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

Latest revision as of 01:18, 18 November 2024

Transcript of the Advisory Committee on Reactor Safeguards Fuels, Materials, and Structures and Plant Operations, Radiation Protection, and Fire Protection Joint Subcommittee - Seabrook ASR Briefing, April 27, 2022, Page 1-181
ML22136A319
Person / Time
Issue date: 04/27/2022
From:
Advisory Committee on Reactor Safeguards
To:
Howard, Kent, ACRS
References
NRC-1939
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