ML12174A017

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Draft Letter from J. Clifford, Region I to R. Nelson, NRR; Subject: Request for Technical Assistance, Seabrook Station Alkali-Silica Reaction
ML12174A017
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 06/04/2012
From: Clifford J
Division Reactor Projects I
To: Nelson R
Division of Policy and Rulemaking
References
FOIA/PA-2012-0119
Download: ML12174A017 (10)
v • d • e


Text

IS*

. "UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 Allendale Road King of Prussia, PA 19406 MEMORANDUM TO: Robert A. Nelson, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor Regulation FROM: James Clifford, Deputy Director Division of Reactor Projects

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE SEABROOK STATION ALKALI-SILICA REACTION Region I requests technical assistance from the Office of Nuclear Reactor Regulation (NRR) to evaluate the potential consequence of alkali-silica reaction (ASR) degradation of a safety related concrete structure at Seabrook Station. More specifically, based on NRR review for adequacy of a NextEra prompt operability determination (POD) and its associated open issues, NRC staff should be able to identify what additional information is needed in order to fully evaluate the impact of the degradation on the current licensing and design basis in the final operability determination for structures important-to-safety at the plant. As the primary case for review, the NextEra evaluation was for the Seabrook Control Building ("B" Electrical Tunnel and Penetration Room) in light of the recently discovered degradation mechanism. Other structures important-to-safety within the scope of the maintenance rule have also been affected by the ASR problem.. Accordingly, additional Task Interface Agreements may be necessary such as for a review of the final operability determination results for other buildings also exhibiting the ASR problem.

Background

NextEra (the licensee) analyzed concrete core samples from the interior surface of exterior walls of the Control Building as part of their assessment to support renewal of their license. In August 2010, tests undertaken as a part of the core sample analysis reported a change in material properties. The analysis reported the presence of ASR-degradation in core samples taken from chronically wet walls below grade, with reductions reported in the concrete compressive strength and modulus of elasticity from that expected. NextEra evaluated these parametric reductions to determine the impact on the design basis of the Control Building. By their process, the licensee performed an immediate and prompt operability determination (POD) and concluded, preliminarily, that the Control Building (CB) was operable but with reduced strength reserves to design capacity.

NextEra continued to evaluate the extent of this condition for five other safety related concrete buildings. The other five buildings for which concrete core samples were taken were:

Equipment Vault (housing ECCS equipment including that for Residual Heat Removal (RHR)],

RCA (Radiological Controls Area) Walkway, Emergency Feedwater Building (EFW), Emergency Diesel Generator (EDG) Building, and the Containment Enclosure Building (CEB). As of June It 17

R. Nelson 2 30, 2011 there are two open prompt operability determinations, one for the Control Building and one for the other five buildings collectively. The licensee found additional evidence of ASR in four of the five other buildings and they evaluated that information in a separate immediate and prompt operability determination using the same evaluation techniques as for the Control Building. This evaluation is also considered preliminary or open. Based on NRC internal discussions, it appears that the calculation methods and correlations that NextEra used in their prompt operability determination may not be fully appropriate in light of the ASR problem.

NextEra's planned actions are two-fold: 1) to follow their operability determination process; and,

2) to follow the guidance in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," to develop an aging management program to support the license renewal application. Possible outcomes to the PODs are: 1) restored conditions (which may not be possible); 2) resolved conditions (use "as is" by procedure change incorporated or Action Request (AR) disposition approved); or 3) current licensing basis (CLB) revised (e.g., 10 CFR 50.59 evaluation). The licensee has posted on the Certrec internal website their operability determination process for reference (EN-AA-203-1001_005, No. 1 on Certrec Document Tab List)

NextEra's proposal related to license renewal was described in a letter dated April 14, 2011, under the response to NRC request for additional information B.2.1.31-1 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11108A131). This letter describes periodic reviews for operability as information is developed to support the aging management review. At the time, the proposal included another analysis (termed "final" by NextEra) of the impact of ASR on the current licensing and design basis, including the extent of the condition, to be completed by June 2011. Since that letter and as noted above, the control building POD was kept open and a new immediate and POD were completed for the other five building core sample results. The subject NextEra letter also commits to an Engineering Evaluation to be completed in March 2012.

On June 29, 2011, the NRR Division of License Renewal issued another "Request for Additional Information" (ADAMS Accession No. ML11178A338) related to key aspects of NextEra's comprehensive plan for assessing the ASR problem for the Structures Monitoring Program including that for the Fuel Handling Building and Containment ("Followup RAI B2.1.31-1, B2.1.31-4, and B2.1.28-3). The response to this letter is due on or about August 13, 2011 and we expect it to reflect a comprehensive plan for determining operability/functionality of affected buildings along with plans for the development of aging management review and program.

With respect to Part 50 requirements, Region I reviewed the NextEra current Structures Monitoring Program and found a violation of the maintenance rule for the control building. The finding is described in detail in NRC Inspection Report 05000443/2011002 (ADAMS Accession No. ML111330689). More details related to the newly discovered ASR issue were also documented in NRC Inspection Report 05000443/2011007 (ADAMS Accession No. ML111360432) as part of a license renewal inspection. The cover letter for the latter report notes that the aging management review for the ASR issue is not complete and that there is a need for a continuing review in the Part 50 and 54 areas. The staff of Region I and NRR (Division of Engineering and Division of License Renewal) have been discussing actions since January 2011 to ensure that the Part 50 and 54 reviews are coordinated.

R. Nelson 3

1. (No. 2 on Certrec Document Library Tab List) C-S-1-10159 CALC_000, Rev. 0, 'B' Electrical Tunnel Transverse Shear Evaluation Supplement to Calculation CD-20
2. (No. 4 on Certrec Document Library Tab List) C-S-1-10150 CALC 000, Rev. 0, Effects of Reduce Modulus of Elasticity - 'B' Electrical Tunnel Exterior Walls
3. (No. 5 on Certrec Document Library Tab List) CD-20-CALC, UE Control and Diesel Generator Building Design of Material and Walls below grade for Electrical Tunnel and the Control Building (Original Design Calculation)
4. (No. 6 on Certrec Document Library Tab List) Action Request (AR) 581434 Prompt Operability Determination Reduced Concrete Properties Below Grade in 'B' Electrical Tunnel Exterior Walls.

Also, before the startup of Seabrook from a refueling outage in May 2011, on April 27, 2011, NRR Division of Engineering provided support by performing an initial review of the following dor,umqeqnt.nt - AR No. 1644074 which documents NextEra's basis for accetabilit of the -----------

reduction in modulus of elasticity in light of concrete core testing using a sotNRs reviw ad document has been Th_.Tis uploaded to the Certrec file and it is related to a design change document which accepts the .....

reduced parameters of compressive strength and modulus of elasticity for the Control Building and the Containment Enclosure Building as a potential disposition for the operability determination (No. 10 on Certrec Document Library Tab List, Enclosure Bldg and Control Bldg MSP - Design Change Packa e Description No. EC-272057, Rev. 000, Concrete Modulus of Elasticity Evaluation). o cenn rcs a usindb R OLsaf The licensee is also planning an apparent cause review for the maintenance rule violation noted above. Corrective actions include a comprehensive walkdown of all structures important-to-safety with suspected ASR condition in accordance with a revised structures monitoring program procedure that meets the latest ACI standard in the area (ACI 349.3R-02). This has been completed for the control building, containment enclosure building, and the containment but the completion dates for the other buildings is tentatively August to September 2011.

Further, the licensee plans to conduct a root cause evaluation of the ASR issue which should be completed in time for incorporation into the planned March 2012 Engineering Evaluation as noted above.

Licensee Position To date, within the limitations of their testing and analysis, NextEra determined that none of the seismic category I structures tested have been found to be outside their design basis and were, therefore, operable with extent of conditions questions needing be addressed. The Seabrook design and licensing basis to which the licensee made these determinations was documented in UFSAR Section 3.8. NextEra is willing to address the attached questions from DE; but, it is uncertain if those questions will be addressed in the final operability determination currently scheduled for September 30, 2011. NextEra will be providing a comprehensive plan on or about August 13, 2011, in response to NRC letter of June 29, 2011, as noted above.

R. Nelson 4 In light of the newly discovered ASR issue, it appears that NextEra technical personnel are developing new insights for what key aspects must be addressed in the final operability determination for any building with evidence of ASR. NextEra is considering NRC staff questions to date and has hired consultants in this area. These consultants also will be developing a new model for the Containment Enclosure Building load analysis.

Requested Actions In order for Region I to independently determine operability of the control building or any other important-to-safety structure affected by the ASR problem; and, as a primary case, we need a review for adequacy of the control building prompt operability determination and any related open issues as identified by NextEra. This information would be applied to the any A 819POtabitynal operability for the control building and any other affected important-to-safety structures. The important-to-safety structures affected by the ASR problem are within the scope of the maintenance rule and are also consistent within the scope of license renewal. More specifically we need to independently develop a comprehensive set of issues to be applied to any final operability determination as a part of our oversight of the licensee's process and any new insights gained from NextEra's technical research.

Accordingly, Region I requests that NRR evaluate the adequacy of NextEra's control building prompt operability determination and its related open issues with particular focus, but not limited to, the below listed key technical questions. The licensee has provided a set of documents as noted on the reference Certrec website above but the NRR review should not be limited to those documents. Region I will facilitate ensuring that additional documents, as needed, are on the website or, as necessary, by an onsite inspection. NRR's determination should enable the staff to confirm that there is reasonable assurance of continued operability given the concrete degradation identified due to ASR for the control building once the final operability determination are made by NextEra for this or any other important structure affected by the ASR problem.

In the course of this review, Region I requests that NRR specifically identify any concerns with the assumptions, methodologies, or calculations, etc., along with the regulatory or other basis of each concern; and, notify Region I immediately if NRR finds that any of the reviewed documents for the control building do not provide reasonable assurance of continued operability of that building. As a minimum, the response to the TIA should include an independently developed comprehensive set of issues to be addressed in the final operability determination for the Control Building in order for us to further assess the licensee's process and their new insights gained for all important-to-safety structures with evidence of ASR.

1. Do the referenced questions represent a comprehensive list of issues that need to be addressed in the final operability determination for the Control Building, given the current view of operability by NextEra as reflected in the prompt operability determination?

Discussion: The reference questions are those listed in the attachment of this document and those questions posted in the NRC RAI request for additional information [(ADAMS Accession No. MLI11178A338) dated June 29, 2011, related to key aspects of NextEra's comprehensive plan for assessing the ASR problem for the Structures Monitoring Program including that for the Fuel Handling Building and Containment (Followup RAI B2.1.31-1, B2.1.31-4, and B2.1.28-3)]. If the issues are initially considered comprehensive, please give consideration to the below additional views produced by the regional technical staff. Ifthe issues are not considered comprehensive, then identity those additional issues to be

R. Nelson 5 included with consideration to those listed below along with regulatory or other basis for the concern. An example would be the need for Poisson ratio calculations on core samples because there are assumed numbers in the UFSAR or the need for stiffness damage tests because of applicable ACI standard requires it in the current licensing basis.

~re mn~nn rnrnnmn mon~ummnn~~ mnuimn on mm nnmni.n rrnm Inn ~K flflflClflfl

..... tu.....If so, provide the jusifi.atio. and- to..hnic . fr its ig.. ifi..

-basis W.th r.. rd tot -dsgbasis of the affotetd etruoturo.

Dionution:MR No@ te~orilo Gitroth tooting ie boing ore~eformd Gn the GOROnmo oooSam QFplon and thi qw00ti@n w-as maiseo in the RAI Foqwoo' fzrF Inf1rMotio in a.m ohor

-f_9WA 02piagilly ia boing dotGIFORmind. Wo~kWWGF, thoi RoGion 1otaff boiv tht HhApo Sl PFQaramOt of tniloS1 ctSR9ngt of oonroFto FASY not Wm SzOiGficonY' MOGUFO and tho0rotfor rolo'SR4int 0na 9Oniraind 04tr-o-'ro acG thoASR PFS6@Wro load IS#tRSOnFS1111to 4111 rbar.

Ava:ilable rooccroeh int1hie oroa appoaro to be eanflisting. Tho UiAR C fo otonn S

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3. GA1100 MVWIMAO% It 8ft Of QbW"9 'My POFOMWAF WA dGM by (W&Alp 09fe U"ft j# Mff$*S *em ASR a-46-g-te-d- amn Ham wo L LoFnUMML LAIJ: VVnM ISMe UM DMg I refened hffe?

4-2. Because the original design basis assumes no ASR is present during the design life of the structure, what, if any, are the specific original design assumptions affected by the presence of ASR that are not clearly evident in the UFSAR design basis?

Discussion: For example several calculation methods such as the relationship between compressive strength and modulus of elasticity to shear capacity and shear force are used in the seismic analysis. These assumed relationships may not be valid with ASR present in the structure.

I &3. What is the appropriate ACl standard to be used for degraded concrete core sampling assessing in-situ ASR degradation for the control building (locations, numbers, frequency of sampling in the future, etc)?

Discussion: While this is an issue raised in the attachment, we need to know the regulatory or other basis for the use of either of two applicable standards or other more appropriate standard. One standard is ACI 228 used by NextEra for correlation to penetration resistance probe data and the other is ACI 214 (version 1965 is referenced in the UFSAR section 3.8.2.4). It should be further noted that a later revision of ACI 214 (ACI-214.R-03) provides for additional sampling in order to achieve a 95% confidence level. The ACI 228 appears to be met by NextEra but it requires less sampling. These standards were developed for general design and construction of concrete structures for non-nuclear applications. Technical research may be needed in order to determine their relevance for

R. Nelson 6 nuclear application in which the structures are heavily reinforced with rebar. This leads to the next set of questions.

I 64. Did NextEra-adequately perform adequate laboratory tests for core sampling, including appropriate parameters obtained along with laboratory test conditions?

Discussion:- Also, during the course of this review, please identify the need for any in situ testing of control building conditions including appropriate parameters to be obtained such as temperature and humidity along with test conditions for now and in the future. Also, provide guidance on where and how much rebar should be exposed in order to assess the effect on rebar from the ASR issue.

No tensile strenoth testina is beina performed on the concrete core samples and this question was raised in the RAI request for information in terms of how shear capacity is beina determined. However, the Reaion I staff believe that the specific parameter of tensile strength of concrete may not be sufficiently accurate and therefore relevant in a constrained structure as the ASR pressure load is transferred to the rebar. Available research in this area apcears to be conflicting. The UFSAR for containment assume concrete in reinforced systems provide no tensile strength.

A core sample with ASR does not represent the forces contained in the structure because -......- Formatted: Plain Text, Indent: Left: 0.25" for this test, in particular, elastic rebound is not considered. For split tensile tests on core samples, the frictional influences in the test itself are not accommodated. The frictional losses are further exacerbated by the standard laboratory practice ofWlacinoDvwood on Opposino faces of the tensile specimen to stop it from rolling off the test stand thus restraining axial expansion of the sample.

7. What is the impact of the alkali ailica reWioeerain With regards to the ability of the contmrol build-in to resipond to decien basis leads. includWing se-ismic events!2 isec.sion: Next..a i, plAnni;g neW modeling of the bilding loads in-uding , eism.ic. A re.iew~. ofthSeiSMic a.A.YSiS is beYond the.u..ent c.p.bilitY of the Region I technicl*:I staf.

Thic re8iew should inGlde98an'. cAasmon.'AS

..- At Of the neeAS d- to a,.alY, the fou'ndati*ons*aone vs.

the response of awhole stucture Yhen just the foundation isdegraded.

......................... sufficient to disc ve r Dr dic additional ASR damage to SUffi-OintY eharactaf.s the buildings for an in*tial Oassesment in light of the ASR problem?

5.. Diso-sseo: D-*,-,g structures onror to the ng*ot*i0ios for thiks TI A it ham b"cam*e ncreasng important for damage neaativelv impacting the te-hial ;oviow.r to have design basis of the WI s.A-.et-ef-structure?

Discussion: To date three building assessments. To date three are done for the fOBolAng buildiAge have been completed: control building, the containment, and the containment enclosure building and ara available on Site. S*nc.a.the.fcu.....o.fthi.T.A.is.thc.ntrol building that acaeusment would be sampled poigiSPOction Ana to folloW Up On thiS open i*sue. A*n opportunity may exist to a"ully ob"e..e the-int.i. These assessments being do*ne O the other seism*-were initiated as a conseauence of discoveries made preparina for a renewed license application. These discoveries should be reflected in enhancements to the proqrams required as part of the Maintenance Rule. The Reaion

R. Nelson 7 requests NRR assistance inevaluating the current acceptability of NextEra's oroarams to maintain the integritv of the safety related structures from-mid August to mid Soptember Coordination This request was discussed between Richard Conte and his staff and saanRjdr uwihisaalgwhBrMle( uring a final conference_ ........ -t CoMmot VM]: Don DLR r*Ws to be call on ...... The TIA was accepted with an agreed upon response date within 90 days from the Mduded hM?

last day of the technical reviewer's onsite review of the building initial assessments (item No. 8 above) and no later than 90 days from September 30, 2011. Region I will ensure the upcoming inspection is scheduled to end before September 301h. An additional TIA may be needed for the final operability for the control building and other buildings as they are completed. A final response would be dependent on the successful completion of the September 2011 inspection, otherwise, response dates will need to be renegotiated.

References http://ims.certrec.com (No. 2 on Certrec Document Library Tab List) C-S-1 -10159 CALC_000, Rev. 0, 'B' Electrical Tunnel Transverse Shear Evaluation Supplement to Calculation CD-20 (No. 4 on Certrec Document Library Tab List) C-S-1-10150 CALC_000, Rev. 0, Effects of Reduce Modulus of Elasticity - 'B' Electrical Tunnel Exterior Walls (No. 5 on Certrec Document Library Tab List) CD-20-CALC, UE Control and Diesel Generator Building Design of Material and Walls below grade for Electrical Tunnel and the Control Building (Original Design Calculation)

(No. 6 on Certrec Document Library Tab List) Action Request (AR) 581434 Prompt Operability Determination Reduced Concrete Properties Below Grade in 'B' Electrical Tunnel Exterior Walls.

http://portal.nrc.gov/edo/l/EB1/Shared /o2ODocuments/FormslAllltems.aspx Docket No. 50-443 CONTACT: Michael Modes, DRS (610) 337-5198

R. Nelson 8 ML111610530 SUNSI Review __ Complete DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- MModes\TIA Seabrook ASR Draft 2.docx Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this docunent. indicate inthe concurrence boxC = Copy without attach/encl; "E"

  • , with attach/enc 'N' = No copy OFFICE RI IDRS RI DRS RI IDRP R I DRS RI DRP D

NAME MModes RConte ABurritt PWilson DRoberts DATE 06/ /11 06/ /11 06/ /11 06/ /11 06/ /11

R. Nelson 9 Admahmant w r-W-T-WA-ZF-f:V.F Irr.M-%'VMrrM Nor=

(4-24-444

1. An important effet ofrducini elmasticmodulus (EcS) of conRGete due- to ARR Wsa reducwtion in Stifthee (aXdal, floxural, shear) of the affected areas relative to tho Atiffness of the u naffect*d* -ra-s. Thiaoeuld roult UKOR-Feditr-iutn in Of ifor ;, globl Int 89 respo*.s -ofthe st-ruure-under design loAds d'ueS to changA-e n .thO ,,.,.*at'O ,Iff of tho affootad and unmaffacted arear from that considered inthe original global OtRucturalI anAlycSG of the Creg using the SAG computer oode. FRtho, Sinco the ASIR degradation iinthe%lower areas of the CES, the reduction i Wnt*latc madulu-Icoualdi affect the boundary cond-itions assummed inthe original analysis at the junctin of tho-bMasMAt And the C r, .al. INo.te that R QAR Se- -e R 3. .4.4.a states, iR p rt, that , foro.

,Latra a*F transfen'od to tha faundation matS prrnari~y by the action of Shaar imI/&,-coma Ioad is awso transferred by meanmaof fio~a! ~aaction of the wag,~ a#l f whioh ame rigidy attaehed o the met" Also ref8Frto pageS 11 and 12 of CaiculationCG 1 10150. The AR16440714 Evaluatioen does net address the effect of the roducod. Modulus on the global response of the stmructur. it assumes that the force anRd amoments- inthe diffeBrnt elemenAts of the structure under dcsign loads rem~ains the same and only evaluates the loca! sections (cocrt stresses, strains and flaw ra! capacty) fr the reduc* a.d- mod.uluis, whiGh ar

-balsed-en fercas and moments fromA the original Structural analysis.

2.The AR1011407.4 Evaluation does not avaluata the effect Of the Fedcd mouusohe shear capacity of the affected area

3. The AR 10110714 Evelu -.9en doest not address the effect of the reducad mad, dm on the poWtental changes in the natural freqquenies of the CEa sUtructre, whicrh ca, .d have e-ffect the-reSPOnse of the s#Utructu to so-ig miclad.
4. Th R6101Eauaino telcl oto does nat mosaluate the effect of Faducad moedulus on strese and stmrai int-he rebhar. The strain *Athe re9bar could go beyond the yield Stin. Rm page 17 of Cale CE 4 rejFernced in the.. aluatio,n for elment 266, the stres inth oprfercamoant is 6141)3 kai, which is already beyond y~ied.

56.The AR 1611071 Evaluatian of the local' section is based on clement 266, whiceh is 27" th~ick anAd appear to be outside the area affeoted by ASR. The areas affected by ASR a~pparF to -be

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. f the

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.. ..230" ick. A. .. c#itical

. .... AlamonAt

.. . in t~ho affeted area neeadg to be evalu ated. Furither, note that theb fomrce and moments in element 255 cou ld inr asebsd on Comment 1 above, and thereby further affect concree and POWbarHA- stse ad-strWais in element 266.

6. The AR 1A-4 074 Evaluation does not eXplicitiy eyealuate the effect of the reduced modulu on-aa the fitexural capaoitv of affected local sections. but makes refornece to Calc

I R. Nelson 10 C S 411040o porformed for. the ois e tric.-aI tu As-nno.

The *,f*ft on feA AI

_m-c Gapa city of th affeoted Sectin of the GEB3 should be *1expicty evaluated SinAG the 6ff99t Of the redud modu-u-s on mo-'ment capac-ty of a ectoRn !isa function atf th Amou-nt of reinfofracmnt in the setothe Section d-imOnsionS AnAd Amatial properties.- The G-6B wall reinforcamont, dimonsiens anRd mate-rial propeties appear SiOrnAntydfeetfo that of the eletrcal tunnel.

7. On page_2 of the AR.1644074 Evalu:'-tion, it is stated that "The redatian in Ec canses the AnoAm' axis of the balanced cencret and reinforcing steel section to shift towrard the tenS 9-AFionr~fGrcing steel." it appears that the redu ctonA in E: MoulId tend to causma the Aneut#axe to*shif toeard thS toXt-e Gc.' mprcF ai.sn fibe r that the t nsion reinfi FA ;Ang Per Geoge T:hom~aS telecon of June 9, 2-010 4.0th R.Conte.

.To have any le.el. f statistical validity, the number of ..ares usd in On e.haluation houli bea.tlat.^ Tho AR^A44074. G. aluatian ueas results based en only 2 Area teats of the A.SR af.eted ara..

9. What nar the strain limse'.s at the rsepoted 40alucs -ofeme-c.Fete Geomprces-ve stengt and elasttic maduluhu from cere tests rseprted in Table I of AR46440742 Doees patrographic G~aminatiOn Of the careS indicate ASIR through the thic.'tnees of the wafll.
10. The A.14644074 esaluatfion sthou ld include a prebiem statement desciption of the caend-ifien being evaluated and ft~proliminar; e~ton (at leaist bacad on vi~A' ;Uinpci) fo-r the s-tructure iRguc-t-ionAse tha-t Aanoutside reviwercan und-- an

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