didn't see much 7
history on the procedures, so perhaps he could include 8
that in his discussion.
9 MR. NEWPORT: Nik, I have those dates here 10 if you want me to talk about the implementation dates.
11 MR. FLOYD: Yeah, sure. I mean I can --
12 yeah, I'll chime in after you go Chris.
13 MR. NEWPORT: Yeah, it's a good question.
14 What we refer to now as the license for ASR, which is 15 integrated into their structures monitoring program, 16 additional chapters they've added on. The licensee 17 developed that process, and submitted it to us, but 18 they -- before we approved it, they implemented it.
19 They started carrying out that process on site, and 20 that was in late 2016.
21 They, even though we hadn't licensed them 22 to use it, they voluntarily adopted that, those 23 procedures that you're talking about. And I'll get to 24 the conditions as well. And then we formally approved 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 that license in March 2019, which is now required by 1
regulation to do what they had already been doing 2
since 2016. And then to answer your specific 3
question, as far as the license conditions.
4 They were already
- doing, by their 5
procedures, and processes, I believe all of them, or 6
maybe all but one of the license conditions, and they 7
went back, and verified that. And they beefed up some 8
of their procedures once the ASLB issued these license 9
conditions. They also put notes in their procedures 10 saying this is a license condition. And then I'll 11 turn it over to Nik.
12 Because Nik led a team that actually 13 inspected these four conditions to make sure they were 14 properly carrying them out. So I hope that answers at 15 least part of your question.
16 MEMBER REMPE: That helps, because again, 17 as we get into what you guys detected, I'm curious 18 about how difficult it was to follow that procedure, 19 because it just seems like there's been some issues 20 that you guys have detected.
21 MR. FLOYD: Yeah, and Joy, so I will go 22 over what we found in that second quarter of 2021 23 report, in terms of the finding, and the observation.
24 We didn't have a finding on the implementation of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 license conditions. We did have an observation on it 1
though, and it was really just along the lines that 2
the methodology and the license specified certain 3
conditions on how to monitor rebar stress, and when 4
you would do that.
5 We found that for several structures, and 6
again, I'll expand on this in a couple slides, several 7
structures are outside of the current licensing basis, 8
because they exceed that structural demand to capacity 9
ratio in certain elements. And so it was for those 10 certain elements, it didn't explain specifically how 11 you'd go back, and verify your rebar stresses remain 12 bounded by the original analysis.
13 So we went through the methodology, we 14 went through the procedures, and what we found is it 15 wasn't so much implementation here, it was just that 16 it wasn't documented anywhere. They verbally 17 explained to us what they were doing, their actions, 18 how they were tracking it. But it just was not 19 written anywhere, and that's where we had the pause.
20 It's like okay, we understand, we acknowledge.
21 But you really need to write it down, 22 because you have a gap between your procedure, and 23 what you're actually doing. So that was really the 24 basis of that operation.
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43 MEMBER REMPE: Thank you.
1 CO-CHAIR BALLINGER:
This is Ron 2
Ballinger, the ASLB report, or testimony has been 3
mentioned a number of times. For those with an 4
interest, this is probably the best set of overall 5
documentation of this problem that you'll find. So if 6
you're looking to read a simple -- not a simple, 7
excuse me, one report, that's the place to go.
8 Thanks, let's keep going then.
9 MR. LEHMAN: Yeah, this is Bryce. I was 10 done, I was turning it over to Nik, so I think you're 11 up, Nik. And I was done with sort of the background, 12 and summary, so Nik's going to be talking about what's 13 happened since the license was issued.
14 MR. FLOYD: Thanks Bryce. So, yes, this 15 slide is really just to provide our overview of 16 oversight activities at Seabrook. So we do continue 17 to inspect Seabrook's implementation, and performance 18 of their structural monitoring programs regarding ASR, 19 and this is to ensure that they are identifying, 20 managing, and correcting issues in a timely manner, 21 and this is to ensure safe plant operation.
22 So what this really does is it starts with 23 the onsite resident inspector, so as you've seen, 24 Chris Newport, he's the senior resident inspector 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 there. Him, and Travis Daun, the resident will review 1
Seabrook's entries into their corrective action 2
program. They'll also review, and perform routine 3
walk downs of the plant concrete structures, that's 4
part of their daily plant status.
5 Now, they might not walk down the 6
structures every day, but they're walking down the 7
plant every week at a minimum. And then we also use 8
subject matter experts such as myself from our Region 9
I Office, as well as structural engineers from our 10 Headquarters Office with backgrounds in materials, 11 concrete, and structures to perform as needed 12 inspections.
13 And actually, if you go back, and look at 14 the history of
- this, we've been documenting 15 inspections approximately every six months going back 16 to 2013. So I'll say as far as frequently performed 17 inspections, ASR is at the top of the list. Our NRC 18 senior leadership is continually assessing the level 19 of inspection effort required under our reactor 20 oversight program.
21 So that's the baseline set of inspections 22 that we perform at the plants, and that also includes 23 additional consideration of expanding our resources if 24 necessary. Next slide please. So as part of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 approved license amendment, NextEra was required to go 1
through, and review all of the seismic category one 2
structures at Seabrook.
3 During that initial application of the 4
methodology, six structures were determined to not 5
meet the new licensing basis. So that includes the 6
original design loads, plus the ASR loads, and margin 7
for future ASR expansion. It's not the entire 8
structure, it's really just discrete locations within 9
that structure. So that could be a wall, a floor, a 10 slab, a beam, or some other type of individual 11 element.
12 For those six structures that didn't meet 13 the licensing basis, licensee did perform a detailed 14 evaluation to confirm that they are able to perform 15 their design safety functions, and we reviewed those 16 evaluations. Next slide please.
17 CO-CHAIR HALNON: Hey Nik, this is Greg 18 Halnon. Before you go on, the prompt operability 19 determination, it's not typical to have a POD that 20 goes on forever. What is the end point of this 21 operability determination, or will there be one? Is 22 this going to be something that's a living document to 23 the end of life for the plant?
24 MR. FLOYD: Right, that's a good question.
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46 So the original idea was previous to the license 1
amendment that we approved back in 2019. Basically 2
all the structures affected by ASR were under the 3
licensee's prompt operability determination. After 4
getting that license amendment, the idea was now you 5
have a methodology for evaluating ASR such that you're 6
now in compliance.
7 And so after the application of the 8
structure evaluations, which included ASR, the idea 9
was you'd be out of operability determination space.
10 Well, that didn't turn out to be the case here. In 11 fact, we didn't know it at the time, but as they were 12 applying this methodology, you added ASR loads, and 13 it's not as simple as just adding the ASR loads, you 14 also added load factors, which is a margin.
15 Plus you have to account for that future 16 ASR expansion. And so when you do that, you add in a 17 significant portion of load to that structure, and 18 what the licensee found during that is that there were 19 several areas in these six structures that weren't 20 able to meet that load criteria. So really the end 21 point of this is going to be once the licensee 22 completes -- and in these cases, reanalysis is not an 23 option.
24 So they're going to have to complete 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 physical modifications.
Once those physical 1
modifications are complete, they'll reanalyze it, 2
taking into account the increased strength, which ups 3
the capacity to account for that ASR load. And then 4
they'll be able to get out of operability 5
determination space. So it's not going to be a 6
forever thing, and certainly we do not want them to 7
stay in that space.
8 So that's something that we're going to 9
continue to monitor, inspect going forward.
10 CO-CHAIR HALNON: Okay, where does the POD 11 live, is it within the corrective action program?
12 MR. FLOYD: So the prompt operability 13 determination is its own separate entity. Any time a 14 degraded condition on site is found, it doesn't have 15 to be in the structure, it can be in any component 16 (audio interference) so you have an OD, operability 17 determination, and then in corrective action space, 18 you have to do something to get out of that OD.
19 And that can be, there's a suite of 20 options there. Analysis, inspections, replacement, 21 repair, and so the CAP (phonetic) is really a 22 byproduct to drive you out of that operability 23 determination, but two separate processes.
24 CO-CHAIR HALNON: Okay. Given that we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 hinging a lot of this on a good corrective action 1
program performance, is that performance on site 2
pretty good? How would you rate that? Maybe Chris 3
needs to weigh in on that also.
4 MR. FLOYD: Yeah, I'll let Chris chime in 5
on that since he's there daily.
6 MR. GRAY: Hey, do you mind if I chime --
7 go ahead Chris, I'm sorry, go ahead.
8 MR. NEWPORT: Sure. Yeah, so the NRC at 9
every plant in the country, every two years we do a 10 two week long inspection of their corrective action 11 program called a
problem identification, and 12 resolution inspection, and usually one of the resident 13 inspectors is on that team. But for Seabrook 14 historically, they've had no significant issue. I do 15 say that they have a strong, robust corrective action 16 program.
17 And historically we have not found any 18 significant issues with their program. Travis, and I 19 look at it every day, and this team comes in, it does 20 a deep dive every other year. So to answer your 21 question, at Seabrook there are no issues with the 22 carrying out of that regulatory required corrective 23 action process.
24 CO-CHAIR HALNON: Okay, very good. I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 assume that there was no themes emerging then in the 1
cross cutting aspect world?
2 MR. NEWPORT: No, not at Seabrook.
3 CO-CHAIR HALNON: Okay, thank you. Go on, 4
Nik, I'm good, I'm done asking questions on this.
5 MR. FLOYD: Okay, I know Mel was going to 6
chime in, I don't know if he had anything additional 7
to add there.
8 MR. GRAY: Thanks for that Nik. I don't 9
know, I was just going to say, that question, that is 10 a focus we have at Seabrook. That they have these 11 prompt operability determinations, our first finding 12 that will be talked about was all about doing that, 13 and looking forward to how long that was valid, and 14 that your corrective actions are on pace with marching 15 to correct that before there's an issue.
16 That was the message. So but Nik will get 17 into that, and what they're actually doing for mods.
18 So we have another team on in May, and that will be, 19 we are going to kick that tire hard about where they 20 are in POD space, and corrective action space.
21 Thanks.
22 CO-CHAIR HALNON: Thank you Mel.
23 MR. FLOYD: Okay, next slide please.
24 MEMBER PETTI: I have a question before 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 you get -- this is Dave Petti.
1 MR. FLOYD: Yes.
2 MEMBER PETTI: For some reason I lost you 3
part of the way, the connection, I just want to make 4
sure in my mind. So there are 20 total structures, 5
six of them outside the licensing basis, and none of 6
those six structures, there were 43 discrete locations 7
in those structures that were outside the licensing 8
basis, and that they will have to do some modification 9
to those structures as a long term corrective action?
10 MR. FLOYD: That is correct.
11 MEMBER PETTI: So, okay, thank you.
12 MR. FLOYD: So slide 19. So I put 13 together these numbers just to show where we've been 14 at in oversight space since the approved license in 15 2019. These numbers do not include the additional 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> spent by the resident inspectors on site 17 performing their routine walk downs around the plant, 18 or the daily review of condition reports.
19 But really since 2019 we've focused on 20 those structures that were reevaluated for ASR as part 21 of that methodology, and then were determined to be 22 outside of the licensing basis. Our inspections 23 verified that the licensee established appropriate 24 compensatory monitoring consistent with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 evaluations. So in most cases that included the 1
regular monitoring they were doing at an enhanced 2
frequency.
3 As well as some additional qualitative 4
monitoring looking at those specific areas of concern.
5 We also continued to review the licensee's performance 6
to monitor, and manage ASR at Seabrook. So that 7
really includes review of their monitoring data, and 8
doing our own independent looks at the data trends, 9
and walk downs. In 2021, we documented inspection 10 samples in every quarter, or every resident quarterly 11 report.
12 Two of which were inspection findings, and 13 we'll cover that in the next couple of slides. And I 14 didn't put this on here, but myself, Region I, and NRR 15 plan to be back on site the week of May 9th to perform 16 additional inspections. So that'll be the second 17 quarter of this year, 2022. Next slide. So this 18 chart summarizes the methodology process to evaluate 19 the impacts from ASR.
20 And those impacts aren't just ASR itself 21 in the structure, but also includes indirect impacts 22 of loading from backfill external to the structure.
23 As Bryce previously described in the background 24 section, there are three different stages of analysis.
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52 Of these analyses, critical areas are identified for 1
additional monitoring based on the available margin in 2
that structure.
3 And these are those areas that are a part 4
of the threshold limits. So while we're on this 5
slide, I want to highlight two areas on this chart 6
where we focus our inspection efforts. That first 7
green box is the structure's monitoring program. So 8
this is when we're reviewing the data, doing our own 9
independent walk downs, and also doing our own 10 informal trends of the ASR data on site.
11 And then we'll compare that to what the 12 licensee is documenting. We'll also look at a sample 13 of that threshold monitoring data during our 14 inspections, and that ensures that those structural 15 evaluations remain valid. And then now we're moving 16 into kind of the later phase of this chart, which is 17 corrective action. So right now, those structures 18 that are not in compliance with the new license, 19 they're in POD space.
20 So we'll look at the enhanced monitoring 21 for those structures, and as they're moving towards 22 their physical modifications as part of the long term 23 corrective actions, we'll basically review the plans, 24 and then the in progress work. And since we, I'll say 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 Region I experts are not always on site, Chris, and 1
Travis will assist us with that. And then we're going 2
on site next week -- actually not next week, in the 3
next few weeks in May, we'll look at the in progress 4
modification work as well.
5 So this process is the methodology that 6
the NRC approved. We do hold the licensee accountable 7
to this process. We have not identified issues with 8
the collection of the monitoring data, or the 9
methodology process itself, but really what we're 10 seeing is implementation of specific procedures, so 11 I'll discuss those now. Next slide please.
12 So for this second quarter 2021 report, I 13 led this inspection with the assistance of our NRR 14 structural engineers. So that's Bryce Lehman, and 15 George Thomas is also on the call. The resident 16 inspectors identified to their review of the 17 licensee's corrective action program, that three 18 structures had exceeded their threshold limits. At 19 that point in time, Chris reached out to me at the 20 Regional Office for expert assistance.
21 So it's important to note this is the 22 first time the established threshold limits had been 23 exceeded, but these buildings were already in POD 24 space, so it didn't change that, it just changed the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 fact that they had monitoring data that now is 1
progressing. So we performed a detailed review of the 2
prompt operability determinations for four structures, 3
that included the three that had exceeded their 4
threshold limits.
5 And this was to verify their continued 6
safety function. We also looked at the associated 7
corrective actions licensee had put in place, and the 8
timeliness of those actions. And this is really 9
focusing on their long term modification plans. While 10 reviewing the ASR monitoring data, which was also the 11 threshold monitoring data, I also looked at the trends 12 in expansion measurements.
13 We identified that NextEra did not account 14 for the future progression of ASR in their prompt 15 operability determinations. More specifically, the 16 pin to pin measurements on multiple walls in the 17 control, and diesel generator building showed an 18 observable trend. And this was based off of me 19 looking at the data, and just making a trend graph, 20 and seeing that hey, there's a positive trend here, 21 and it needs to be accounted for.
22 So rather than evaluate this projected 23 trend as required by their operability determination 24 procedure, NextEra was evaluating the impact of that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 increased expansion after it had occurred. So this is 1
important, because as you get increased ASR expansion, 2
that's going to result in increased loading. And so 3
by their own procedures, they should project what that 4
increased expansion, and resulting loading should be.
5 So they know the next time they do those 6
expansions, they'll be okay, and it'll be an 7
acceptable condition, and rather than being proactive, 8
they were being reactive.
9 CO-CHAIR HALNON: So, Nik, this is Greg 10 Halnon. I've seen through the documentation that the 11 issue was addressed, but I never saw why it happened.
12 I mean you used words like this is very important, 13 this was easy to do, this was in their program. Can 14 you address why it happened?
15 MR. FLOYD: That is a tougher question to 16 answer. Really just because you have procedures in 17 place, if you follow the procedures, it'll get you to 18 the correct outcome. And I'm not exactly sure, maybe 19 Chris can chime in here from a plant perspective, how 20 they got in this boat. But yeah, I don't have the 21 full reason as to why.
22 MR. NEWPORT: Thanks Nik, I won't answer 23 why, but I can tell you what the plant did, which I 24 think might help. As a result of this finding, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 some other issues, and observations that we brought to 1
their attention, they did bring in a new manager to 2
lead the ASR program, and they bolstered the staffing 3
of the program.
4 So they did make some fairly resource 5
intensive, and significant changes to how they run the 6
ASR program as a result of some of the issues that 7
we've brought up here, that were discussed today. So 8
I don't want to speak for the licensee as to why it 9
happened, but I can share with you what they've done 10 to help mitigate these types of things moving forward.
11 CO-CHAIR HALNON: As I've seen these types 12 of programs in the past, they become routine, and off 13 the radar screen sometimes. And I'm just wondering if 14 that's what occurred here, or I don't want to 15 necessarily say complacent, but it becomes more of a 16 routine, and then a lapse in personal performance, or 17 lapse in management attention may allow one of these 18 minor deficiencies to fester a little bit.
19 I was just thinking, wondering if the 20 staff had written a condition report on the actual 21 performance of the program, not necessarily the 22 technical aspect of it, and done an organizational 23 effectiveness type review. And maybe that's something 24 just to go do, Chris take a look at, and see. I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 understand that they made some corrective actions 1
organizationally, but they didn't address the actual 2
issue.
3 MR. GRAY: Chairman Halnon, this is Mel 4
Gray. I'd probably feel more at ease giving a broader 5
view than the staff. First of all, I will say that 6
this was a finding, we will go back and look at the 7
corrective actions, and it's up to the licensee to 8
identify the causal factors of the corrective actions 9
match. But of course I've had oversight of this for 10 a number of years.
11 My sense is, I'll offer up, is that the 12 licensee, NextEra, has brought to bear very good 13 technical support. And they provide products to the 14 plant that sometimes their contractors aren't nuclear 15 per se. They'll provide something, and putting that 16 in processes in the plant, and thinking about looking 17 forward to the next exam is not something the 18 contractor did for them.
19 But they missed that in accepting that 20 product at that point. And I think that might be a 21 common thread in both findings. This is my view, and 22 Chris is correct. What they did in this instance, 23 they did put an individual in charge that had a 24 background in things like IST, testing of pumps, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 valves, where you routinely look forward, and project.
1 So my sense is that. We will look at 2
corrective
- actions, and determine if they're 3
effective, and of course our inspections will bear 4
that out also. But I thought I'd share that, it's 5
certainly not complacency, it might be the translation 6
of highly technical products into normal station 7
procedures. So thanks.
8 CO-CHAIR HALNON: Thank you Mel. And I 9
assume that this is a topic that's discussed at those 10 senior management meetings that you guys talk about --
11 was it a couple times a quarter you said you speak?
12 You're on mute Mel.
13 MR. GRAY: Yeah, I'm sorry. We certainly 14 do that at our periodic end of cycle, and mid cycle, 15 and more often at the branch level, so yes, that's the 16 case.
17 CO-CHAIR HALNON: Thank you.
18 CO-CHAIR BALLINGER: Joy has her hand 19 raised, I hope it's current, and not a residual.
20 MEMBER REMPE: It's current. I guess I 21 wanted to follow up on my earlier question, and Greg's 22 comment. Because again, I'm trying to understand 23 better, a root cause, which maybe you're saying the 24 licensee still hasn't completed that. But I've heard 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 well it wasn't complacency, it was the first time that 1
they hit a trigger point, again, in my review of this 2
material, so correct me if I'm misunderstanding it.
3 But they hit a trigger point in the 4
procedure, and I heard earlier today, no, they had 5
flags in the procedure to tell them to do something.
6 And I'm just wondering if the procedure was difficult 7
for them to follow, or it was just sometimes mistakes 8
happen, and it would be interesting to better 9
understand the root cause to make sure that maybe some 10 bigger flags are needed, or something.
11 But I'm sure that this lesson has been 12 carefully honed in on to the staff by now. But again, 13 you're looking for other places where similar things 14 might occur, and you want it to be as easy as possible 15 for the staff to follow it. It's why I had asked the 16 earlier question, and I'm reiterating it again. Are 17 the flags, and is the procedure easy enough to follow?
18 MR. NEWPORT: That's a great question, 19 great insights. To zero in on what you say, the root 20 cause. The cause of these issues is more on the human 21 performance side than on the procedures side. I'll 22 tell you that the changes that they made at the site 23 were on the human performance side. So new 24 management, additional management, additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 scrutiny.
1 The site vice president gets a personal 2
weekly brief now on these things. So to answer your 3
question, I hesitate to pass on opinions on behalf of 4
the licensee of that density, but the changes they've 5
made are all oriented to that human performance side, 6
versus the procedure side. So hopefully that helps 7
answer your question.
8 MEMBER REMPE: Okay, it's just something 9
when I looked at it, and I'm still kind of puzzling a 10 bit about it. But I get where you're saying you don't 11 want to answer for them, but anyway, thank you.
12 MEMBER BROWN: This is Charlie Brown, can 13 I ask a question also? You still there? Can you hear 14 me?
15 MR. FLOYD: Yes, go ahead, sorry, I was 16 nodding.
17 MEMBER BROWN: All right, I couldn't see 18 your head nod on my screen, and now I see it, thank 19 you. I look forward to -- there was a February 20 inspection report also that followed up, I guess on 21 the August -- I thought it did, report that we've been 22 talking about where you talked about corrective 23 actions. And did those -- I guess it was on page 19, 24 started on page 16, 19 PDF, but page 16 of the report.
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61 I didn't see a conclusion, it just said 1
the corrective actions were generated committing to 2
the performance, it was stage two ASR related 3
structural evaluation per the monitoring program. But 4
you still didn't get -- there was no conclusion when 5
I left that, that things were okay, or not okay. It 6
was just that the deficiency was not a high level 7
deficiency.
8 It was -- how did they phrase it? The 9
significance of the finding to be of very low safety 10 significance. That was a two page evaluation that 11 looked to me like a follow up on the August, this was 12 in the February 21st issued inspection report.
13 MR. NEWPORT: That's our next topic, so I 14 think we can --
15 MEMBER BROWN: Okay, I'll pass then, go 16 ahead.
17 CO-CHAIR BALLINGER:
This is Ron 18 Ballinger, am I to understand based on all this 19 discussion, that there will be a root cause report 20 that's produced by NextEra, and that that would 21 probably answer all of these questions that we've been 22 having? Am I getting this right?
23 MR. NEWPORT: No, and that's why I 24 hesitated to use the word root cause, because in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 regulatory space, that's a very specific word.
1 NextEra has not performed, nor are they required by 2
their procedures to perform a wort cause for these 3
green findings that we've identified. That being a 4
formal, structured root cause.
5 There's very specific criteria in their 6
procedures for them to do one of those analyses, which 7
are pretty high level, you have to cross some pretty 8
high thresholds to do a full root cause evaluation.
9 But they have done lower level kind of causal 10 products, and made, like I said, some significant 11 changes to bolster the program. It was not a formal 12 root cause evaluation.
13 CO-CHAIR BALLINGER: Okay, I'm using the 14 wrong words then, but the fact that they made some 15 changes, suggests to me that somebody thought about it 16 before they made the changes.
17 MR. NEWPORT: Well, we call it broke fix, 18 when something happens, they just fix it, and move 19 along. Internally, we call that broke fix. They did 20 not do that here. With these issues, like I said, 21 they did kind of what you'd see out of a root cause, 22 they did some analysis on why did this happen, and how 23 do we prevent it from happening again? And so they 24 went beyond just fixing the issue.
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63 They implemented these changes that we 1
talked about, that will help prevent these things from 2
happening again in the future. Does that get at your 3
question?
4 CO-CHAIR BALLINGER: Sort of, but you're 5
saying that that's not documented anywhere?
6 MR. GRAY: Chris, this is Mel Gray. I 7
think I would say that our inspection identified the 8
issue. We made sure the plant was safe before we left 9
the site. They put it in their corrective action 10 process. As to what they've done, and have we 11 formally inspected that yet? No. And we haven't put 12 pen to paper for you to scrutinize that. That's 13 probably the narrative there.
14 Is that, Nik, and Chris, I think that's 15 the gist.
16 MR. NEWPORT: Yeah.
17 MR. GRAY: In the same report, we didn't 18 tackle corrective actions, except the ones needed to 19 help us determine that the plant was safe.
20 MR. NEWPORT: Yeah, they did what they 21 call an organizational effectiveness investigation.
22 It was Travis, and I informally reviewed as part of 23 our daily day to day activities. We didn't document 24 formally our review in a public inspection report, if 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 that's what you're getting at.
1 CO-CHAIR BALLINGER: Okay, so now you're 2
using Halnon language.
3 CO-CHAIR HALNON: Ron, this is a typical 4
corrective action program type performance, where you 5
get a finding of low safety significance that goes 6
into the corrective action program, and then that 7
process carries it through to completion including --
8 and there may be some narrative in that document about 9
what the apparent -- I even hesitate to use apparent 10 cause, because that's a process within the industry as 11 well.
12 But maybe a perceived cause, and fix, down 13 to what Chris was saying, was a broke fix. Which is 14 it's evident what happened, let's just fix it. So I 15 don't see anything outside the norm of the regular 16 corrective action process that they're talking about.
17 I wanted to make sure that the organizational 18 effectiveness piece was addressed.
19 It sounds like from what you just said 20 Chris, it either is, or has an ongoing process of 21 being addressed by the station management, and I think 22 that was the key aspect here. That station management 23 is aware of organizational issues, and have taken 24 corrective actions based on them.
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65 MR. NEWPORT: Yeah, I'll emphasize that 1
again, they've taken substantial actions to bolster 2
their programs as a result of some of these issues 3
that we're briefing. And I talk with them, I talk 4
with their manager, and I talk with the site vice 5
president at least monthly, if not weekly, sometimes 6
daily. But I run into them in the hallways, and ASR 7
comes up a lot.
8 So there's a lot of informal conversations 9
that I have. My boss, Matt Young, talks to them when 10 he's on site, his boss talks to them. So there's a 11 lot that's going on here. And I'll just say right 12 now, I'll speak for myself here, we're confident right 13 now that the changes they've made, they've bolstered 14 the program.
15 They've beefed it up to where it needs to 16 be to make sure that nothing is slipping through the 17 cracks like we've seen here with some of the findings 18 we're briefing.
19 CO-CHAIR HALNON: Sounds good. Now, Steve 20 Schultz, you've got your hand up?
21 DR. SCHULTZ: I did Ron, thank you. I 22 don't want to parse the words here on the presentation 23 paragraph here on the green finding, but I want to 24 understand the phrase did not adequately account for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 the future progression of ASR, and then it continues 1
in the prompt operability determination. But as was 2
described earlier in the overall program for ASR at 3
Seabrook, the structures monitoring program.
4 There is a margin that looks at the future 5
of structural capability of the buildings, and 6
structures associated with the safety of the plant.
7 And so there's a timing that's associated with that 8
piece of it in the evaluation, and there's margin 9
associated in that evaluation, and analysis. What 10 you're talking about here is, you mentioned the 11 evaluation of the ASR in between the inspections that 12 wasn't being accounted for.
13 Can you describe for us more clearly what 14 the inadequacy of accounting for future progression is 15 here? Or, maybe just speak to the rate of progression 16 as it relates to the structural evaluations that were 17 discussed in the first presentation.
18 MR. FLOYD: I'll try my best, and anyone 19 else that wants to chime in, please go ahead. But 20 specifically, the reason why I say in the prompt 21 operability determination is because these are, at 22 least the structures we inspected for this inspection, 23 these are structures that are already outside of that 24 licensing basis. So ideally when you're in compliance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 with the methodology in the licensing basis, there is 1
margin for future expansion.
2 There's also the additional load factor, 3
so there's plenty of margin to accommodate any type of 4
expansion in that structure, and then you monitor that 5
limit to ensure that you don't remove that margin up 6
to a limit. Once you exceed that, and now you're --
7 I'll say eating into that margin, now you're outside 8
of your licensing basis. Now it's not complying 9
anymore, and you have to restore that compliance 10 somehow.
11 So as they work in this interim before 12 they do these corrective actions, they have to ensure 13 the structures remain capable of performing their 14 function, and they do that through going back to the 15 calculation, and looking at areas where they can chip 16 away the margin, and part of this is removing some of 17 that future expansion. So in the original analysis, 18 all of that loading already incorporated all those 19 extra loads.
20 Once you remove those, and you continue to 21 monitor, now any additional expansion you get, they 22 have to go back, and reevaluate that as an additional 23 impact on the loading. So basically any time they 24 take monitoring data, if you've already exceeded a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 limit, you've got to project ahead, hey, how much 1
further is it going to exceed it so that they know how 2
much additional load is going to be on there.
3 And that's not typical for the structures 4
on site. It's really just for some of these specific 5
structures that are in POD space, so under the normal 6
structures monitoring program, we wouldn't be talking 7
about this, but just because they're in POD space, 8
that's why this was important. I don't know if that 9
clarifies your question though.
10 DR. SCHULTZ: It does, and that's actually 11 exactly what I wanted to make sure we explained at 12 this time, thank you.
13 MR. FLOYD: Okay, you're welcome. Are 14 there any more questions? I don't want to move on if 15 anyone has anything, and we can always come back to 16 this as well. Okay. Just a quick, important note 17 here. So this finding is really written about the 18 trend that I saw on the control, and diesel generator 19 building. The other structures we reviewed, I didn't 20 see any similar trends.
21 So this was really just, in terms of 22 expansion rates, isolated to this one structure.
23 Separately, we also had an observation on, and this is 24 by proxy, because they're kind of one, and the same 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 trending of the data. The observation that they 1
didn't have trend data to inform the timing of their 2
long term corrective actions. So the example here, 3
again, I'll go back to the control, and diesel 4
generator building.
5 They showed an observable growth on a few 6
of their ASR grids, but they didn't have a physical 7
modification plan until out in the year 2026. So 8
based off that trend, I looked at the timing of the 9
corrective actions like well, you're not really going 10 to meet that time line. And so part of the corrective 11 action in response to our finding, and observation, 12 they now have trend projections for each of the 13 monitored structures now.
14 I think that was their original intent, 15 but we saw it, and we brought it up to their 16 attention, and that's how we got to the findings. So 17 now going forward, while they correct trend data, 18 they're also projecting setting trend data, and that 19 will inform the timeliness of their future corrective 20 actions.
21 So basically if you do see an observable 22 trend, you'll be able to hedge that off, and correct 23 the structure before you get there. So that was 24 another key piece of this inspection.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 CO-CHAIR BALLINGER: This is Ron Ballinger 1
again, the conditions of operation required them to 2
trend it, did it not?
3 MR. FLOYD: They should -- so they have 4
kind of, they document the measurements, they kind of 5
have trends. What I didn't see, what I did myself, is 6
I actually plotted out those trends. I did it for 7
myself, I wanted to see what this data looked like, 8
and so I hadn't seen that previous. They had previous 9
trends for CCI, and expansion measurements. But in 10 terms of the data I looked at, I was looking at the 11 threshold monitoring data.
12 Which is kind of a separate set from the 13 initial chapter two ASR data. And so I was plotting 14 that threshold monitoring data, and that's where I saw 15 this trend. But no, their own program would point 16 them to do some trending, it's just I did not see 17 that.
18 CO-CHAIR HALNON: Nik, this is kind of a 19 disconnect in my mind, and maybe you can provide some 20 help. It seems very fundamental to do this, either in 21 another process called scheduling, and planning of 22 modifications, or just in the assessing of the risk of 23 a corrective action, how long it can be open. So this 24 seems fundamental to corrective action process, to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 modification planning
- process, accountable 1
engineering.
2 A system engineer type person, are you 3
confident that the changes they made in the 4
organization have been resensitized to this, where 5
these fundamental issues like what you just found are 6
going to get covered in the future?
7 MR. FLOYD: So Chris is probably the 8
better person to weigh in on this right now, because 9
he's seen the changes since the last time I was on 10 site. When we go back in May, one of the key 11 objectives of that inspection is I'm going to follow 12 up on the results that we had from this report.
13 Primarily looking at the timeliness of their future 14 corrective actions.
15 So I expect to see some major changes as 16 a result of that, but I can't comment on it yet, 17 because we haven't been back. I don't know Chris, if 18 you have any addition to that. Before I left, they 19 had many trend progressions for each of the structures 20 that they showed me, including the one that I brought 21 up in the findings. So I felt confident when I left 22 the site.
23 But going forward, for the remainder of 24 the structures that are going to require modification, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 I have not looked at those in detail yet.
1 MR.
NEWPORT:
The answer is yes.
2 Currently, I am confident, and I passed onto my 3
management, that we're confident the changes they've 4
made bolstered the program to where we believe it 5
needs to be. That being said, ASR is not a static 6
thing, it's not a static phenomenon. So going 7
forward, as long as the plant is going to continue to 8
operate, it's going to require intensive scrutiny, and 9
attention.
10 It's not something that just sits 11 passively in the background. So it's incumbent on 12 both the plant, and this is messaging we send to them, 13 both the plant, and the NRC frankly, to continuously 14 monitor this, and to continuously give it the scrutiny 15 that it needs. Because it's not just a static 16 condition that is never changing. So currently, yes, 17 the program is bolstered.
18 They made significant changes that put the 19 program where it needs to be, but it requires a 20 continuous attention as long as the plant is 21 operating. Did that answer your question?
22 CO-CHAIR HALNON: Yeah, it did, thanks.
23 And I'm continuing to poke at, I guess the 24 organizational effectiveness, and just making sure you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 guys have assessed it, and are confident that these 1
are behind us. It comes down to the next finding that 2
we'll talk about, and the conclusion that it was not 3
indicative of current performance.
4 Apparently it was, and maybe address the 5
fact that -- when you get into the next finding, which 6
we can go onto right now, whether, or not that was a 7
missed opportunity to address some of these 8
fundamental issues that we're finding now. So go 9
ahead, let's move on, and then we can talk more about 10 organization if it comes up.
11 MR. FLOYD: Okay, yeah, I didn't have 12 anything additional on this slide. So with that, I 13 will turn it over to Chris to discuss our inspection 14 results from the fourth quarter report.
15 MR. NEWPORT: All right, thanks Nik.
16 Thank you everyone, appreciate the opportunity to 17 present the NRC's perspective on the ASR, and ASR at 18 Seabrook, and what's been happening. My name is Chris 19 Newport, I'm the senior resident inspector at 20 Seabrook. My colleague, Travis Daun, he's on the call 21 today, he's the other resident inspector here at 22 Seabrook.
23 As I think you're all aware, Travis and I 24 live in the area, we work on site, we're on site every 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 day, we're out in the plant every day, interacting 1
with the licensee every day. We review the corrective 2
action documents every day as they come through.
3 While I'm not a practicing structural engineer, and I 4
can't perform elemental analysis, or even review some 5
of those more complex products, Travis, and I both do 6
understand the framework of the program.
7 How the program needs to be implemented.
8 And we know when to call for help is what I'd say. So 9
we see these products, we see them come through, we 10 see what's happening at the plant, and when we see 11 things that we think need more scrutiny that exceed 12 our ability, we call for help from Nik, and our 13 partners at headquarters. A lot of the things that 14 the plant -- pumps, and valves Travis, and I can 15 handle.
16 But for some of these more technical 17 issues, I wanted to emphasize that we do work with 18 headquarters, and some of our experts there to really 19 make sure we're getting an independent safety review 20 on all of these products. So I wanted to talk about, 21 this is one of these findings that's probably come to 22 your attention, and we wanted to make sure you're 23 aware of what the issue is, and what happened.
24 This was in the fourth quarter of 2021 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 during a refueling outage. While they're talking 1
about an instance where Seabrook failed to properly 2
implement the program, they failed to properly perform 3
a very specific, one of these building deformation ASR 4
related evaluations that's required by their new 5
license program. So next slide please.
6 So, again, the area that we're talking 7
about, and hopefully our graphics here can help, it's 8
inside of containment, and it's part of what they call 9
the containment internal structures. Specifically 10 it's the reactor cavity pit. So if you can see the 11 blue dot that I think Matt's circling there, you can 12 almost think of it like a basement. You have the 13 floor of containment, but there's a cut out in the 14 middle.
15 And the picture on the top is kind of an 16 overhead view of that cut out. But it's basically a 17 cut out down through the floor of containment that 18 allows the reactor vessel to kind of, it hangs there 19 above the cut out, and allows access to the underside 20 of the reactor vessel, both for inspections, and then 21 also there's some detectors, and instruments that come 22 up through the underside of the reactor vessel there.
23 This area has a lethal radiation dose 24 while the plant's operating, there's a direct neutron 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 dose coming down under there, so you cannot go in 1
there while the plant's operating, so it's an 2
inaccessible area. It's an area that's generally only 3
accessible when they shut down for a refueling outage, 4
which is once every 18 months. So this refueling 5
outage in the fall of 2021.
6 They went down there for their required 7
structural monitoring inspections, and this is me in 8
the picture here, if you look at my right knee, you 9
can see this is a non-structural floor slab that's in 10 direct contact with the vertical structural wall. You 11 can see the spalled concrete by my right knee, and you 12 can see a bowed deck plate there. And that was not 13 there the last time that the licensee inspected this 14 in 2018.
15 So what it appears, that vertical wall 16 that you can see where I'm shining my flashlight, it 17 appears that that vertical wall had been placing 18 stress onto that floor slab, and spalled up the 19 concrete, and bowed up that deck plate. So obviously 20 that raised the attention of the licensee, and that 21 raised our attention. So Travis and I, within the 22 next morning, we went down there.
23 And did our own independent inspections of 24 what was going on down there. And so we started 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 pulling the thread on what happened here, what's going 1
on down there? And what's the licensee, what have 2
they done, and what are they doing to correct this 3
issue? So what we found down here is kind of what 4
some of these classic signs of potential, I want to 5
emphasize potential building deformation.
6 So you see on the vertical wall here, some 7
horizontal, what is called flexural cracks. Obviously 8
you see the bowed deck plate, the spalled concrete, 9
which would lead one to believe that that vertical 10 wall might be pushing up against that floor slab. And 11 then around the corner not shown in the picture there, 12 there are some wide cracks that had opened up on some 13 weak points in the structure, and the door opening.
14 So all of those together, instinctually, 15 as an inspector who knows about ASR, I said huh, that 16 seems to me like that could be building deformation.
17 So we pulled the thread, we went, and we looked at 18 their formal license program. And it actually gives 19 in the program very specific sets of criteria that 20 said you shall do a formal ASR driven building 21 deformation evaluation, finite element analysis model, 22 if you see these signs of degradation.
23 And what we saw down here in the cavity 24 pit clearly met those criteria, and that told us as a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 regulator that they were required to do this 1
evaluation, that basically they had not done. And let 2
me talk about the history there to tie this together.
3 Like I said earlier, they submitted this, the ASR of 4
the entire program to us to approve as a license 5
amendment way back 2015, 2016 time frame.
6 They adopted the program, even though we 7
hadn't approved it yet, in late 2016. So as early as 8
2017, they were down here in the cavity pit looking 9
for some of these ASR related building deformation 10 signs. And you can see on the wall, barely, some of 11 the markings, the crack width markings there. Those 12 were placed there in 2017 as they were starting to go 13 through, and do these analyses on these buildings.
14 So these cracks were known to the 15 licensee, the spalling of the concrete, and the bowed 16 deck plate you saw there, that was first identified in 17
- 2012, before they even know about building 18 deformation, and they repaired it, so it respalled 19 recently. So what we discovered is that we had 20 documented this, and they had done an evaluation of 21 this.
22 But the evaluation that they did was more 23 of a traditional structural evaluation, as if there 24 was no ASR potentially impacting the walls. So they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 looked at it for reductions in friction shear 1
strength, more of your classical, we had a crack in 2
the wall, is the wall okay? But what we saw, what we 3
determined is that when you look at this building 4
deformation, and the potential issue here is not that 5
there's ASR in this vertical wall that you see here.
6 There's no ASR in this vertical wall, 7
there's a steel liner plate behind it, so there's no 8
ground water in that wall, no humidity impact on that 9
wall, it's a very dry space. But what potentially 10 could be happening is that that backfill concrete 11 that's behind this wall, sandwiched between the 12 bedrock, and the wall, that backfill concrete 13 potentially does have ASR in it.
14 And it potentially is exerting a force on 15 that wall, which would cause it to bow out like you're 16 seeing there, and impact the deck plate. The 17 licensee's contractor, they assessed this, like I 18 said, and they said this was not due to the building 19 deformation, this was due to shrinkage, and due to the 20 differential temperatures. But our assessment was 21 your program says if you see these things you shall do 22 an evaluation.
23 Taking into account any potential loads 24 that those forces might be putting on the wall, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 they didn't do that, and their procedure required them 1
to do that. And that's in a nut shell, what our 2
finding was.
3 CO-CHAIR HALNON: So, Chris, is the 4
containment, the steel liner in the reactor building, 5
the concrete?
6 MR. NEWPORT: Well, if you look at the 7
side view here, you see this thin black line? So one 8
of the primary purposes of containment is it acts as 9
a giant pressure vessel. And there's a huge, air 10 tight, steel liner plate that surrounds all of 11 containment, and that's what holds the pressure in.
12 The concrete --
13 CO-CHAIR HALNON: Right, so that's 14 containment, and the concrete's the shield building 15 essentially.
16 MR. NEWPORT: That's right.
17 CO-CHAIR HALNON: So was the evaluation 18 they did based on the deformation, apparently it's 19 pushing against that steel liner, has that steel liner 20 as well been evaluated as acceptable to continue being 21 in containment?
22 MR. NEWPORT: Yeah, that's a separate --
23 you're talking about, because the purpose of the steel 24 liner is to prevent, during an accident with fuel 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 damage, to prevent radionuclides from getting out to 1
the public.
2 CO-CHAIR HALNON: Correct.
3 MR. NEWPORT: Yeah, there's no signs in 4
this vertical wall right here, there's no sights of a 5
breach of that liner. But from a safety significance, 6
for a radionuclide, the cracks aren't big enough, 7
there's no way that radionuclides could get through 8
those tiny cracks, and then somehow through -- the 9
path would just be too torturous, and even then, it 10 just hits that back fill concrete.
11 So there's not a safety concern for 12 purposes --
13 CO-CHAIR HALNON: I guess my point is, and 14 maybe I heard it wrong, that the back fill is pushing 15 against the steel liner, which is pushing against the 16 internal concrete, which is causing it to spall. So 17 the liner must be moving as well, so if there's 18 deformation in the liner, has that been evaluated?
19 MR. NEWPORT: That's going to be -- so 20 this is the corrective actions. What we said we 21 didn't do is this formal ASR related license finite 22 element analysis, what they are going to do is called 23 a stage two analysis. That takes a considerable 24 amount of time, and that's in progress right now, as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 a result of this finding that we documented. That 1
should be done by the fall.
2 It will take all of that into account, and 3
that will be heavily scrutinized by the NRC when that 4
product is complete.
5 CO-CHAIR HALNON: Do they have an 6
immediate operability determination, if the liner is 7
acceptable for lasting that
- long, until the 8
operability determination is complete?
9 MR. NEWPORT: They did -- so I was going 10 to get to that. They did do, because they're 11 automatically not in compliance, because they haven't 12 performed this evaluation. They did do an operability 13 evaluation that did assess the wall, the structural 14 strength, that the wall can still perform its safety 15 function. Which, we reviewed, and we agree that it 16 could still perform its safety function.
17 Nik, if you want to chime in, I don't 18 think it specifically addressed the liner, but we have 19 talked about that. And there are no safety concerns 20 with that, somehow that liner allowing radionuclides 21 to get out into the public.
22 MR. FLOYD: Yeah, I'll chime in, I've got 23 a couple of tidbits I can add here. Actually I made 24 this little diagram here, so I hope it helps. So the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 primary containment is this gray line with the black 1
line touching it. That's the primary containment 2
structure, that's the one that's credited for all your 3
design basis accidents for things occurring inside 4
containment.
5 So loss of coolant accident, main steam 6
line, feedwater breaks, everything under the sun in 7
design accident space, that's that piece, that's 8
primary containment. The second gray line outside of 9
there, that's your containment enclosure building. So 10 that's your containment around the containment so to 11 speak. So both of those two structures have been 12 evaluated by NextEra, and the NRC has reviewed those.
13 So we don't have any issues with those two 14 structures. The new structure in question is called 15 the containment internal structures, it's very much 16 everything else concrete wise, other than those two 17 things. So that includes the dark gray horizontal 18 line, that's your containment base mat, so that's 19 basically your containment floor. And then it also 20 includes kind of the hatched black, and gray area.
21 That's all of your foundation mat, and 22 there is a very, very thin layer of back fill 23 basically underneath, and surrounding that. But it's 24 all of that concrete which basically is your 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 supporting containment foundation, and then all the 1
concrete structures inside that the licensee is now 2
going to have to do an evaluation for.
3 So in the prompt operability determination 4
that the licensee did for the containment internal 5
structure, it looks at the structure itself from a 6
structural standpoint, they did not specifically 7
address any impacts to the containment liner. Now, we 8
don't know for a fact if it is being impacted by ASR.
9 We have our suspicions, and per their process, they 10 need to do an evaluation.
11 Which is going to include, and they 12 already started taking measurements during the last 13 refueling outage in the fall of 2021. So they need to 14 take the measurements, they need to do the evaluation, 15 and start adding up what those ASR loads, and 16 deformations are going to be. And then they'll have 17 their formal stage two evaluation completed, I think 18 the estimated time period for that is later this year, 19 that we'll look at.
20 But there was no discussion on the liner 21 in there. I would not suspect there is any impact to 22 the liner right now, given what we're seeing in there, 23 but it was not formally evaluated by the licensee.
24 CO-CHAIR HALNON: Okay, I was just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 reacting to the cause of the bowing of the grating.
1 It looks roughly half inch maybe movement that caused 2
that to bow, which means if you translate that back 3
all the way to the back fill, that steel liner must be 4
deformed in some respect.
5 MR. FLOYD: Potentially so, that was the 6
other piece, sorry, I wanted to add a correction to 7
what Chris said earlier. So that steel deck grating 8
right there, that was previously deformed, and 9
identified by the licensee going back to as early as 10 2017 when they did their initial walk downs. What was 11 new was this spalled area that had respalled, that was 12 the new indication that we had not previously seen.
13 MR. NEWPORT: Yeah, to answer your 14 question, they did not evaluate specifically the liner 15 in a prompt operability determination. They have no 16 indications that it's, what they would call breached 17 right now, and we don't -- the safety concern there, 18 that liner not being able to perform its function, we 19 don't have a concern with that, with this specific 20 wall given its location below grade.
21 And what's behind the wall, so I hope that 22 answers your question.
23 CO-CHAIR HALNON: Yeah, given that you've 24 physically put your eyes on it, you don't have a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 concern, I will take credit in your experience, and in 1
your inspection. I would just think that that would 2
be a good thing to say somewhere in writing, that we 3
don't have a concern with that respect, since it's 4
part of that whole structure that's in question at 5
this point.
6 MR. NEWPORT: Yeah, that's an insightful 7
comment, much appreciate, very insightful comment. To 8
reiterate, our main concern here, and again, the 9
licensee's contractor, and they're very smart, they 10 have PhD structural engineers, they initially seemed 11 to think this is thermal expansion, they may be right.
12 But to us, it certain, we felt, and they're required 13 to analyze this using those formal analyses.
14 Obviously the concern is you have loads 15 being applied to this wall that aren't being accounted 16 for as part of that -- that aren't being accounted 17 for, and compared against the design code.
18 CO-CHAIR HALNON: Okay, and the other 19 question I had was the relative difference between the 20 two findings. One was on mitigating systems, and one 21 on barrier integrity. I think I get the reason for 22 that now. But there was a statement based on this 23 one, that given the lack of ASR -- of the NextEra 24 staff addressing ASR, you said it was not indicative 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 of current performance.
1 Therefore it kind of decreased the ability 2
to put a cross cutting aspect on it. However, in 3
hindsight, looking back now, do you think that just in 4
general the ASR program could have been indicative of 5
maybe some ASR program performance issues?
6 MR.
NEWPORT:
That's another very 7
insightful question, we've had extensive conversations 8
internally on this very topic. So when we write these 9
findings, and violations, when was the mistake made?
10 We call this when was the performance deficiency made?
11 We determine, we have to choose a specific time, when 12 did the error happen? Like I said before, they 13 implemented the program.
14 They voluntarily adopted this program in 15 2016, and then they went down there in 2017, and they 16 saw these cracks, they knew that that deck plate had 17 spalled up previously, the bowing grate was there. So 18 they saw these signs as early as 2017, and they had 19 voluntarily adopted that program which required them 20 to do the stage two analysis. They said this is not 21 due to ASR.
22 They incorrectly used their -- procedures 23 required them to do this, they didn't use that 24 procedure correctly, they said we believe this is just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 due to thermal expansion, they did a traditional 1
evaluation, but they did not do that formal evaluation 2
back in 2017, that's when the mistake happened so to 3
speak. So that's why we use that as the time frame 4
for our performance deficiency, therefore we said it's 5
not reflective.
6 Could they have figured this out later, in 7
the ensuing years? Yes, but we have to choose one 8
time where we said the mistake happened, and we chose 9
back in 2017, when they initially saw some of these 10 indications. So does that answer your question?
11 CO-CHAIR HALNON: Yeah, I guess I just 12 wanted to make sure you still had confidence that the 13 mistake back in 2017 wasn't a missed opportunity to 14 look forward, and catch this next error that was 15 found. So it sounds like you're still standing on 16 your report.
17 MR. NEWPORT: Yeah, with the changes that 18 they've made to the program, and how they've bolstered 19 the program, and the new awareness of the importance 20 of paying very close attention to this because it's 21 changing, we currently do have confidence that they 22 are where they need to be. And again, like I said 23 before, I say currently, because this is going to need 24 continuous scrutiny throughout the plant's operating 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 life.
1 So currently we believe they're where they 2
are, but we're going to keep a close eye on the 3
program as the years go by to make sure they stay in 4
the space they need to be.
5 CO-CHAIR HALNON: Thank you Chris.
6 MEMBER KIRCHNER: Chris, this is Walt 7
Kirchner. We can't see very well the details here, 8
obviously we can see the spallation. Did you say that 9
this was an area that had been patched previously?
10 CO-CHAIR HALNON: Chris you're on mute.
11 MEMBER KIRCHNER: I think you're on mute 12 Chris.
13 MS. BRADY: They said you're on mute.
14 MR. NEWPORT: Sorry, I unmuted, but then 15 muted again. Can you hear me now?
16 MR. FLOYD: Yes.
17 MR. NEWPORT: So if you look at my right 18 knee, that spalled concrete there, that occurred in 19 2012. And I want to emphasize, this is before anyone 20 knew about building deformation. So it was not on 21 anyone's mind in 2012, that these buildings could be 22 moving. So they found this, they repaired it just 23 like a normal plant without ASR would. Chalked it up 24 to thermal cycling, or thermal expansion, because it 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 does get very hot in there, and cools down.
1 So after 2012, this was a clean slab. You 2
can kind of see up against the wall, some of the 3
repair grout there. And they went down there in 2017, 4
and it hadn't spalled back, and then they went down 5
there in 2018, and there was no spalling of the floor 6
slab. And then the next time they went down there was 7
in 2021, and then they see what you see here in the 8
picture.
9 So it spalled at some point from 10 construction until 2012, they repaired it, and then it 11 spalled again at some point between 2012, and when 12 this photo was taken. Apologies, between 2018, during 13 the last inspection, and when this photo was taken in 14 the fall of 2021. Does that answer the question?
15 MEMBER KIRCHNER: Yes. So buildings move, 16 and deform with, or without ASR. Do you have 17 something in place to measure -- there is going to be 18 continuing movement, and you suspect it is ASR, do you 19 have some ability to do periodic measurements on 20 movement, and such to have a feeling for whether this 21 is going to continue? Or, was it one time thermal 22 expansion, and cracking, or it was ASR pressure from 23 backfill?
24 Are you just going to monitor this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 visually going forward, or are you going to put some 1
-- lay some tracks so to speak, so you can measure 2
whether there's continuing building movement?
3 MR. NEWPORT: Great question. The short 4
answer is yes. The long answer is, so they absolutely 5
do monitor these things. You can see even in the 6
picture, they write on the walls, they measure the 7
crack width, so they put the date, and they indicate 8
what the crack width is. You saw in some of the 9
previous pictures, they have those crack width gauges, 10 it's case by case depending on the structure.
11 But they do extensively monitor growth of 12 the structures. In the RHR vaults for example, which 13 are long, tall, elevator shaft like structures, they 14 have these gauges that go three, or four stories tall 15 that measure vertical expansion very accurately. So 16 there's a number of different ways they track, and 17 monitor changes in these buildings from building 18 deformation.
19 They've taken some initial measurements on 20 the reactor cavity pit for measurements, and 21 monitoring. And depending on what their stage two 22 analysis comes up with, they may implement even more 23 monitoring techniques, and measurements.
So 24 absolutely, they're tracking, and monitoring these 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 things. And we do as well, I track with gauges, 1
Travis and I go down there, and we do our own 2
independent assessments too.
3 And we keep our eye on some of these 4
devices they have in the field as well.
5 MR. FLOYD: Yeah, and to add to what Chris 6
was saying, again, it's structure dependent, location 7
dependent, but the licensee does take distance 8
measurements between structures. So like seismic gap 9
widths, they also measure wall to wall distances, like 10 in the electrical cable tunnel, they were doing that 11 for a portion of time. Down here, during the last 12 refueling outage, they took laser measurements looking 13 at the distance.
14 Because this is kind of a small keyway, so 15 it's easy to measure the distance at different 16 elevations between those two walls. So I envision 17 going forward, they're probably going to continue 18 that. I know they took it last outage, it's on the 19 plans to take next outage, all of that's going into 20 their stage two evaluation. And depending on how 21 critical that is will dictate whether, or not it's 22 continued to be monitored.
23 But in several of the structures on site, 24 they are taking distance measurements looking at the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 lengths, and widths, and deltas between structures.
1 And, sorry, just to add to that, there are some walls 2
that if you suspect moving, you can do basically a 3
plumbness measurements. So if you imagine your wall 4
was straight, now it's moving, you can look at the 5
profile, that side profile of the wall.
6 So they are, for certain key structures 7
and locations, they are monitoring the movement, and 8
the length displacement of those walls.
9 MR. NEWPORT: Yeah, and just as an aside 10 as well, those are critical inputs into these finite 11 element analysis models, so they update those models 12 too when they get some of these inputs coming through 13 over the years. Great question, I hope that answers 14 the question.
15 MEMBER KIRCHNER: Yes, thank you, yes.
16 Because I was thinking that if they have the 17 measurements, you can discern whether it's the 18 building deformation movement, or expansion, versus 19 thermal effects that led to the spalling of the 20 concrete, thank you.
21 MEMBER BIER: Quick question from Vicki 22 Bier if I can follow up at this point. It looks like 23 the monitoring is quite conscientious I would say, 24 quite thorough. What confidence do we have in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 reliability of predictions after we have that 1
monitoring about whether we're getting into trouble?
2 Is that mainly based on finite element calculations, 3
or how do we decide the cut offs?
4 And are we in a situation where we could 5
be just monitoring, and monitoring, and at every step 6
convincing ourselves that well, it's not that much 7
worse than last time, so we're okay, and then finally 8
something bad happens even though we were monitoring, 9
how do we avoid that?
10 MR. NEWPORT: Yeah, great question, I'll 11 take a cut, and then turn it over to you Nik. Great 12 question, very complicated question to answer, I'll 13 take my first cut, and then Nik can chime in here.
14 Personally, I break it down into -- for what you're 15 talking about, there's two things. There's the ASR in 16 the walls, what is that doing to the structural 17 properties of the physical wall?
18 Like we briefed
- earlier, that the 19 measurements they take, the extensometers, and the CCI 20 measurements, they correlate that to that Texas 21 testing. And as long as they're in the bounds of that 22 Texas testing, what the ASR is doing in those walls 23 doesn't negatively impact those structural properties 24 such that a code would apply. The second piece of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 this though, is what about the building deformation?
1 What about the ASR in the walls causing 2
bulk deformation, or what about that back fill 3
concrete pushing up against a wall that may not even 4
have ASR in it? And that's where that methodology 5
process that we talked about comes into play, where 6
they do these increasingly complicated finite element 7
analysis modeling. So to answer your question, 8
there's two parts.
9 As long as they stay within the bounds of 10 that Texas testing with the measurements they're 11 taking, they're safe by their current license. But 12 then with the building deformation aspect of this, 13 they have to continuously look at these models, the 14 outputs of these models, and they have to continuously 15 be feeding in the changes that they're seeing in the 16 plant.
17 They set limit space on the output of 18 these models, and they monitor them depending on how 19 far -- they could do 18 month monitoring, 12 month 20 monitoring, six month monitoring depending on what the 21 models are putting out. So they're continuously 22 looking at these measurements, and as they approach 23 some of those limits, they have to either do more 24 advanced modeling.
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96 Or they have to do modifications to the 1
structures to get that margin, which we'll talk about 2
in the next slide. So that's my first cut, I'll turn 3
it over to Nik to elaborate more.
4 MEMBER PETTI: Just a quick follow up for 5
Nik, this is Dave. But the finite element models 6
implicitly have these load factors, so there's margin 7
in the calculation to account for some potential 8
uncertainties, right?
9 MR. NEWPORT: Yeah, that's a good point.
10 By their license, they bake in a margin into that load 11 that they're applying for the calculation, 12 specifically to account for that we're not taking the 13 next set of measurements for six months, or 18 months, 14 or 12 months, so that margin is very important.
15 MEMBER PETTI: Okay, thanks.
16 MEMBER KIRCHNER: Chris, this is Walt 17 Kirchner again. Who does NextEra use? Do they do 18 their finite element analysis calculations in house, 19 or are they contracting that work out? I'm presuming 20 they were using Ansys, and state of the art models 21 that are approved, and accepted by the agency?
22 MR. NEWPORT: Yeah, they're using SG&H 23 currently, and then Nik, you can elaborate, but if you 24 look at what's called the methodology document, kind 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 of an addendum to the license, addendum to the 1
structures monitoring program. It goes into pretty 2
high level -- it goes into significant detail on how 3
they need to do these models. There's a lot in there, 4
it's hundreds of pages.
5 So they use that document to then take 6
that document to guide how they do the finite element 7
analysis models. Nik, do you want to, anything I'm 8
missing here?
9 MR.
FLOYD:
- Correct, so it's the 10 contractor, the vendor that does all of the finite 11 element modeling. They don't have that ability to do 12 that in house, and they are using an Ansys based 13 software. I can't comment on the specific version of 14 the software, I know that was looked at during the 15 initial audit as part of the license amendment request 16 that developed the methodology.
17 I don't know George, or Bryce, if you can 18 comment further, because they look specifically at 19 those models. But it is, to the best of my knowledge, 20 we have multiple approved versions of Ansys by the 21 NRC. But I don't know the specific one for this 22 application.
23 MR. LEHMAN: Yeah Nik, this is Bryce, 24 unfortunately I don't know the specific one either, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 but we definitely did look at that, and I was in the 1
staff's SE related to the license amendment request.
2 MEMBER KIRCHNER: Okay, so I'm not so 3
interested in, I'm assuming it's probably a recent 4
version of Ansys. My question was more whether the 5
NRR staff, or research reviewed the code methodology 6
that was being applied. And I think the answer you're 7
giving us is yes, they conducted a confirmatory review 8
of that methodology.
9 MR. FLOYD: Yes, that's correct.
10 MEMBER KIRCHNER: Thank you.
11 MR. FLOYD: And in addition to our NRR 12 staff that audit in 2018, might have said 19, sorry, 13 2018. We brought on Brookhaven National Lab as two 14 outside contractors that assisted the NRC staff with 15 that review. So they also looked at the software, and 16 the methodology, and how the licensees perform those 17 calculations.
18 MEMBER KIRCHNER: Thank you.
19 MR. FLOYD: And then to add on Chris's 20 response to the previous question, so the licensee has 21 this whole ASR program as an ASR piece. They also 22 have the building deformation, which is a separate 23 program, the two feed in hand in hand to one another.
24 But those are all the additional programs that got 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
99 added in for monitoring at the site. The site still 1
has their normal structures monitoring program, that 2
they're going to do the walk downs of the structures.
3 So while we're looking at key areas on the 4
site, and we're looking at the threshold monitoring 5
data, we're looking at the established ASR grids, the 6
extensometer locations, I mean those aren't -- they're 7
not 100 percent around the site. They're in a sample 8
of walls, slabs, floors. But in addition to those, 9
they still do the normal walk downs around the site.
10 So as conditions were to change, they would be 11 detected during those walk downs.
12 Now, they might not have the explicit 13 data, but if you were to see additional cracking, 14 additional spalling, if for example the equipment 15 impacted from a building deformation, they're actually 16 doing measurements there, looking at deformations 17 between different pipes, and different conduits. So 18 if conditions were to continue to change, there's a 19 high likelihood it is going to be detected if it 20 wasn't already part of the other ASR enhanced 21 monitoring.
22 That's what gives us that additional 23 confidence. I don't think we'd ever be led down the 24 path that they're doing monitoring, and not finding 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 something, that's not proven to be the case.
1 MR. NEWPORT: So I have one more slide --
2 go ahead Nik.
3 MR. FLOYD: In my opinion, in my 4
professional opinion.
5 MR. NEWPORT: I do have one more slide on 6
a separate subject before we turn it over to summary.
7 So if there's any more questions on the fourth quarter 8
finding that we just talked about before I move on to 9
this slide? All right, so we also wanted to just 10 touch on what happens if they either approach the 11 limits of the building deformation.
12 The stage -- they've done all of the 13 evaluation they can do, and they're still approaching 14 the limits, or what happens if, like we briefed 15 earlier, they've gone outside of those limits, and 16 they need to restore compliance.
The NRC 17 traditionally gives you two, you either have to 18 restore compliance, or change the license.
19 If you're outside of compliance with your 20 licensing basis, those are your two options. And when 21 we talk about restoring compliance for these 22 structures, they restore compliance by doing physical 23 modifications to the structures. So for those six 24 structures that we talked about that are outside of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 licensing basis, and also some structures that they 1
believe might be approaching those limits at some 2
point in the future.
3 The licensee has elected to perform 4
physical modifications. Travis, and I were actually 5
down in the mechanical penetration area looking at 6
some of the modifications they've already started.
7 But we wanted to touch on just some examples of some 8
of the structural -- there's dozens, and dozens of 9
different way where you can buy back margin by doing 10 physical modifications like reinforced concrete walls.
11 But two of them we'll show here as an 12 example, example one, those are the strong backs. I 13 always say if you've ever been up to California, and 14 you see old brick buildings, they have to retrofit 15 them for modern seismic codes, so they'll put 16 essentially bolts through the wall that tie it 17 together, like you see in the example here. That's 18 one example of ways they can restore margin back into 19 the walls.
20 Another example, example two, this is a 21 corner brace there, I think that's kind of self-22 explanatory there, it braces the wall, and adds 23 strength that way. So like I said, there's dozens of 24 different ways that they can get this margin back.
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102 They use their contractors to find the best way for 1
that specific wall they're looking at, and then they 2
do the analysis, and they go out to -- they physically 3
perform these modifications.
4 As I said, for these buildings that are 5
out of compliance, they're required to restore 6
compliance, they've already started that process 7
through these modifications, and Travis, and I have 8
been looking at them, and we have a team coming out 9
this quarter to do a deep dive on some of these 10 modifications, the adequacy of the modifications, and 11 whether they're doing them in a timely manner.
12 So any questions on this slide before I 13 turn it over to Mel for a summary? And then we'll 14 open it up to general questions after that. All 15 right, then I think it's over to you Mel.
16 MR. GRAY: Okay, thanks. Hey, we've been 17 going at it here for a while, I hope these conclusions 18 are self-evident to you. But we have done inspections 19 to date, and we found some gaps, and indeed that got 20 your attention, and other stakeholder attention, and 21 we've talked about them in detail today. But we focus 22 on NextEra's performance to monitor, and manage, and 23 correct the effects of ASR.
24 After all is said, and done, we've had 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103 findings of very low safety significance, because the 1
structures have been found to be able to perform their 2
safety function. And that will be a continual focus 3
for our inspections, and that just leads me -- my 4
second summary item is just inspections are going to 5
continue, we will focus on NextEra's performance 6
monitoring, and corrective actions as we've said.
7 And finally, the third item is important, 8
I hope it's evident to you that the inspectors we 9
bring to bear, and the help from headquarters, it's 10 not a checklist approach, it's a very invasive 11 inspection. And the third item, just verifying that 12 those license conditions are all met, the ones 13 imposed, the ones the staff imposed, that those type 14 speed limits are inspected in detail on an ongoing 15 basis to ensure that the underlying testing and the 16 behavior of the plant are as the staff assumed in 17 approving this.
18 And so that, I envision those inspections 19 to continue on the license conditions. And with that, 20 I'll just say we found the methodology from a regional 21 perspective, we found it to be scrutable, measurable, 22 observable in the field. Yes, it might be 23 complicated, but it can be implemented.
24 And it's a standard that just has shown 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
104 itself to be, with the scrutiny it had in licensing, 1
to be a sound approach to observe, and make judgements 2
about Seabrook's performance, and the safety of the 3
plant. So thanks for that. I would turn it over to 4
the Chairman Ballinger, or Halnon, and we would go 5
from there.
6 CO-CHAIR HALNON: Thank you Mel, this is 7
Greg. I got just one big picture question. So the 8
plant was licensed to operate in 1990, so we're not in 9
the period of extended operation yet, we've got 10 another eight years, or so to go. Do you see the --
11 I mean this program as aging management, it was done, 12 or at least perceived, or conceived during the license 13 renewal aspect for the first period of extended 14 operation.
15 Do you see any need for additional 16 inspector training, or focused inspections beyond what 17 you talked about, or focused audits? As we get closer 18 to the period of extended operation, or is this 19 program up to snuff to carry us into the next 40, or 20 20 years?
21 MR.
GRAY:
- Right, great question.
22 Structurally, the oversight program provides for 23 additional team inspections as a plant approaches 24 their, what's called the period of extended operation, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 the 40 year license. We would bring to bear a team of 1
inspectors to look at their aging management programs.
2 And clearly this is an aging management program 3
credited in license renewal.
4 I think this will have significant 5
inspection effort as we approach the period of 6
extended operation, that there will be a strong record 7
of their performance. But in license renewal space, 8
we would probably verify if there's any additional 9
aspect that wasn't inspected, we would go ahead and 10 look at that at the time, but I think you bring a 11 point up.
12 It's important that the NRC, we continue 13 knowledge management of this inspection space, and the 14 licensee provides for that in their organization, and 15 we're mindful of that here, growing our own inspectors 16 at headquarters in that manner. So I guess I'm sorry, 17 Greg, I might have lost the thread there on your 18 question. I think the program provides for license 19 renewal augmented inspection as we get closer.
20 But I suspect this will have a long and 21 detailed track record. Finally, we do, in the region, 22 ask ourselves if the reactor oversight baseline is 23 sufficient to get at these insights about performance.
24 We have to date said that, and I think that's the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
106 case. We take somewhat of an expansive view about 1
what we can do under the ROP, it's intended to serve 2
the regulator, not the other way around.
3 And so we do devote significant resources 4
on these samples, and we just think it's warranted, so 5
that's what I would say.
6 CO-CHAIR HALNON: Thanks. Is the 7
deviation still open, or has that been closed down?
8 MR. GRAY: That was closed a number of 9
years ago.
10 CO-CHAIR HALNON:
- Okay, and the 11 confirmatory action letter is closed as well?
12 MR. GRAY: Correct.
13 CO-CHAIR HALNON: Okay. So the only thing 14 I would encourage is continue to try to close out this 15 prompt operability determination, operating the plant 16 to an operability determination in a non-conformance.
17 Even on the previous slide, Nik, and Chris were 18 talking about the modifications plus operability 19 determination. It's not necessarily an ideal way to 20 move through operating a nuclear plant, to be relying 21 on an operability determination all the time.
22 So I would hope that there's an end point 23 to that at some point, and that we can clear the non-24 conformance, clear the operability determination, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 just move forward with an aging management program.
1 Thank you for the presentation, and we wanted to make 2
sure we opened it up to the rest of the members, to 3
make sure there weren't any other questions, and --
4 MEMBER BROWN: I have one.
5 CO-CHAIR HALNON: Go ahead.
6 CO-CHAIR BALLINGER: Let me -- this is Ron 7
Ballinger, we have been going on this for quite a 8
while, and certainly some of us would like to have a 9
break of some kind, and we're actually on schedule.
10 I would propose that we have a break until the hour, 11 at which point we'll have the subcommittee discussion 12 where we get all these questions, I suspect that 13 they're going to be extensive. So let's take a break 14 until 11:00 o'clock.
15 (Whereupon, the above-entitled matter went 16 off the record at 10:42 a.m. and resumed at 11:00 17 a.m.)
18 CO-CHAIR BALLINGER: Okay, it's 11:00 19 o'clock. We can reconvene the meeting. This is the 20 discussion period. And what I would like to see 21 happen is, apart from the general discussion, from the 22 members I would like to hear their opinion as to how 23 we should quantify the results of this meeting, as 24 well as any suggestions or related to path forward on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
108 this area.
1 My reading of the situation is -- and this 2
is a personal opinion, of course -- is that the staff 3
and the applicant have done their due diligence and 4
have the situation under control. But there's a 5
significant event that's happening on May 9th. I 6
guess there's a visit that's happening. And then 7
there's a quarterly inspection that may be occurring, 8
that's occurring in the fall during, which time I 9
think I've heard that this extensive analysis, this I 10 guess phase 2 or whatever, will be -- will have been 11 done.
12 And so that would be a fairly significant 13 milestone in this process. But I'd like to open the 14 session, the committee meeting, to Q&A from the 15 members.
16 CO-CHAIR HALNON: Charlie, you had a 17 question, didn't you? Before we broke.
18 He may not be back yet.
19 CO-CHAIR BALLINGER: It is 11:00 o'clock.
20 CO-CHAIR HALNON: Yes.
21 CO-CHAIR BALLINGER: So he should be.
22 CO-CHAIR HALNON: So, Ron, I agree with 23 you. It feels like the inspection staff, the NRR 24 staff, with how they described the licensee's reaction 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 and corrective actions, it feels like we're back on 1
track. Because the NextEra staff, I know many of them 2
are diligent folks. They're good performers so I 3
don't have a concern there.
4 But I
do agree that there's some 5
milestones coming up that are important, and that it 6
may warrant, maybe just a Plant Ops Committee looking 7
at it later this year or early next year, to make sure 8
that the corrective actions that have been put in 9
place are continuing to take hold and protect the 10 plant.
11 I'm not sure we might have to kind of look 12 at the reports and see how they come out. We may just 13 hold that as a potential in the future. However, I 14 agree that what we've heard today sounds like 15 everyone's being very diligent and on top of this.
16 MEMBER SUNSERI: Greg and Ron, this is 17 Matt. I would concur with those positions. You know 18 I like to hang back and kind of listen to the entire, 19 the discussion in its entirety from what the staff is 20 saying, what kind of questions the members are asking, 21 what are we hearing from others.
22 And I thought today's interactions were 23 informative about the current state of the progression 24 of ASR at Seabrook. And we even probed beyond the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 central topic into other organizational performance, 1
system structure, and component performance issues.
2 It seems to me that the actions taken and 3
ongoing, are commensurate with what I would call, you 4
know, good operator and good regulator performance.
5 I mean some of the sort of the things that 6
they should be looking at, to address a very technical 7
issue like this.
8 So I really don't have any questions or 9
other comments.
10 I do think though, like you're saying in 11 light of the continuing nature of this what I would 12 call a unique issue in our industry for, you know, ASR 13 at a nuclear power plant, that we should continue to, 14 or consider establishing some kind of follow-up 15 frequency.
16 And maybe these inspections are that 17 avenue for doing that. But some kind of follow-up 18 just to kind of close the loop, or see where this 19 plateau's out.
20 That's all I have, thanks.
21 MEMBER BROWN: Greg, this is Charlie. Is 22 anybody else?
23 CO-CHAIR HALNON: Yes, go ahead, Charlie.
24 We were waiting for you to get back. Go ahead.
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111 MEMBER BROWN: Okay, yes my dog slowed me 1
down a minute, excuse me.
2 I wanted to ask a question relative to, 3
yes, I have same conclusions Matt did relative to the 4
presentation. I thought it was a very good 5
presentation, with a lot of good detail.
6 In the February inspection report, the 7
last part of that write up noted that the NRC 8
inspectors, including inspectors from the regional 9
- office, reviewed the operational, operability 10 determination, determined that there was sufficient 11 technical rigor to support that the structure remain 12 capable of performing a safety function. Okay?
13 The last part of it, the last sentence 14 said the inspectors noted that a more detailed, fine 15 item element analysis was underway in accordance with 16 the Seabrook structure's monitoring program 17 methodology document.
18 Is that more finite element analysis 19 focused on that part that was discussed with the 20 flooring, and that grating, and the wall that was 21 highlighted in those last few slides?
22 The keyway, and, or is it a more general 23 finite element analysis? And if it's more general, 24 yes, thank you, that's it.
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112 Was it focused on that are explicitly as 1
you show in the slide?
2 MR. NEWPORT: Yes, I can. Yes, so 3
basically by their program, they're required to do 4
that, that's what they call stage two analysis, which 5
is a finite element analysis.
6 They're required to do the whole 7
structure, which in this case is the containment 8
internal structure.
9 So it includes the cavity, the reactor 10 cavity pit that you see here. But it also includes 11 the, the floor of containment, and all of the other, 12 you know, all the other concrete structures inside of 13 containment.
14 So it's more than just the cavity pit, but 15 it does include the cavity pit that you see here. And 16 that's by their process.
17 Did that answer your question?
18 MEMBER BROWN: Yes, part of it. The 19 second part of my question was, I think you stated 20 that that was due to be completed in the fall of this 21 year?
22 MR. NEWPORT: So that's preliminary.
23 Yes, right now their contractor estimates 24 sometime in the fall. The structure itself is a very 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 complicated structure so it's, it take some time to do 1
this analysis.
2 So right now they're projecting for the 3
fall. Obviously like anything, there could be delays.
4 But like we said, when that valuation is complete, we 5
do plan on conducting a detailed inspection of that 6
product.
7 MEMBER BROWN: Is, relative to the gaps 8
and stuff you focused on in some of the other slides, 9
you know you showed us building-to-building gaps, and 10 things like that.
11 Is there, but you didn't mention, or I 12 missed it if you did, any specific limits that you say 13 if you get closer than this amount, then that becomes 14 unsatisfactory?
15 Or are there additional analyses could say 16 that even if they impact somewhat, it would be okay?
17 Or has that been addressed?
18 MR. NEWPORT: Do you mean for the, this 19 specific structure here, the reactor cavity pit, or 20 are you talking generically?
21 MEMBER BROWN: Yes, yes. No, I'm talking 22 about the areas where you had focused on, where you 23 found the problems right now.
24 MR. NEWPORT: Okay. Yes, so for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
114 cavity pit, there's no seismic gaps down there, it's 1
all one building. And --
2 (Simultaneous speaking.)
3 MEMBER BROWN: Oh, okay.
4 MR. NEWPORT: But based off what we saw 5
down there, there's no, you know, there's no limit.
6 So there's nothing that between now and 7
the fall that if they hit, that, you know, they say if 8
we hit this we cannot you know, operate or we're 9
unsafe.
10 There's nothing identified of that nature 11 down in this cavity pit down there, yes.
12 MEMBER BROWN: Okay, well what about the 13 backfill pressure you were talking about?
14 MR. NEWPORT: So that's what, now again, 15 that's just an assumption. That's just what we think 16 could be happening.
17 Now, their Ph.D. structural engineers, you 18 know, their initial take was they think it might be 19 thermal. So we don't know that for sure.
20 But what that stage two analysis will do 21 is it will look at the whole structure. They're going 22 to get out the original design drawings, and find out 23 exactly what is behind those walls; how much is behind 24 those walls.
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115 And they're going to do that modeling to 1
see if that backfill could be exerting pressure, and 2
it could account for what they're seeing here.
3 So until that's done, that's what the 4
product will output. And if they do determine that 5
that backfill's applying pressure, then they'll add 6
that load onto the loads that that wall is required to 7
account for, and compare it against the code.
8 Did that, Nik do you want to chime in, 9
too?
10 MR. FLOYD: No, I was going to say that 11 analysis, you know, as Chris was saying, it's not just 12 the reactor cavity pit. It will be the entire 13 containment internal structure.
14 So part of the walk-downs that the 15 licensee and their vendor did this past refueling 16 outage in the fall of 2021, they were taking 17 measurements and doing walk-downs of all the internal 18 structure.
19 And the whole idea there is that you fit 20 together the bigger picture. So we're focused on just 21 one area down below, but as you can see, that 22 foundation mat concrete is a large, it's a very large 23 section of concrete that is, it's underneath the 24 entire containment structure.
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116 So they're going to look at the whole 1
structure as the bigger picture, as part of that 2
analysis.
3 So it, we'll be able to piece together 4
everything at that moment in time. But right now yes, 5
it's, yes, we're focused on this area but we're going 6
to look at the larger structure as a whole.
7 If that helps.
8 MEMBER BROWN: Oh, yes.
9 MEMBER KIRCHNER: This is Walt Kirchner.
10 Does that include looking at the underlying 11 foundations, or that backfill concrete?
12 Is there any sampling program that's going 13 on to determine its? I mean obviously concrete of 14 that size, it's probably, that's not a reinforced 15 concrete structure underneath the base mat and 16 containment, is it? It's just backfill?
17 MR. FLOYD: Oh no, that foundation mat, 18 that kind of black and gray area?
19 MEMBER KIRCHNER: Yes.
20 MR. FLOYD: All of that's reinforced 21 concrete.
22 MEMBER KIRCHNER: It's all reinforced, 23 okay.
24 MR. FLOYD: Yes. I would say heavily 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 reinforced.
1 MEMBER KIRCHNER: Okay, and is there any 2
condition assessment of it, its current, I don't know 3
what the right word to use would be, but do you have 4
some understanding of, for example, is there a ground 5
water penetration or any other things that might 6
impact the -- its own structural integrity?
7 MR. FLOYD: There is, as along with the 8
rest of the Seabrook structures, there was a 9
waterproofing membrane installed on the underside of 10 that.
11 MEMBER KIRCHNER: Okay, right.
12 MR. FLOYD: But as we know through 13 experience, that waterproof membrane did not hold up 14 to par.
15 So there is potential, and that's also why 16 we think there's some pressure pushing on this under, 17 on this underground structure that.
18 There's a potential for groundwater to get 19 in contact with that concrete, and likely affect it.
20 But that's, that's our assumptions right now, and 21 that's why we pushed the licensee on this.
22 MEMBER KIRCHNER: Well, I ask that 23 question because it also supports your containment and 24 closure building there at Seabrook.
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118 So I'm presuming they're also NextEra will 1
also do an evaluation of the CEB, as well as the 2
containment structure?
3 Or is it, or is the requirement as per the 4
program that you've approved, just to do the 5
containment, the inner containment structure?
6 MR. FLOYD: So just one point of clarity.
7 This is just a schematic. I don't think that 8
containment foundation mat is also underneath the CEB.
9 I'm not for certain. This is not the specific design 10 drawing.
11 I know it's definitely under the inner 12 containment structure, so that was previously 13 evaluated, and the CEB was previously evaluated.
14 So the only thing getting looked at this 15 time around, will be the actual containment internal 16 structure itself, which will include the foundation.
17 Now certainly if they start seeing 18 measurements, or changes in measurements on the CEB 19 that would impact that, or vice versa, they should 20 take into consideration all of those.
21 MEMBER KIRCHNER: Have they seen any 22 settling, or movement of the CEB in terms of how it 23 sits there on that, that underlying concrete?
24 MR. NEWPORT: Yes, just to clarify Nik's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
119 point, what we have there is just a, you know, just 1
for illustration purposes only.
2 I have a structural drawing in front of 3
me. The CEB from my, we do not believe sits on that 4
mat. I'm looking at a structural drawing right now.
5 So I, that's just for illustrative 6
purposes only. CEB is, I believe, a standalone 7
structure.
8 But that being said, they have done that 9
full what they call stage three analysis of the CEB, 10 which is the most in-depth, fine element analysis they 11 do.
12 And that analysis would show any of that 13 settling. They are seeing quite a bit of movement in 14 the CEB, and that's from kind of this cumulative 15 effect of the strain.
16 There is ASR actually in that containment 17 and closure building, and that strain that that that 18 cumulatively pushes bulges and causes forces on that.
19 And that shows up in their output of their models.
20 And any kind of that settlement and other 21 things would show up, as they correlate the model to 22 the actual measurements they've taken.
23 Does that help answer the question?
24 MEMBER KIRCHNER: Yes, it does. So when 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
120 was the most recent time they did a finite element 1
analysis of the CEB?
2 MR. NEWPORT: Do you know the date, Nik?
3 It was --
4 (Simultaneous speaking.)
5 MR. FLOYD: I don't have the date. We 6
reviewed it in March of 2018, during the audit that 7
NRR and Brookhaven National Lab looked at.
8 I can try to find the date for you.
9 MEMBER KIRCHNER: Okay, so coming up now, 10 the analysis is going to mainly focus on the inner 11 containment building structure, is that correct?
12 MR. NEWPORT: The containment internal 13 structure, which is different than the containment 14 dome.
15 MEMBER KIRCHNER: Okay, no, I get that.
16 So what's your process? What do you 17 expect once NextEra and its contractor has their model 18 up and running, and they've done their analyses?
19 What are you, what's your, what are you 20 going to look for when they present the results from 21 their finite element analysis of that structure?
22 And what process are you going to use to 23 review that?
24 MR. NEWPORT: Well, I will immediately 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
121 send it to Nik and our headquarters experts, because 1
I do not have the expertise to understand finite 2
element analysis, IGS.
3 But yes, it's a very complicated analysis.
4 So we will have, you know, the regional team and the 5
headquarters team do a deep dive on it.
6 And I don't know, Nik, Bryce, or George, 7
did you want to talk about it just generically what 8
you look at when you, when you get these work 9
products?
10 I don't want to speak specifically for 11 this one because we don't know what it's going to say 12 yet, but Bryce or Nik, did you want to talk about 13 generically what, what you look at when you look 14 through these, these outputs?
15 MR. FLOYD: I'm going to punt to Bryce, 16 since him and George are the ones that do those 17 detailed reviews.
18 MR. LEHMAN: Yes, thanks.
19 I mean obviously we'll just go through the 20 analysis and make sure that their assumptions are 21 reasonable, and that they've been following the 22 methodology document.
23 And that the model that they develop is 24 actually aligning with what they are, what they are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
122 seeing in the field. And just look at it and make 1
sure that it makes sense.
2 Do you have anything else, George, to add?
3 MR. THOMAS: No.
4 MEMBER KIRCHNER: Well, yes, of course a 5
very important part of using any kind of code. My 6
area is thermohydraulics, not finite element methods 7
for structure.
8 But yes, the first part is the model, the 9
actual model and its validity in terms of representing 10 the physical structure as, and its condition.
11 But I was leading to something else. Then 12 you get the results of the analyses, and I would 13 presume what you're looking for is what margins you'd 14 have based on assumptions about the progress of ASR, 15 and so on.
16 So that you have confidence that the 17 structure has significant margin to perform its safety 18 functions.
19 MR. NEWPORT: Yes, that's right, yes. And 20 it gives you, it gives you essentially loads that you 21 can add to the other load --
22 (Simultaneous speaking.)
23 MEMBER KIRCHNER: Right.
24 MR. NEWPORT: -- to assume comparator 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
123 code, and make sure you're below the code limits. And 1
there's margins built in to the -- at least there's --
2 MEMBER KIRCHNER: Well, what I'm asking 3
you to do is to tell the public, because we have a 4
large audience today, what you're going to do with 5
this analysis, why you're doing it, and then from 6
that, you know, from those results, how you review 7
them? And then how you make a finding, essentially, 8
of you've got adequate margin to the demand.
9 MR. NEWPORT: Yes --
10 (Simultaneous speaking.)
11 MR. GRAY: Yes, let me step in here.
12 MR. NEWPORT: Okay.
13 MR. GRAY: Mel Gray, Branch Chief.
14 We would, Chris will be well attuned when 15 that's done, and we would expect that to be shared 16 with us. We would look at it internally, and develop 17 an inspection plan to look at that.
18 And the pace of our plan would be, and 19 engagement, would be a function of the confidence we 20 had in the modeling. That it represented the as-21 found, as-measured structure, as, and that it followed 22 the methodology. That it modeled correctly ASR, use 23 the correct load factors, and added future ASR.
24 And if any elements of the structure 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
124 didn't meet that, we'd have a special focus on that.
1 Why that function, why that structure can still 2
perform its safety function.
3 So if it came out that there was margin 4
throughout that structure that fully met the licensing 5
basis, we would certainly inspect that, and we would 6
have a footprint on it.
7 We would have a quicker and more in-depth 8
and detailed footprint, if there was anything that 9
gave us pause about safety.
10 That's really the overall. As to what 11 inspection it will be, we'll use the one. I would 12 think it would be if it was, if it was results that 13 were in line with the COB, we might have it in the 14 maintenance rule sample, which for the public is, is 15 in general monitoring and modeling.
16 And then if it had functionality issues, 17 we would probably take an operability sample. And if 18 there are corrective actions that we're meeting or 19 near term, we'd probably use what's called a problem 20 identification and resolution sample.
21 That might be more detail, but overall we 22 would take a look at that and, and put the footprint 23 on it, explicit that would be available for 24 stakeholder awareness.
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125 MR. FLOYD: And just to add to that.
1 Being the inspector that's going to be leading that 2
charge, you know, once they get the results of the 3
model. So I, again, I'm not the expert in finite 4
element that will be Bryce and George, and NRR, back 5
in our headquarters office.
6 They'll look at the
- modeling, the 7
appropriateness of the modeling, the appropriateness 8
of the assumptions, and the consistency with our 9
methodology.
10 On the inspection side, I'll be looking at 11 the results of the model, and primarily as you said, 12 yes, areas of low margin and those areas they're 13 targeting for threshold limits, make sure that they 14 actually have monitoring in place for those key areas.
15 And that it's now captured in the 16 structures monitoring program.
17 One of the things that we do when we go 18 back onsite to look at that monitoring, is hey, one, 19 did you capture it in your document, because that 20 ensures that you're doing the scheduling; and, then 21 two, do you actually do the inspections?
22 And once you do the inspections, are you 23 tracking that data and trending that data?
24 So I mean yes, the biggest result here 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
126 will be what is the output of the model, and then what 1
monitoring do they establish to ensure that they stay 2
consistent with that model. Those are the key things.
3 And, without seeing the results, I can't 4
tell you for sure what that's going to look like. But 5
I mean from a high level, that's -- that's what we'll 6
do.
7 MR. NEWPORT: And I will also add, too, 8
for, you know, for the members of the public 9
listening.
10 And when you look through what's called 11 the methodology document, which is this formal license 12 document that they have to follow, it's very 13 proscriptive when they're doing this modeling, that 14 they don't, you know, for example there's a whole 15 section that talks about how do you model backfill 16 concrete pressing up against the wall.
17 There's multiple pages about how you input 18 that into the model, what assumptions you have to use.
19 So it's very proscriptive on how they have to do these 20 models.
21 And that's what Bryce and George, would be 22 kind of making sure they use that process correctly.
23 Does that help answer the question?
24 MEMBER KIRCHNER: Yes, thank you. I just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
127 wanted you to go through the process, not the results 1
obviously. You don't have them yet.
2 Thank you.
3 CO-CHAIR BALLINGER: Questions, more 4
questions from the members? Or consultants?
5 What I have not heard is a recommendation 6
with respect to path forward, with, by way of for lack 7
of a better word, documenting what we've heard today, 8
and going forward.
9 MEMBER BROWN: Ron, I'll give you a 10 suggestion. I didn't bring it up wanting the rest of 11 the people to talk.
12 Based on the analyses being done, should 13 we have some path established that in the fall, or 14 when they finish these other analyses, do we want to 15 take, do we want to hear from them again as to what 16 their results were?
17 That's the only question I had left.
18 CO-CHAIR BALLINGER: That would have been, 19 and would be my recommendation based on what we've 20 heard. But I'm talking more, I was more referring to 21 the immediate future.
22 That is to say, right now we have the 23 minutes of this meeting, which will be public. Is 24 that sufficient?
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128 Or do the members think that we should do 1
something a little bit more, more than that?
2 MEMBER BROWN: My opinion is unless we 3
have something else that we want done, that the 4
minutes should be, suffice unless we have a big 5
problem that we think needs to be illuminated farther 6
now.
7 CO-CHAIR BALLINGER: Thank you.
8 MEMBER BROWN: Other members can chime in 9
on that, but that's my thoughts.
10 MEMBER KIRCHNER: Ron, this is Walt.
11 I
would like to second Charlie's 12 suggestion. I think that it would be of much interest 13 to see whenever this, these sets of finite element 14 calculations are done for the structure, for the 15 containment structure.
16 I think that's a logical point to, after 17 the NRC has completed its own audit and review, to re-18 engage on this topic.
19 CO-CHAIR BALLINGER: Yes, I think Kent has 20 got that --
21 (Simultaneous speaking.)
22 MEMBER KIRCHNER: At least from my 23 perspective --
24 CO-CHAIR BALLINGER: -- got that on his 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
129 list for sure.
1 MEMBER KIRCHNER: -- that's my opinion.
2 CO-CHAIR BALLINGER: Yes.
3 CO-CHAIR HALNON: Ron, this is Greg.
4 I think that we're touching on what I was 5
trying to get to earlier, which was a let's get 6
through the May inspection; let's get the fall 7
calculations; and, let's look at those.
8 And then make a decision if we need 9
another subcommittee meeting, or if everything played 10 out the way we thought.
11 It may be prudent to go ahead and schedule 12 a subcommittee meeting in October or November 13 timeframe, just to put it on the calendar.
14 And, then after we see the products, 15 determine whether or not we actually need to have a 16 meeting or not. But I think that we don't want to let 17 go of this just yet, until we see some of the results.
18 CO-CHAIR BALLINGER: Yes, that would be 19 my, that would be my opinion as well.
20 MEMBER BROWN:
That's what I
was 21 suggesting we do also. Thanks for clarifying it 22 better, Frank.
23 CO-CHAIR BALLINGER: Other members?
24 MEMBER PETTI: This is Dave. It seems 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
130 reasonable, that approach seems reasonable to me.
1 CO-CHAIR BALLINGER:
We're rapidly 2
approaching a majority. But we're not there yet.
3 MEMBER REMPE: If you need another voice 4
to say yes, me, too, I also agree. This is Joy.
5 CO-CHAIR BALLINGER: Okay, so there seems 6
to be a general consensus that that's an appropriate 7
path.
8 MEMBER SUNSERI: Yes, this is Matt, I'm in 9
consensus.
10 CO-CHAIR BALLINGER: Okay, all right 11 having said all that, we now need to go to public 12 comments.
13 I would remind the public that there has 14 been an invitation, a Team invitation out there, and 15 you're on it, I think.
16 If you are dialing in with a phone, I 17 think you need to do the *6 trick to get in. But if 18 you wish to make a comment, please state your name, 19 and make your comment.
20 I would remind people that we, as part of 21 our procedure, we look for comments but we don't make 22 responses. The only responses that we make are 23 through a committee letter.
24 So with that said, please, any member of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
131 the public that wants to make a comment, please unmute 1
or make your comment.
2 I see photographs coming up, or video 3
coming up from somewhere. But I don't hear anything.
4 DR. SAOUMA: This is Victor Saouma, from 5
the University of Colorado.
6 CO-CHAIR BALLINGER: Ah, thank you.
7 Please make your comment.
8 DR. SAOUMA: Yes. In the interest of 9
time, allow me to make one specific, and one 10 overarching remark.
11 I have done sufficient finite element 12 analysis in my life to say that especially when it 13 comes to ASR, one can get a linear elastic finite 14 element analysis program, especially if they don't 15 specifically validated for AR analysis to give you any 16 results you want it to give you.
17 Especially if there is no proper 18 oversight, by real independent expert both at the 19 early, intermediate, and final stages.
20 And my second remark is a bit more 21 general. Based on what I heard today, based on my 22 extensive study of Seabrook through C-10 for my 23 testimony to the ASLB, based on my 35 plus years of 24 research, 20 of which on ASR.
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132 Based on numerous peer reviewed 1
publication, material testing, fracture of concrete, 2
probabilistic risk assessment, finite element seismic 3
analysis and more, I cannot say that the NRC is making 4
a convincing argument that it is currently safe to 5
live within 10 miles of Seabrook.
6 Those are my remarks.
7 CO-CHAIR BALLINGER: Thank you, but this, 8
I see another, another video coming up.
9 CO-CHAIR HALNON: Patricia, that's to you.
10 Are you interested in making a comment?
11 MS. SKIBBEE: Oh, yes, I am. I was just 12 unmuting myself. So I have a number of comments but 13 I think you've explained that you don't respond, which 14 is fine. So let me start. And I know that another 15 member of C-10 has comments also and will be speaking 16 after me.
17 So I'm Pat Skibbee. I'm the president of 18 the board of directors of C-10 Research and Education 19 Foundation, an organization that monitors Seabrook 20 within the 10-mile emergency planning zone. So I have 21 some general comments, too.
22 As far as like, and I'm not a scientist.
23 As far as I can figure out, we still don't know where 24 we are on the curve of the activity of the ASR 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
133 situation at Seabrook.
1 I think that I read, and I hope this is 2
right, that there are methodologies to actually 3
determine where in the activity arch a specific case 4
of ASR is.
5 But I don't believe that that has been 6
done at Seabrook. Not being a scientist, I'm not sure 7
it can be.
8 But if it could be, I certainly think that 9
would be incredibly helpful to find that out. So 10 that's my first comment.
11 My second general comment is, over the 12 years of reading NRC documentation, it seems to me the 13 approach to monitoring is always phrased so that the 14 plan is always found to be degraded, but operable.
15 In other words, it's always worded that 16 the goal of the inspection is to show or prove, that 17 the plant structures are still able to perform their 18 safety functions.
19 It doesn't seem to me that that approach 20 is an objective, scientific approach. It seems that 21 the approaches, we going to check everything to make 22 sure it's still working well, but then you're 23 approaching it with almost a foregone conclusion.
24 That's a little bit stronger than reality I think.
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134 But I think it's really important to word 1
the goals of monitoring the ASR situation, in a very 2
objective way. In other words, the monitoring and 3
inspections should be to find out if the structures 4
are certainly safe. In other words, operable in a 5
safe way.
6 And I think when it's phrased that you're 7
trying to prove that there's, I don't mean you 8
personally, is trying to prove that the structures are 9
operable and safe, that's a bias, and that that's not 10 a good thing at all.
11 I want to address the idea of margins. So 12 it was talked about today several times that when you 13 approach a margin, there are many ways to create a 14 greater margin, or to get around that problem.
15 And one of the ways is through 16 recalculating the margin. I've come across this idea 17 in other NRC documentation.
18 I'm not a mathematician either and I don't 19 really understand the, if there's a given margin and 20 there's ASR damage if you will, and you're approaching 21 a margin, how can recalculation solve that?
22 I mean the other ways that were stated 23 today, said there were dozens of ways to help maintain 24 a margin.
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135 Some of those are structural, structural 1
modifications. Those I can understand. But 2
addressing the problem of a narrowing, dangerously 3
narrowing margin through mathematical recalculation, 4
that doesn't seem, that doesn't seem sound to me.
5 And again, I don't want to take too much 6
time here. I know that our other person is going to 7
talk about structural modifications, so I don't need 8
to talk about that.
9 Going back a couple of years, it was on 10 slide number 12, it seemed to strongly indicate that 11 the license extension, the 20-year license extension 12 granted to Seabrook, was granted in light of, and 13 because of, the license amendment request 14 incorporating higher standards for monitoring.
15 And that once the LAR was approved, then 16 the license extension was granted in light of that.
17 And that's not accurate. It was the other way.
18 The license extension, the 20-year license 19 extension, was granted before the LAR hearings even 20 took place.
21 So I think that's something that everybody 22 should be aware of, and many may be, maybe many of you 23 are already.
24 No, I'm not going to talk about, not going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
136 to talk about remediation.
1 I want to ask a question, and I understand 2
that you can't respond to it. But the wording 3
threshold I hadn't come across before.
4 And it was stated today that three 5
buildings are approaching, or have crossed a specific 6
threshold for the first time.
7 I don't know what that means. I think 8
maybe it means, well, I don't know what it means. So 9
maybe I'll put that in writing and someone can answer 10 what that actually means.
11 I also want to add --
12 (Simultaneous speaking.)
13 CO-CHAIR BALLINGER: This is Ron Ballinger 14 again. I'm remiss in reminding, in indicating that if 15 you have specific questions and things, please supply 16 them to Kent Howard, and he'll, there will be a 17 response.
18 MS. SKIBBEE: To Kent. Okay, thank you.
19 I will do that for sure.
20 And in closing, I just want to say I 21 should have opened this way, to say that thank you 22 all.
23 There are many people on this call. Many 24 professionals. Thank you for your time. It seems to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
137 me that everybody is really trying to be very 1
conscientious here in the oversight of Seabrook, and 2
I just want you to know that is much appreciated.
3 And it's much appreciated by C-10, by me 4
personally, and I'm sure by the hundreds of thousands 5
of people who live in our area, who don't even know 6
this meeting is going on.
7 So thank you very much.
8 MS. GRINNELL: I totally agree. I'm 9
Debbie Grinnell, I'm also with the C-10 Foundation.
10 And I would like to say first of all, that 11 we've had confidence in our energy inspectors, and we 12 appreciate the in-depth work that they're doing.
13 However, C-10 does not have a radiation on 14 ASR. And, as a result, we can only, as the NRC, you 15 can only ask, ask them to do it.
16 And there is no request in a timeframe.
17 And I think that since we've had the ASR become much 18 worse since 2009, and our NRC inspectors have worked 19 very hard to monitor and interview the NRC, time is of 20 the essence.
21 So I would like to say that after hearing 22 the presentation today, the NRC Foundation requests 23 that there be additional ACRS proprietary meetings on 24 these C-10 necessary remediation-critical structures 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
138 that are seriously out of -- I'm sorry, did anyone not 1
hear me?
2 CO-CHAIR BALLINGER: We missed the last 3
couple of words. I don't know what happened.
4 MS. GRINNELL: Oh, neither do I.
5 So what I said was the NRC inspection is 6
requesting an additional ACRS proprietary meeting on 7
all of Seabrook's necessary remediation, that's 8
necessary to do on critical structures that are 9
seriously out of design basis.
10 As NextEra is, and has been, in violation 11 of their current license, and in their renewed 12 license, and they are not completing their corrective 13 actions. They are if not at all, and their 14 assumptions are incorrect often.
15 These are serious issues when we don't 16 have a regulation, and you can't require that it's 17 done within a timeframe.
18 So we all know that Seabrook's ASR 19 concrete degradation was first NRC inspected in 2009, 20 and tested to be moderate and severe on that category 21 one building.
22 Unfortunately, that was too late to repair 23 any of this. And, since 2013, the ASR at Seabrook 24 tested for an ASTM C 1020 expansion of a mortar bar.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
139 And what we found then was it was without 1
reaching and a plate plateau. Or expansion of the 2
reactive silica.
3 Now, the problem with this is it's 13 4
years later, and the NRC still is stating consistently 5
that ASR is still operating slow to develop.
6 Well, this is not prudent, and not true at 7
all anymore. Because the structures are far worse.
8 We have more deformation; we have an 9
increase, we need to have more frequent inspections 10 and they're much worse; and, we are now at a point 11 where we need to do something about it now.
12 The NRC has not reported an NRC 13 remediable, long-term plan. Where is it? The NRC is 14 responsible for letting us know, for one thing, it was 15 the NRC Foundation that had the case that had the 16 expert who had the four new amendments done on the 17 ASR.
18 And we have not seen anything about it.
19 So the NRC requested NextEra to submit a long-term ASR 20 remediation long-term plan. And we haven't seen it.
21 Obviously, a short-term ASR remediation 22 plan is the most, to the most serious plants at 23 Seabrook.
24 The NRC really is very aware that the, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
140 that NextEra has not completed their correct actions.
1 And, as a result, without having a regulation, and 2
without having the cooperation to do the work that's 3
necessary at NextEra, a short-term plan for the 4
remediation should be done. And the public should 5
know the result of all the tests.
6 So I will pass this on to anyone else 7
who's ready to ask, or suggest any comments.
8 Thank you very much.
9 CO-CHAIR BALLINGER: Thank you.
10 Are there other members of the public that 11 would, oops, wait a minute, sorry about that.
12 Well, there was a hand up and now it's 13 gone. Oh, now it's back.
14 That's Justin Poole?
15 MR. POOLE: Yes, sorry, Charlie, this is 16 Justin Poole, I'm part of the staff and the project 17 manager.
18 I had one more thing if we're, if there's 19 no more public comment but I can wait.
20 CO-CHAIR BALLINGER: I don't see anymore.
21 Wait a minute, well, there's, Victor, you have your 22 hand up?
23 DR. SAOUMA: Yes, I do. Just to mention 24 that there are indeed, well established so-called 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
141 acceleration, accelerated expansion tests, which have 1
been performed all over the world, to make anticipated 2
prediction as to what would be the future expansion.
3 When I mentioned that in my (audio 4
interference) report, and in my testimony at the ASLB, 5
it was vehemently pushed back by NextEra and the NRC.
6 They don't want to undertake such a test.
7 Such tests exist. It's called accelerated 8
expansion test, and we can make prediction on the 9
near-and long-term future. And I don't know why they 10 do not perform those tests.
11 CO-CHAIR BALLINGER: Thank you. Okay, I'm 12 assuming that Victor's hand is going to come down.
13 Justin?
14 MR. POOLE: Thank you, Chairman.
15 I just wanted to propose real quick. You 16 guys talked before about having a follow up, or 17 potentially having a follow up meeting with the 18 subcommittee.
19 And the timeframe that you mentioned, I 20 think, at that time, was the fall timeframe. And I 21 would just like to propose that I work with Kent, you 22 know, with what that, with what ends up being the 23 proper timeframe to have that said meeting.
24 Because if the report doesn't come in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
142 until October, which could be delayed, you know, we 1
need some time to go complete our inspection, which is 2
probably going to be the fourth quarter inspection.
3 Doesn't get published till, you know, 4
probably early in the following year.
5 CO-CHAIR BALLINGER: I'm sure Kent will 6
work with you. I mean we just mentioned the fall 7
because it was mentioned in the presentation.
8 So we're fine.
9 MR. POOLE: Okay. Understood, thank you.
10 CO-CHAIR BALLINGER: Yes.
11 Okay, for the members of the public we'll 12 apply a 10-second rule, as opposed to a 5-second rule.
13 There is another person with their hand 14 up. Patricia?
15 MS. SKIBBEE: It's me again.
16 CO-CHAIR BALLINGER: Oh.
17 MS. SKIBBEE: I always thought the 5-18 second rule was when you drop a cookie on the kitchen 19 floor, that you had to pick it up --
20 (Simultaneous speaking.)
21 CO-CHAIR BALLINGER: That also applies 22 unless you own a dog.
23 MS. SKIBBEE: Oh, yes, then you don't even 24 have the 5-seconds, that's true.
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143 I just wanted to say, so for example on 1
slide 13 it says the expansion, expansion must remain 2
below the tested limits.
3 But of course the question is, and I 4
understand you're not answering questions, that it's 5
very nice to say that it must stay below the tested 6
limits. But I'm not sure the ASR understands that it 7
has this stricture that it must stay below these 8
limits.
9 And this concept has come up over and over 10 in our discussion with NRC regulations that well, 11 don't worry because, you know, we'll be sure that the 12 ASR expansion always stays within, within this certain 13 box.
14 But my comment is just, I don't think ASR 15 knows that. And that obviously makes one wonder what 16 happens in this situation, where it goes beyond the 17 limits that we are saying it must abide by.
18 And again, not a question because I know 19 you can't answer it. But just a comment.
20 CO-CHAIR BALLINGER: Thank you.
21 MS. GRINNELL: I'd like to add one more 22 comment, if I could.
23 CO-CHAIR BALLINGER: Sure.
24 MS. GRINNELL: It's Debbie Grinnell, with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
144 the C-10 Foundation. And I agree with Pat completely.
1 And I think the thing that the ACRS should know, is 2
that we have a wild -- we have a world renowned expert 3
on ASR.
4 And, as a result of having him and winning 5
the case, we were able to get four really good, 6
although not always as requested or our expert had 7
requested for, four very good license amendments.
8 Now, the other issue with this is that we 9
don't have anyone within the NRC staff, or in any 10 department, who is an expert on ASR.
11
- And, as a
- result, there are some 12 limitations that engineering can do on this. Because 13 the primary issue that we have at Seabrook is a 14 scientific one.
15 And, as a result, we need an expert on 16 ASR. And the result is this should be that the NRC 17 has not only one, but has someone reliable on ASR 18 expertise, to then recall some peers to form a group 19 to look closely at C-10. Because public safety is the 20 number one concern that we all have.
21 And as this is not happening slowly, as 22 NRC continues to say repeatedly for 14 years without 23 knowing anything about ASR, and also without having 24 anyone from ASR on the staff.
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145 Thank you very much.
1 CO-CHAIR BALLINGER: Thank you.
2 Victor has got his hand up again.
3 DR. SAOUMA: One more time. Yes, my 4
concern is that indeed the NRC has taken over all, 5
reasonably decent engineering approach to an extremely 6
complex
- problem, which would have required a 7
scientific approach. And that has been missing in the 8
overall assessment of the safety of Seabrook.
9 It is the very first time that we have 10 such a complex structure subjected to ASR, and it has 11 been handled almost as a routine engineering problem, 12 analyzed by engineer with very little if any, 13 background in ASR.
14 And when we defer to expert for instance 15 at some of the national lab, as it was evidenced 16 during the hearing, none of them had any expertise on 17 ASR. They were just assessing the validity of linear 18 elastic finite element model.
19 So I would urge everyone to make sure 20 that we take a more comprehensive assessment, on a 21 structure which plays such an important role on the 22 safety of the public.
23 For example, on slide number 23, when it 24 was assessed by NextEra, that the crack might be due 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
146 to shrinkage, how can you talk about shrinkage over 20 1
years, 20 years after the structure had been 2
completed?
3 Shrinkage manifest itself at the early 4
stage. This is clearly due to ASR, which is an 5
ongoing, time dependent expansion.
6 But for them to say that it is shrinkage 7
or even due to thermal load, where there has been so 8
many cycle of thermal load over the past 25 years, is 9
unbelievable.
10 Thank you.
11 CO-CHAIR BALLINGER: Thank you once again.
12 Okay, I think we've exhausted the public 13 comments to this point.
14 One last request, are there any other 15 comments, questions from the members, or consultants?
16 MEMBER KIRCHNER: Ron?
17 CO-CHAIR BALLINGER: Yes.
18 MEMBER KIRCHNER: This is Walt.
19 I have one question I did want to ask. I 20 think it could, if the staff would like to answer it 21 now, that would be good. But certainly I would like 22 to put it on the agenda if, when we re-engage on this 23 topic.
24 And that is to what extent have structural 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
147 modifications been made to date, or are planned, to 1
deal with some of the effects of ASR in the plant?
2 Now I'm talking actual physical. We had 3
a slide on, you know, reinforcements and other 4
techniques. But no details on what might be under way 5
at the plant.
6 Thank you.
7 MR. NEWPORT: I can answer that.
8 CO-CHAIR BALLINGER: Yes, I'm guessing 9
that in a subsequent meeting, there will be a lot of 10 information on that topic.
11
- Okay, other comments from members?
12 Members are allowed to ask questions of course, and 13 get answers.
14 MEMBER BLEY: And, Ron, somebody from NRC 15 staff wanted to respond to Walt's question.
16 CO-CHAIR BALLINGER: I don't see a, gee 17 whiz, I don't see a hand up so I'm sorry, who is it?
18 MR. NEWPORT: I can answer that briefly if 19 you can hear me.
20 CO-CHAIR BALLINGER: That's fine. Yes.
21 MR. NEWPORT: Yes, the so I think we 22 touched on this earlier, but the modifications, you 23 know, obviously we said the licensee's chosen to 24 perform a physical modifications to restore compliance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
148 of the structures, that are outside of compliance.
1 Those have been budgeted for. The plan is 2
underway, and they've already started the work on at 3
least one structure.
4 And then, like we mentioned there, we do 5
have a team coming onsite likely in May to do a 6
detailed evaluation of, of those modifications. The 7
timeliness of those modifications, and the adequacy of 8
those modifications.
9 MR. FLOYD: And I'll comment on the 10 previous modifications. There have been two previous 11 physical modifications performed on Seabrook 12 structures.
13 So the first one was the missile shield 14 blocks and the containment annulus. That was part of 15 the CEB. That was a restoration of the seismic gaps 16 that had closed up. So that was a restoration of the 17 seismic gaps.
18 And then the second one was the CEVA, 19 that's C-E-V-A, the containment enclosure ventilation 20 area. A north wall in the stairwell was modified, and 21 that involved strengthening that structure.
22 So those are two physical mods that have 23 been completed at the site. We have -- we did document 24 some of those details in past inspection reports.
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149 MS. GRINNELL: May I make one more comment?
1 CO-CHAIR BALLINGER: My computer just went 2
berserk on me and I had to re-engage. So.
3 CO-CHAIR HALNON:
There was another 4
comment.
5 MS. GRINNELL: Can I make?
6 CO-CHAIR HALNON: Go ahead.
7 MS. GRINNELL: Yes, can I make another 8
comment? The NRC needs the public to know, because of 9
the concern for the extent of every building in the 10 plant on concrete, an ASR concrete. And we need to 11 know the remediation issues that are being done, 12 requested, completed, and what the results are.
13 It is that important, which is why we 14 asked for a proprietary meeting, for the ACRS to 15 discuss this. Because it's not clear at each one of 16 these, as the corrective actions are not completed, 17 often incomplete, to be understood in time. And these 18 things need to be resolved in time.
19 Thank you very much.
20 CO-CHAIR HALNON: Ron, are you there?
21 Okay, Ron might be having computer 22 problems. This is Greg.
23 Victor, one last time and then we're going 24 to close public comments.
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150 DR. SAOUMA: Very short.
1 There cannot be any remediation for a 2
structure suffering from ASR. There's no such a thing 3
as remediation.
4 CO-CHAIR HALNON: Thank you, Victor.
5 We'll do one last call for public comment, 6
and then I'm going to close the public comment and 7
then we'll summarize the meeting.
8 Patricia?
9 Patricia, you're muted. You're welcome to 10 make your comment.
11 MS. SKIBBEE: Apologies, sorry, sorry.
12 I have to say, I'm finding it shocking 13 that physical remediation attempts are going on 14 apparently without an overall plan, whether it's 15 short-term or long-term, as Deb Grinnell mentioned.
16 That seems astonishing.
17 And apparently there is no plan, because 18 I would have to hope that if there were such a plan, 19 number one, the ACRS would have been aware of it and 20 had read it, and number two, that it would be publicly 21 available for public comment.
22 So I do find this shocking. And I'm not 23 an engineer, but I did look at those slides, those 24 little braces, and I think I have to echo without a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
151 basis of very good information, what Victor just said.
1 It doesn't seem to me that a lot of corner 2
braces are going to make a difference, when you're 3
talking about the deformation of gigantic concrete 4
structures. But we'll see.
5 But again, thank you very much for your 6
efforts. I think you're doing your best, and I think 7
there's more that could be done, and I think you will 8
do it. And, thank you.
9 CO-CHAIR HALNON: Thank you, Patricia.
10 Okay, I'm going to go ahead and close the 11 public comment period at this point. One last call 12 for any member or consultant.
13 Hearing none --
14 (Simultaneous speaking.)
15 MS. GRINNELL: You know --
16 CO-CHAIR HALNON: I'm sorry --
17 MS. GRINNELL: Well, there is one. There 18 is one very short one.
19 CO-CHAIR HALNON: I'm sorry, we closed 20 public comments. I'm sorry.
21 MS. GRINNELL: Sorry, of course.
22 CO-CHAIR HALNON: If you have additional 23 comments, you can get a hold of Kent Howard, the DFO.
24 MS. GRINNELL: Got it.
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152 CO-CHAIR HALNON: Thank you.
1 MS. GRINNELL: Thank you.
2 CO-CHAIR BALLINGER: Okay, this is Ron, 3
I'm back again. I don't know, my computer just went 4
up the imaginary axis.
5 CO-CHAIR HALNON: Okay, hey, Ron, we just 6
closed public comments.
7 CO-CHAIR BALLINGER: Okay.
8 CO-CHAIR HALNON: And we had one that 9
wanted to make another comment, but I asked her to go 10 ahead and just send it to, to Kent.
11 CO-CHAIR BALLINGER: Sure enough.
12 CO-CHAIR HALNON: So we're ready to 13 summarize and close.
14 CO-CHAIR BALLINGER: Okay, good enough.
15 Thanks again.
16 Wow. In any case, I found the meeting 17 very, very informative, and everybody was pretty well 18 prepared. And very prepared.
19 And I think we got the information that we 20 were looking for. And we have an identified path 21 forward where we can follow through on this.
22 We have considered comments from the 23 members of the public, and I'm sure they will stay 24 engaged. And I'm sure we will let people know that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
153 when we have an additional meeting on this, so you'll 1
be well informed.
2 But other than that, Greg, do you have 3
anything else you want to come through with?
4 CO-CHAIR HALNON: No, I echo it. I think 5
that the staff did a fine job explaining it to us. I 6
think the questions from the members were, were 7
pointed and well received.
8 I think the comments from the public were 9
on target, and I appreciate the professionalism of the 10 comments that came in.
11 And, you know, we'll certainly take all 12 these comments to heart and in our, formulating our 13 next meeting, we will ensure that we try to cover all 14 the bases on this. So in general, I think it was a 15 very good, informative meeting.
16 Thanks, Ron.
17 CO-CHAIR BALLINGER: Okay, before my 18 computer decides to misbehave again, I think we're all 19 set. And, my goodness, we're within about 30 seconds 20 of the schedule.
21 So thank you all very much for 22 participating and this meeting is adjourned.
23 (Whereupon, the above-entitled matter went 24 off the record at 11:59 a.m.)
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Advisory Committee on Reactor Safeguards Subcommittee Meeting Seabrook Alkali Silica Reaction (ASR)
Information Briefing Division of Operating Reactor Safety Division of Engineering and External Hazards Division of Operating Reactor Licensing U.S. NRC Region I and Office of Nuclear Reactor Regulation April 27, 2022
NRC Staff Presenters Justin Poole Project Manager Division of Operating Reactor Licensing, NRR Bryce Lehman Structural Engineer Division of Engineering and External Hazards, NRR Niklas Floyd Senior Reactor Inspector Region I Christopher Newport Senior Resident Inspector, Seabrook Region I 2
Agenda NRC Staff Presentations on:
- Alkali-Silica Reaction (ASR) Background
- NRC Approval of Approach to Address ASR
- NRC Inspection and Assessment of Seabrook ASR
- Summary 3
ASR Background
- ASR is a slow, expansive chemical reaction in hardened concrete which occurs in the presence of water, between the alkaline cement and reactive silica found in some aggregates
- The expansion can cause various material impacts
- ASR is a very slow-moving phenomenon 4
Reaction:
ASR Background 5
Micro-cracking in the aggregate Visual signs of cracking on the surface of the concrete
ASR Background
- 2009 - 2010: Degradation in Seabrook concrete exposed to groundwater identified during license renewal audit walkdowns
- Testing confirmed the presence of ASR
- Codes of record in the Seabrook current licensing basis did not account for ASR
- NextEra initiated prompt operability determination (POD) and extent-of-condition (early 2011)
- Why ASR occurred and was not identified earlier:
- Seabrook unknowingly used a slow-reactive aggregate in the concrete
- Ineffective ASTM Standards at the time of construction
- ASR development was not expected
- Inspections were not looking for ASR 6
ASR Background
- NextEra concluded that ASR-affected structures were Operable but Degraded and Non-conforming
- Regional Inspectors and HQ Experts reviewed Operability Determinations and concluded that ASR-affected structures remained capable of performing their safety functions
- 2012: NRC increased oversight to ensure structures remained functional while NextEra developed corrective actions 7
ASR Background Large-Scale Testing Program:
- 2013 - 2016: NRC conducted inspections at the test facility to ensure NRC requirements for quality test standards were met 8
ASR Background Large-Scale Testing Program Results:
- Showed no reduction in structural capacity up to the expansion levels tested, and code equations can be used up to the tested limits
- Determined through-wall expansion was best way to track ASR progression after in-plane expansion plateaus
- Data was used to develop a correlation between measured modulus-of-elasticity and through-wall expansion; used to estimate expansion until extensometer installation
- Expansion levels from the testing were added to Seabrooks CLB as expansion limits for capacity limit states 9
ASR Background Building Deformation Program:
- 2014 - 2015: NRC identified bulk structural deformation in the following Seismic Category 1 structures on site:
- Containment Enclosure Building
- Residual Heat Removal vaults
- Spent Fuel Building 10
- Bulk deformation results in additional loading and can impact equipment
- Building deformation was incorporated into NextEra's license amendment request
ASR Background Building Deformation Program:
- 3-stage analysis methodology to address ASR loads
- More detailed and accurate as stages progress from 1 to 3
- Estimates ASR loads based on field measurements
- Also accounts for future ASR progression
- Demonstrates Capacity >= Total Demand (including ASR)
- Identifies quantitative acceptance criteria (threshold monitoring parameters, limits) for each structure based on analysis; triggers corrective action when approached or exceeded
- Allows for structural modifications instead of further evaluation
- Methodology described in the LAR and incorporated into Seabrooks Structures Monitoring Program 11
ASR Background
- License Amendment Request:
- Incorporated test program expansion limits for capacity
- Detailed methodology for evaluating the effects of ASR on Seabrook Structures (incorporates ASR load/demand, acceptance criteria)
- Monitoring ensures timely corrective action
- License Renewal:
- Aging management programs (AMPs) identify and manage future effects of aging
- License renewal application supplemented to include ASR monitoring and evaluation programs as AMPs
- NRC approved and issued the license amendment and renewed license in March 2019.
- ACRS meetings and ASLB hearing 12
NRC Approval of Approach to Address ASR
- Large-Scale Testing Program
- Reasonable to use the original design equations and material properties
- Expansion behavior must remain similar to test specimens and expansion must remain below the tested limits
- Methodology for Evaluating ASR-Affected Structures
- Consistent with existing code-of-record design philosophy
- Reasonable approach for estimating ASR loads based on field data
- Monitoring Programs
- Three programs: 1) ASR monitoring, 2) Building Deformation, and
- 3) Equipment Impacted by Deformation
- Reasonable inspection methods, intervals, and acceptance criteria 13
NRC Approval of Approach to Address ASR Examples of Monitoring ASR at Seabrook:
14 Combined crack indexing (CCI) and pin-to-pin distance Seismic gap widths between buildings Crack gauges Extensometers
NRC Approval of Approach to Address ASR Original License Conditions on ASR:
a)
Assess the Seabrook expansion behavior to ensure it is behaving in the same fashion as the test program expansion b)
Corroborate, using Seabrook field data, the concrete modulus to expansion correlation used to calculate pre-instrument through-thickness expansion 15
NRC Approval of Approach to Address ASR In November 2020, ASLB added four license conditions:
c)
Conduct a volumetric expansion check for control extensometers every six months.
d)
Develop a monitoring program to ensure that rebar failure or yielding does not occur, or is detected if it has already occurred, if the structural evaluations indicate rebar stress may exceed yield.
e)
If the ASR expansion rate significantly exceeds 0.2 mm/m (0.02%)
through-thickness expansion per year, NextEra will perform an engineering evaluation focused on the continued suitability of the six-month monitoring interval.
f)
Each core extracted from Seabrook Unit 1 will be subjected to a petrographic analysis to detect internal microcracking and delamination.
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NRC Inspection and Assessment of Seabrook ASR
- Onsite oversight by resident inspectors via Plant Status (daily condition report review and plant walk downs)
- Selection of risk-informed samples including Maintenance Rule, Operability Determinations, Modifications, and focused PI&R samples
- Utilize Regional and NRR technical expertise
- Periodic discussions with Region I senior managers and formal end-of-cycle reviews
- Document inspection results in publicly available reports 17
NRC Inspection and Assessment of Seabrook ASR
- NextEra reviewed Seismic Category I structures using the Methodology Document
- 28 Total Structures
- 6 structures outside of the licensing basis
- 43 elements in discrete locations
- Continued functionality is documented in a detailed Prompt Operability Determination
- Additional monitoring (typically every 2 months)
- Long-term corrective actions via modification 18
NRC Inspection and Assessment of Seabrook ASR
- Since 2019 approval of ASR license amendment
- 8 weeks of direct, on-site inspections
- 11 total inspection samples
- 2 very low safety significant findings
- In 2021, Region I completed ROP baseline samples related to ASR activities during each quarter of the year 19
NRC Inspection and Assessment of Seabrook ASR Methodology Overview:
20 Methodology Document Structural Analysis & Evaluation Monitoring Parameters and Limits Stage 1, 2, and 3 analyses Load demand calculations Design margin for future ASR expansion Threshold limits Structures Monitoring Program Monitoring parameters and frequency Trending Action if approaching threshold limits Corrective Action Further analysis and/or monitoring Structural modification
NRC Inspection and Assessment of Seabrook ASR 2Q2021 Finding (ML21222A126):
- Green finding associated with NextEras procedure because NextEra staff did not adequately account for the future progression of ASR (i.e., a time dependent mechanism) in the prompt operability determination for several Seabrook structures
- Observation on the lack of trend data to inform the timing of long-term corrective actions 21
NRC Inspection and Assessment of Seabrook ASR 4Q2021 Finding (ML22040A204):
- Inspectors identified and documented an instance where structural monitoring measurements of the Seabrook containment internal structure were not properly evaluated in accordance with the licensees structural monitoring program.
- Potential additional loads on the containment internal structures from ASR related building deformation were not accounted for.
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NRC Inspection and Assessment of Seabrook ASR 23 N
East Wall West Wall Keyway Wall Opening Deck Grate /
Floor Slab Reactor Cavity Pit Overhead View Containment Side View
NRC Inspection and Assessment of Seabrook ASR Corrective Actions for Structures Approaching or Outside of Methodology Limits:
- Physical Modification + Operability Evaluation
- Physical modification process described in the NRC-approved methodology to evaluate and manage the effects of ASR 24 Example 1 -
Strong backs Example 2 -
Corner Braces
Summary
- NRC inspections to date have determined Seabrook structures remain capable of performing their safety functions
- NRC inspections will continue to verify NextEra performance to monitor and take corrective actions to maintain Seabrook structures
- NRC inspections will continue to verify NextEra performance to meet ASR related license conditions 25
End of Staff Presentation 26