ML17100B013

C-10 Foundation Petition for Leave to Intervene

ML17100B013
Person / Time
Site:	Seabrook
Issue date:	04/10/2017
From:	Treat N H C-10 Research & Education Foundation
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-443-LA-2, RAS 52766
Download: ML17100B013 (17)

Text

April 10, 2017 Via electronic submission UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of: NextEra Energy Seabrook Station Unit 1 - License Amendment Request 16-03 dated August 1, 2016 Docket No. 50-443: NextEra Energy Seabrook LLC, Seabrook Station, Unit No. 1, Rockingham County, New Hampshire C-10 Research and Education Foundation, Inc. Petition for leave to intervene: Nuclear Regulatory Commission Docket No. 50-443 I. Introduction For reasons stated herein, the C-10 Research and Education Foundation, Inc. (C-10 Foundation or C-10) respectfully requests a public hearing and submits this petition for leave to intervene in the Nuclear Regulatory Commission (NRC) Docket # 50-443, relative to NextEra Energy Seabrook LLC(NextEra) License Amendment Request (LAR) 16-03. The C-10 Foundation is a non-profit 501 (c)(3) membership organization whose mission is to protect public health and the environment surrounding the Seabrook Station nuclear power plant in Seabrook, New Hampshire. Our vision is a clean, safe, sustainable energy future. Named for the citizens within the ten-mile radius of the plant designated as the -1measure real-time radiological emissions from the plant, under contract with the Massachusetts Department of Public Healths Bureau of Environmental Health. The C-10 Foundation has over twenty years of monitoring data and technical knowledge of plant safety and security issues. We are an informational resource for the public, partner organizations and the scientific community. Our office is located within the EPZ of Seabrook Station nuclear power plant; our board of directors and most of our members reside in the communities adjacent to the plant. The safety of operations at the plant, the release of radiological emissions by air and water on an ongoing basis as well the prevention of a catastrophic event are all germane to the health, well-being, livelihoods and property of the people we represent: the citizens within a ten-mile radius of Seabrook Station. Should the NRC accept the License Amendment Request submitted in this proceeding, the C-10 Foundation believes that could put the public at serious risk by allowing NextEra to continue to operate Seabrook Stations nuclear reactor with no way to adequately remedy the plants deteriorating concrete. II. Summary of Contentions of the C-10 Foundation in requesting a hearing and leave to intervene The C-10 Foundation submits the following contentions for litigation by the Nuclear Regulatory Commission of the License Amendment Request (LAR 16-03) {Seabrook Station License Amendment Request 16-03: Revise Current Licensing Basis to Adopt a Methodology for the Analysis of Seismic Category 1 Structures with Concrete Affected by Alkali-Silica Reaction}, August 1, 2016, 10 CFR 50.90, Docket No. 50-443, SBK-L-16071. C-years, including submitting formal comments on the subject license amendment request on March 9, 2017. Based on information made available to us, we do not believe that the C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 2 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 proposed approval of the license amendment request sufficiently addresses or resolve our concerns; hence our need to contest the amendment, request a hearing and seek status as an intervening party. These contentions are intended to demonstrate that the LAR and therefore the Current Licensing Basis (CLB) are inadequate to the stated Nuclear Regulatory primary mission of protection of public health and safety, because they do not provide for the accurate assessment of the current, actual, physical condition of the concrete structural components of Seabrook Station. By logical extension, the LAR further does not provide for the accurate assessment of Alkali-Silica Reaction (ASR) on the plant structures going forwardof 2030, and through the 20 additional years from 2030-period. Our contentions are as follows: A. Visual inspection, crack width indexing, and extensometer deployment are not sufficient tools for determining the presence and extent of ASR in safety-related structures at Seabrook Station. A misinterpretation of data resulting from these tests could cause a serious underestimation of the current extent of degradation due to ASR. - effect. Any mitigation of lost structural capacity due to reinforcement is temporary and unpredictable, because of the non-linear progression of ASR. False assumptions concerning the strength of concrete at Seabrook Station made as a result of this misapprehension could result in potentially disastrous consequences for the safety of surrounding communities. in-situ concrete, must be integral to NRCs determination of the advance of ASR. testing is based on false assumptions, and could endanger the public health and safety. D. The Large-Scale Test Program, undertaken for NextEra at the Ferguson Structural Engineering Laboratory (FSEL), e progression of ASR at Seabrook Station, and therefore cannot be substituted for the required comprehensive petrographic analysis of in-situ concrete at the Seabrook reactornow -concrete could lead to disastrous consequences, and should not be allowed. within the nearby com In addition, this lack of transparency hinders the awareness of and associated management of this concrete degradation mechanism at other nuclear power plants in the United States. NextErato withhold this data harms the interests of the communities around Seabrook as well as the wider interests of citizens concerned with safety protocols in the nuclear industry. C-10 anticipates that the proceeding initiated by our filing will result in this data seeing the light of day for the benefit of many. F. Assumptions made by NextEra and MPR Associates, Inc. (MPR) concerning the continued robustness of reinforcing steel at the Seabrook reactor are at odds with clear evidence of the in-situ chemistry necessary for corrosion. Only direct testing will ensure that corrosion does not further degrade the strength of already impaired concrete. Reliance on spurious assumptions of robustness could cause a significant over-thereby le-related structures. G. While there is acknowledgement of the progressive nature of ASR, to our knowledge, there has been no testing, nor proposed future testing, to the point of failure/limit stateof either manufactured test concrete samples (FSEL) nor of in-situ concrete from Seabrook Station itself. Seabrook Nuclear Power Plant in a timely mannerbecause these intervals are too long, and too rigid. I. Completely omitted from the LAR is any accounting for the change in impact of ASR on the portions of the plant exposed to, or affected by, increasingly severe coastal storms and predicted sea level rise.

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 3 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 J. The language used in LAR 16-03 is inappropriate for a document written for the purpose of demonstrating objectivity in the testingand the conclusions of that testingby MPR / FSEL, on its manufactured concrete specimens. III. Discussion A. Visual inspection, crack width indexing, and extensometer deployment are not sufficient tools for determining the presence and extent of Alkali-Silica Reaction (ASR) in safety-related structures at Seabrook Station. crack indexing, and extensometer deployment in order to gauge the progression of ASR. spaced pattern cracking and some regions of widely-spaced pattern cracks indicative of lower levels of ASR based on available field inspections and crack indexing measurements. A confirmatory visual walk-down inspection of the building exterior wall will be performed to further characterize the extent of (Seabrook Station, License Amendment Request 16-Evaluation of t-Straining Loads and Deformations for Containment Continued reliance on visual inspection and crack width indexing as gauges of the extent of ASR is neither appropriate nor reliable, especially with regard to safety-related structures at Seabrook Station. Since 2010, NRC has acknowledged that the Seabrook complex is affected by ASR. Because it is known that ASR can be present within the matrix of a given structure and yet not be visible, the only safe course for determining the presence and extent of ASR is to test the in-situ concrete. The shortcomings of visual inspection are reviewed in a 2013 report from the Union of Concerned Scientists (UCS): ture is not a reliable way to understand the extent of damage within the concrete. This is especially true in concrete with internal reinforcing bars, which constrain crack widths but do not limit t(David Wright, Ph.D., Co-Director Global Security Program, UCS; Paul Brown, Ph.D., retired Professor of Ceramic Science and Engineering, Pennsylvania State University: -Silica Reaction on Concrete Structures and Attachments. vertical sides of a 20-inch by 20-inch square on the ASR--scale test programs have shown that crack index provides a reasonable and conservative approximation of true engineering strain for reinforced concrete members - Here we have a case of a potentially dangerous false assumption based on a skewed reading of test data. The misapprehension of data is addressed within the following contention (B.) regarding ASR-induced expansion. On the profile: asure of an expansive reaction in a structure restrained by reinforcement. Because of the restraint, an index that instead reflects the total lengths of cracks on a given cross sectional plane is expected to be a more reliable indicator of the extent of A (P. Brown, Ph.D., Commentary on SBK-L--Silica Reaction o2013.)

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 4 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 -place concrete being promoted on behalf of Seabrook is one that involves using crack displacement as an indicator of the severity of the ASR. This would be sensible in a non-reinforced or lightly reinforced structure. However, its validity for a heavily reinforced structure is questionable. One should really give consideration to the mechanisms of damage depending on the nature of the reinforcement. In a structure that is truly reinforced in 3 dimensions, ASR under such constraint will manifest by creating networks of microcracks. Consequently, although crack widths will be narrow, the concrete will tur[Italics added.] In fact, tests conducted for NextEra at FSEL revealed a relatively high-reliance on crack index data: -Austin FSEL staff have observed in the large-scale test specimens the X- and Y-direction deep pin expansion measurements (comparable to the Seabrook vertical and horizontal wall surface CCI measurements) do not appear to correlate with the through-wall (e.g., out-of-plane, or Z-direction) deep pin expansion measurements after the initial phase of ASR expansion. X- and Y-direction expansion appears to plateau while the Z-direction expansion continues to trend upward (increase). All large-scale reinforcement anchorage and shear specimens have demonstrated this expansion trend. The Z-direction expansion in the test specimens has been observed to be 10 times greater than the X- and Y- expansions after approximately one year. The preliminary implication of these test specimen expansion measurement trends is that the X- and Y- expansion measurement methods (CCI and crack width) currently used for monitoring the progression of ASR on Seabrook Station structure surfaces (per the Structures Monitoring Program) may not provide alone, an adequate means to monitor (1) ASR progression and (2) by inference (pending the completion of the testing program), the ASR impact on the affected The validation of the use of the CCI and crack width measurements for monitoring the structural impact of ASR has been an objective of the large specimen testing progr (NRC Integrated Inspection Report 05000443/2014002, 5/16/14) Finally, extensometers are another valuable tool being used to make determinations about the interior changes to concrete structures that they are not designed to accomplish: reliable measurements for monitoring through-(LAR, Enclosure 7, 3.2.1) can only provide information as to the overall dimensional change; they cannot determine the specific locations of expansion. Consequently, very localized and intensely damaging expansion could occur in planes parallel to the planes of the walls which would not result in a significant through-wall dimensional - We have known for seven years that the concrete at Seabrook Station is under attack from ASR. Visual inspections may not reveal the presence of ASR in a given area, because it may not show on the surface. Cracking index can give a false indication of the rate of ASR advancement, since concrete restrained by reinforcement will cause microcracks of greater number, without restricting the length of cracks. Extensometers can completely miss localized damage propagating in-plane from ASR. While each of these is a legitimate tool that can, and should, be used to analyze the advancement of ASR, only sample testing of in-situ concrete can accurately gauge the extent of ASR within a given concrete matrix. Reliance on these methods, without the necessary accompanying in-situ testing, is not sufficient. B. Expansion occurring within a reinforced concrete structure due to Alkali-Silica Reaction is not equivalent to a pre-stressing effect. Any mitigation of lost structural capacity, due to reinforcement, is temporary and unpredictable. Among the justifications for the LAR, NextEra relies heavily on a concept that is, from C-10s perspective, based on a flawed understanding of the forces that ASR has imposed:

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 5 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 equivalent compressive force develops in the concrete that is comparable to prestressi (LAR Enclosure 2, MPR-Station: Impact of Alkali- ial properties of concrete (compressive strength, elastic modulus, tensile strength). The property most notably affected is the elastic modulus (Reference 4). However, the change in material properties does not necessarily result in a corresponding decrease in capacity of a reinforced concrete structure. ASR-induced expansion in reinforced concrete has a pre-stressing effect that mitigates the loss of structural capacity that would be assumed NextEra seems to equate the smaller crack dimensions notstructural capacityand a potentially dangerous interpretation of the forces therein at work. Dr. Brown declares: ASR gel is not a compound of fixed composition. It has a variable monovalent cation-to-calcium ratio and a compositionally dependent viscosity. A high ratio produces a gel which is fluid and will accommodate to the pores and voids. As this ratio decreases the gel becomes sufficiently viscous that osmotic effects can place stress on the surrounding concrete. A local source of restraint can, for some period of time, minimize dimensional instability and cracking. However, restraint does not stop the progress of the reaction. The course of ASR in restrained samples is known to initially cause pore filling, resulting in densification, which will for some period of time counteract the loss of structural capacity. This has been observed in other expansive forms of concrete deterioration, such as a sulfate attack. However, eventually cracking does occur with an abrupt loss of mechLicense Amendment Request 16--4, 9/30/16) With regard to the actual change of properties for ASR-affected reinforced concrete, Dr. Brown notes: observed for deleterious expansive reactions in concrete. In areas where restraint of concrete by reinforcement is absent, microcracks that are present grow and macroscopic cracking is observed. In areas where there is restraint by reinforcement, the processes that lead to crack widening are inhibited. However, there is no evidence to indicate that cracking per se is inhibited by restraint of the concrete. Rather, concrete responds to expansive ASR reaction in concrete under restraint by producing higher densities of microcracks, which reduces the strength of the cASR-induced expansion in areas of constraint can be regarded as causing softening of the concrete because of a tendency to produce high density networks (P. Impact of Alkali- The danger in misconstruing the effects of ASR, acting within the restraint imposed by reinforcing steel, is that serious degradation that may go unnoticed without employing thorough petrographic analysis. This is less true in a tensile or shear mode. However, a degradation mechanism, such as ASR, that leads to cracking has an autocatalytic aspect to it. In other words, the worse it gets, the worse it gets. This is because the cracks serve as high conductivity paths for the movement of water and aggres(P. Brown, Ph.D., commentary on Advisory Committee on Reactor Safety [ACRS] Transcript ML122070401, p6, 9/15/12) The notion put forward by NextEra that ASR-increases in strength reflects a false understanding of the forces at work. Concrete may well show a temporary increase in certain measures of strength, but irrevocably will advance toward failure. Because the course of ASR is non-linear in this way, the aspect of the latter stage of ASR-induced deterioration makes this not only an inaccurate pbut a dangerous conclusion.

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 6 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 C. Thorough petrographic ana-situ concrete, must be integral to contained within their walls, petrographic analysis of concrete from the Containment structures and the Spent Fuel especially for safety-related structuresis based on spurious assumptions, leaves inspectors and the surrounding communities with an unnecessarily incomplete picture of the actual state of concrete degradation, and could endanger the public health and safety. C-10s understanding based on public documents is that core samples were extracted from Seabrook Station structures seven years ago. An incomplete battery of tests was performed on the samples; many of those from safety-related structures showed significant reductions in compressive strength. NRC engineering staff, in testimony before the Advisory Committee on Reactor Safety (ACRS), revealed a 22% reduction in compressive strength, when the concrete should have actually strengthened by 20% during that time period. (Abdul Sheikh, Senior Structural Engineer for the Office of Nuclear Regulation, testimony before the Plant License Review Subcommittee, ACRS, July 2012. Dr. Brown discusses the omitted tests for tensile strength: microcracking. Using the expansive reaction associated with sulfate attack as an analog, a study carried out by the Bureau of Reclamation determined that sulfate-attacked concrete did not show a meaningful reduction in compressive strength, but did show a 95% reduction in tensile strength. Yet despite the importance of tensile strength, while multiple cores were extracted for analysis at Seabrook, no splitting ts carried -Silica Reaction on Concrete Structures and Since that time, and perhaps due to the public outcry over the 22% loss in compressive strength reported for certain safety-related areas, NextEra has avoided core sampling for the purpose of petrographic analysis. They have developed a rationale for not testing the in-situ concrete, which involves properties of the concrete changing when it is no longer -reinforced structure: confining loads) the behavior of the cores no longer (Seabrook Station Updated Final Safety Analysis Report, Revision 16, Section 3.8, p147) The concrete prestressing effect is only present when the concrete is confined. The concrete prestressing effect is lost when the concrete is taken out of the stress field (e.g., core removal from a wall). A core taken from a confined ASR-affected structure will lose its confinement and no longer represents the context of the structure. Measured mechanical properties from a core taken from a confined ASR-affected structure have limited applicability to the in situ performance and only represen-Silica Reaction on atory Action Letter, SBK-L-12106, NextEra, 5/24/12) Dr. Brown has made numerous comments on the veracity of this claim: the concrete have changed, beyond those recognized in ASTM Standards C39 and C42, merely because it has been C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 7 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 regarded as the equivalent -L-16071, Enclosure 2, MPR-Station: Impact of Alkali-range for prestressing steel is 1725-1860 MPa while that of rebar is no greater than 690 MPa. This is far from equivalence. A logical extension of this argument suggests that the properties of the concrete per se (P. Brown, Ph--4, 9/30/16) environment associated with that structure. This in no way invalidates the result of the testing. The results of core testing are generally understood within the relevant engineering community. The NextEra preposition misuses the cautionary language of ASTM C42 and appears to be an attempt to avoid accumulating data which might be regarded as 11/4/13) Furthermore, as explained earlier (pp4-mitigating the deleterious impact of the ASR attack on concreteis in fact a temporary reprieve from the unpredictable and irreversible march toward structural failure. Although NextEra seems to make an effort to avoid and even discredit the well-understood methods of core sampling in reinforced structures, the scientific consensus remains that thorough petrography must include core sampling and testing. The testing and analysis protocols for core sampling, as a part of petrographic analysis, are delineated by groups -11. tensile tests on cores are routinely done. It is not expensive or exotic to do. It seems to me that this should be done on an ongoing basis as an aspect (P. Brown, Ph.D., Commentary on ACRS transcript ML122070401, p4, 9/15/12) should be extracted from the affected concrete and compared with cores taken from unaffected concrete in the same key element of the work carried out by NextEra has been to attempt to discredit compressive testing of core samples that was carried out relatively shortly after ASR had been reported. However, models for predicting the path of ASR in reinforced structures Mechanical Degradation of Reinforced Concrete Affected by Alkali-The Journal of Engineering Mechanics (Vol. 134, 2008), which specifically cites the need to carry out compressive [core] testing if the response of reinforced concrete to ASR is to be predicted. While a variety of models have been developed to predict the mechanical consequences of ASR, none have been referenced in this LAR. This is an important limitation The above-cited model is particularly relevant because it specifically addresses reinforced [italics and bold-face original.] Request 16- The burden of proof for safety is greatest where the risk of environmental and human consequence is greatest. The Seabrook reactor complex presents just such risk of consequence, due to the use and storage of highly radioactive substances, all of which are carcinogenic, mutagenic, or teratogenicsome of which are all three together. These substances can be found, always, inside the concrete walls of the containment structures and the spent fuel pool, by virtue of their being used and stored there. Because thorough petrography requires core sampling and comprehensive testingand because the aforementioned structures have such risk associated with their functionsNextEra must subject these structures to core testing and C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 8 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 thorough petrographic analysis, in order to carry on their business in a way that protects the health and safety of surrounding communities. But to our knowledge, they are not doing so; and NRC heretofore has chosen not to require such testing. Since core sampling at Seabrook Station in 2010 revealed the significant degradation in the strength of tested structures described earlier (p7), NextEra has avoided further use of this essential tool for petrographic analysis. Instead, they have -attacked concrete in its c-attacked concrete in relation to prestressing, is completely refuted by known science. The discernable benefit from ASR expansion in confinement is temporary, because the micro-cracking under way during this phase of deterioration leads to an autocatalytic collapse of Core data are always analyzed in Furthermore, existing models that have been devised to predict the advancement of ASR for concrete in confinement have not been referenced in the LAR. NextEra simply seems -situ structures, NextEra has no real basis by which it can reassure the surrounding fprogression is truly understood. D. The Large-Scale Test Program, undertaken for NextEra at the Ferguson Structural Engineering Laboratory (FSEL), substituted for the required comprehensive petrographic analysis of in-situ concrete at the Seabrook reactornow many years overdue. When the results of the first core testing were revealed in 2012, the public alarm generated was understandable: NRC -related structures. Since those revelations, NextEra has assiduously avoided the necessary petrographic analysis of their reactor that exists in the literature on structural testing of ASR-affected concrete specimens. However, the application of the conclusions from the literature to structures at Seabrook Station can be challenged by lack of representativeness. As a result, for selected structural limit states, NextEra commissioned MPR/FSEL to perform large-scale structural testing cs added.] (MPR--Silica Re4.1, July 2016) MPR reiterates the claim debunked earlier (section B. p5-7) that concrete containing the proper reinforcement advance the mild-seeming notion nt limits ASR expansion of the in-situ structure, which reduces the extent of deleterious cracking and the resultant decrease in equivalent comindicates that the prestressing effect of ASR creates a stiffer structural component with a higher ultimate strength than (Ibid, 4.2) ve of the structural C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 9 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 characteristics of safety- (Ibid, 4.3) comes something much more ominous. advancement of ASR at their working atomic reactor, without having to properly and fully test the actual concrete at the plant! It is surprising that a firm (MPR) with the engineering expertise necessary to carry out the level of testing undertaken at FSEL, would knowingly contradict decades of accumulated wisdom concerning the behavior of ASR-attacked concrete, in order to create a data stream that in all likelihood misrepresents the progression of ASR degradation at a nuclear power facility. In fact, they do make clear their own disclaimer: -year large-scale test program to support evaluation of ASR-affected reinforced concrete structures is unique in the industry in purpose, scale and methodology. Application of the results of the FSEL test program requires that the test specimens be representative of reinforced concrete at Seabrook Station and that expansion behavior of (MPR-4273, Seabrook Station Implications of Large-Scale Test Program Results on Reinforced Concrete Affected by Alkali- Following this, MPR explicitly calls for testing of Seab-situ concrete, as one of several specific recommendations that must be followed to validate the FSEL findingsalthough their recommendation for core -thickness expansion for mid-plane we believe is needed, in fact, is the full range of petrographic testing, because only then do we know that the testing done in Texas has any relevance to Seabrook. -standard tests may have merit, they are incomplete. In his opinion, NextEra must also systematically evaluate the concrete via petrography and physical testing of cores, and evaluate the expansive capacity of ASR based on ASTM standard tests as promulgated by ASTM Committee C- According to Brown, degradation due to ASR is not a linear phenomenon, as there is some period during which the iencing ASR. But as the available local pore volumes become filled, cracking initiates. Crack formation and growth are not linear with time. In concrete restrained by reinforcement, mechanical testing of extracted concrete cores to establish compressive (David Wright, Ph.D., UCS, Letter to William M. Dean, Regional Administrator Region 1, NRC, p2-3, 9/13/12) stated goal has little grounding in engineering scienceunderstandable for a seemingly impossible mission: -term evaluations, MPR conducted large-scale test programs at [FSEL] using specimens that were designed and fabricated to represent reinforced concrete at Seabrook Station to the maximum extent practic [Italics added.] (MPR-4273, 1.2.2) Given all the variables for concrete mix, reinforcing, introduction of ASR attack, and much more to be sure, MPR/FSEL -situ characteristics. An example is instructive: wetted absorbent fabric that was placed on the top side of each specimen. Misters in the [Environmental Conditioning Facility] ECF maintained a humid environment during wet cycles. Comparison of expansion data from both sides of the test specimens did not identify a discernible bias in ASR development resulting from the wet fabric (MPR-4273 4.2.6)

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 10 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 For an engineering firm to assert that putting wet towels against a concrete member for a 28-day test can in any way -year inundation of concrete foundation wallsfor the purpose of testing and analysiscompletely strains credulity. A rough outline of the facts is as follows: over the relatively brief course of their project, MPR/FSEL purpose-formed reinforced concrete structures from available concrete sources (chas was practical), within which ASR was encouraged to propagate. These members were subjected to a sophisticated battery of tests, from which data was gathered. This is appears to be an overly-simplified and incomplete depiction of a detailed and carefully run project carried out with professionalism. -linear advancement of ASR over the course of 35-40 years, within concrete structures formed from components some sources of which are no longer available; many of those structures have been submerged at their footings by as much as six feet for all of that time; and for some of that time, the water inundating those foundations has had a relatively high salt content. Furthermore, some of those concrete structures have been subjected to significant, even high levels of heat; and some of those structures have been subjected to significant, and even high levels of radiation and the resulting neutron bombardment. o the maximum extent practical, one can only wonder whether the result of all this hard-won data from The effect of radiation in particular, on the progressive weakening of concrete through ASR, is notable. Indeed, an NRC publication highlights the changes that radiation (and heat) can bring about: potentially accelerate ASR activity or cause ASR to occur with aggregates that are not normally reactive. As plants age, the potential of ASR to occur in structures forming the biological shield or support for the reactor pressure vessel may increase as these structures are located in areas in which they are subjected to moderate elevated temperature in (NUREG/CR- An in this case on the part of NextEra, deserves mention here: -built structures is impractical for the S No rationale has ever been given for this assertion; and without any justification, it remains a false assumption. However, C-Unit 2 for a thorough Unit 1minus of course effects from heat and radiation, which would have to be factored in. Can that in any way be less degrading condition? Having turned away from core sampling after the core sample revelations of 2012, NextEra devised a narrative that , the actual condition. MPR agreed to carry out a multi-year study at FSEL in Austin, Texas, where concrete members were formed with the appropriate reinforcement to resemble configurations found at Seabrookand purposely infused with chemical properties encouraging the propagation of ASR. These were subjected to a series of tests to analyze the effect of ASR on this purpose-formed concrete; and the data derived from those tests -situ Seabrook Station concrete. There many problems with this methodology. The goal set for representativeness C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 11 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 sets no definitive parameters to establish a relationship between the FSEL findings and the ongoing ASR attack at Seabrook. The basic assumptions underlying the FSEL project, which then in turn counteracts the had already been disproven by the known science surrounding the study of ASR, long before the FSEL project was undertaken! Furthermore, the concrete walls of Seabrook, sitting in a salt marsh on the New Hampshire coast, present far too many variables to allow even a well-performed set of tests (as the FSEL tests obviously were) in Texas to reflect their characteristics: their age; the length of time ASR has propagated; the effect of the fresh water at varying levels; the effect of the salt in the water at varying levels of height and concentration; the effects of heat; the effects of radiation on certain vital structures; etc. While the testing at FSEL yielded important and valuable data about the behavior of short-term ASR progression in the FSEL data cannot, in any mean-situ concrete at the Seabrook reactor, under sustained attack from Alkali-Silica Reaction. Even MPR, who partnered with FSEL to carry out the project, stopped short of declaring that such a should not be allowed to replace thorough petrographic analysis of the actual concrete in question. om the FSEL testing is proprietary is not good science. The redaction of findings for the nearby communities that the problem is being han cloaking this data behind a proprietary curtain harms the interests of the community around Seabrook as well as the nuclear community. C-10 anticipates that the proceeding initiated by our filing will result in this data seeing the light of day for the benefit of many. and thereby kept out of the public domainfor two important reasons. First, the families who have to live in the ingestion pathway of Seabrook Station have the right to know just how safe, or unsafe, the most dangerous components of the reactor facility areespecially since NextEra currently seeks a 20-year extension to its operating license. Second, publication of test results would allow the larger engineering community to have access to the data, so that the proper feedback mechanisms for review are established. This is all the more important with regard to the FSEL project, where the engineering groups involved know that they are attempting something unprecedentedas stated above. Obviously, there is controversy around this methodology. Allowing the data to be seen and analyzed by the wider scientific and engineering communities would facilitate the needed debate. to be redacted includes details of test programs that MPR conducted and results from the test programs. Release of this information would concede intellectual property. Release of this information would also constitute a loss of competitive advantage relative to others engaged in assessment of structural impacts of alkali-inconsistent with the stated goal of the report to advance the body of knowledge of the effects of ASR under conditions of restraint. This is an extraordinary point of view. It is difficult to understand how withholding pertinent information, which would allow an independent assessment of the test results used to support the claims of NextEra, could reasonably be interpreted in this way. It is usual to actually submit such results for peer review to provide a basis for consensus among the relevant scientific community 16-03, p3, UCS, 9/30/16) awareness of, and associated management of, this concrete degradation mechanism at other nuclear power plants in the United States. We have urged the NRC to allow the disclosure of ASR testing and analysis for Seabrook Station. In nuclear safety hallmark C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 12 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 sharing good practices as well as bad ones. In this respect, both the local residential community, and the nuclear engineering community, remain informed. F. Assumptions made by NextEra and MPR concerning the continued robustness of reinforcing steel at the Seabrook reactor are unsupported by direct evidence. The long-term inundation, from brackish water, of foundation walls in safety-related areas of the complex, has exposed the concrete to elevated levels of salt. When combined with the chemical processes of ASR propagation through the concrete, this has likely created the conditions for corrosion of reinforcing steel to set in. Only in-situ monitoring for evidence of these impacts can ensure corrosion does not further degrade the strength of already impaired concrete. There is little mention of steel deterioration anywhere in the LAR and supporting documents. MPR states a basic assumption about the quality of construction that seems to put their single concern for steel strength to rest: extent that would be required for susceptibility to rebar fracture. Additionally, quality control requirements in effect during original construction of Seabrook Station would have prevented the poor construction practices that resulted in (MPR-Station. or not knowing that NRC issued -Compliance of against Public Service Company of New Hampshire during construction of Seabrook Station, because of poor quality controlresulting in large sections of reinforcing steel being cut during a 72-hour concrete pour session. (The construction worker who reported the error to the authorities on-site was fired the next day.) Therefore, we cannot assume that all reinforcing steel procedures were carried out to the highest standards. Dr. Brown has made repeated efforts, through his commentary on the ASR issue at Seabrook, to caution NRC that the imbedded steel is in site-specific mechanisms at work at Seabrook: -L- License -grade concrete has experienced ground water ranging from 19 to 3900 ppm. Exposure of reinforced concrete to chloride can induce deterioration by two separate mechanisms. Steel imbedded in concrete does not normally corrode because the elevated pH of concrete pore solution facilitates the formation of thin, adherent and protective layers of oxide on the steel surfaces. The phenomenon is called passivation. The presence of chloride ion in the pore solution adjacent to the reinforcing steel reduces the integrity of the passive layer; the process is called depassivation. This renders the embedded steel susceptible to corrosion regardless of the elevated pH of the concrete pore solution. Exposure conditions should be systematically characterized to establish the probability of corrosion of reinforcing steel that may be accompanying ASR. While chloride is more potent, sulfate also has the capacity to depassivate embedded steel. The sulfate exposure was reported as10-100 ppm. While substantially lower than the chloride concentrations, sulfate-containing water having concentrations in this range can be aggressive to concrete... The accumulation of chloride in the Seabrook concrete can be established by petrographic means using scanning electron microscopy. -Silica Reaction in Concrete -ons and effects on durability, 3/14/12) -day strength is immersed in a 3500-ppm sodium chloride solution, have intrud C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 13 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 to embedded steel. However, once chloride finds its way to the steel, that passivity is lost. Consequently, given the service environment at Seabrook, I think there a reasonable basis to anticipate that the reinforcement at some locations is likely to have undergone significant corrosion. Th(P. Brown, Ph. D., The dynamic interplay of ASR products with water saturating the concrete, may be indicative of steel corrosion within. According to Dr. Brown, the conditions for this are present at Seabrook Station: t various locations. This is an indication that significant amounts of moisture have migrated entirely through the walls. It is not unusual to observe this on subterranean walls and the material that has accumulated is often calcium hydroxide. As the calcium hydroxide solution reaches the concrete surface, it is exposed to atmospheric CO2, and calcium carbonate precipitates and typically forms an adherent deposit. If ASR is occurring, it is not uncommon for ASR gel also to extrude out of cracks, undergo a carbonation reaction and form deposits at evaporative fronts on interior surfaces. If the water source contains chloride or sulfate, sodium sulfate or calcium sulfate and sodium chloride deposits can formeposits Establishing whether the deposits contain chloride is of significant importance in establishing the vulnerability of embedded steel to chloride-induced corrosion. The NextEra response on page 26 of SKB-L-10204, comments that risk of damage to concrete due to corrosion of embedded steel is very low. However, this is only true in the absence of carbonation at the level of the steel, in the absence of a chloride exposure. Neither of these appears to be the case. SKB-L-10204 reports the observation of heavy corrosion at certain locations. Representative samples of corrosion product Alkali- Although this contention does not specifically address the quality of steel emplacement at the time of construction, the quality-control measures for steel installation cannot be the basis for an assumption of durabilitysince the improper handling of steel was cited by NRC during construction. The dynamic chemistry involving ASR products on the surface of the concrete, interacting with the elevated salt content of water from the surrounding salt marsh, forms compounds that can cause de-passivation and subsequent corrosion of the reinforcing steel. As ASR cracking increases, the process of steel corrosion is accelerated. The conditions necessary for de-passivation and steel corrosion have been present for more than 30 years. Therefore, the assumption that the steel reinforcement requires no testing for interior corrosion is false. This rely on the notion that ASR-bedded steel. It seems irresponsible even to their own hypothesis, not to test that same steel to be certain that its strength is not corroding away. (Of course, the results of such tests would need to be made public, for reasons stated earlier.) G. Omitted from the LAR 16-nature of ASR, there has been no testing nor proposed future testing of either manufactured concrete samples as in the FSEL (Ferguson Structural Engineering Laboratory) Texas tests nor of actual concrete from Seabrook Station itself to the point of failure/limit state. The tipping point concept is that all seems to be going well untiwall is hit and the situation changes abruptly. This concept is easiest to understand from a mechanical perspective, and, in fact, that is the appropriate perspective from which to look at the ASR situation at the Seabrook Nuclear Power Plant. Progressive ASR C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 14 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 will continue to weaken structures gradually over time. Then, one day, there may well be a profound failure because, er words, there was no testing to the point of failure, which means that the testing did not establish the percentages/degree of ASR damage that leads to structural failure/deformation due to loss of material properties. Even though the above paragraph describes the (lack of) testing scope of the FSEL Texas tests, a chart appears in the LAR 16-03 document (percentages redacted) that purports to show the levels at which limit state (failure) is reached. (LAR 160-03 Section 3.5.1., Table 4.) According to this chart/table, four structural limit states/failure is reached for four before failure/limit state is reached. Again, the percentages are redacted. It is unclear how the LAR can document the percentages of ASR damages at which failure occurs a few report sections after which it states that no testing was done to the point of limit state/failure. Further, the speed of progression of ASR is unknown: further cracking leads to further penetration by water, which in turn intensifies the ASR damage. It seems clear that the speed of concrete degradation may be gaining in momentum; therefore, the tipping point concept needs to be incorporated into this LAR. least fbasis of 40 years of operating life into a 40-60-year framework of operation. The original design basis did not take into consideration the current and ongoing, but originally unforeseen, ASR structural damage. The Seabrook Station UFSAR, Revision 10, Section 3.8, page 151, sectioproperties over the life of the structure, beyond that which is taken into account is establishing allowable stresses, strains, capacity function factors, concrete protection of reinforcing, and crack control as outlined in the referenced ACI -cited change in behavior or, more relevantly, provide a firm basis to assert that abrupt changes in structural capacity will not rook Station License Amendment Request 16-03, P.W. Brown, Ph.D., September 30, 2016) operability determination is whether the material properties are affected, it is unconservative to assume there is no degradation in material properties, especially since this has been observed elsewhere on site. C-10 believes the licensee would have to demonstrate that the material properties remain within its CLB (the ACI 318 limits). If not, it is outside of showing structures degrading to beyond their load-(Angela R. Buford, Structural Engineer, Division of License Renewal, U.S. Nuclear Regulatory Commission, September 12, 2012, Comments on the latest draft of the rebar and core sampling position papers) Section 2.2 of the LAR 16--pressure of the concrete on the rebar is balanced by the outward pressure of the rebar on the expanding concrete. In fact, these pressures are not equal and logically, over time, cause failure: regarded as the equivalent of prestressing. However, the tensile strength range for prestressing steel is 1725-1860 MPa C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 15 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 Amendment Request 16-03, P. W. Brown, Ph.D., September 30, 2016, page 3) Due to this documented differential in the internal forces of the structures and to the accepted progressive nature of ASR, material and thence structural failure is the only logical outcome. The following conversation is from the Official Transcript of Proceedings of the Nuclear Regulatory Commission, Advisory Committee on Reactor Safeguards, Structural Analysis/Plant License Renewal Subcommittee. The conversation is between Committee Member Brown and concrete expert Dr. Paul Wabout expansive, the ACR (sic) being and expansive process. Or ASR. Excuse me. And I was trying to calibrate myself what okay, all right. I understand. Dr. Brown: Yes. Either the aggregate itself is expanding and pushing against the cement base or the gel is getting he overall structural capacity by the internal tensile Dr. Brown: Yes. Member Brown: forces? Okay. Chair Riccardella: It could also be trying to push, you know, stress against the rebar, right? Dr. Brown: Oh, yes. Sure. Member Brown: Got that. Got that. Dr. Brown: And there was on study cited in Japan, and maybe you guys are more aware of it than I am, but where that happened. The ASR actually blew the rebar. Chair Criccardella: Yes, I think one of the NIST presentations showed that, showed the rebar, the Any LAR needs to set out methodology to test materials to and past their limit state/failure/tipping point. This one does not and therefore must be rejected by the Nuclear Regulatory Commission. H. The proposed inspection intervals laid out in LAR 16-03 are too long, and too fixed, to effectively measure the ongoing effects of ASR to structures at the Seabrook Nuclear Power Plant in a timely manner. One part of the SMP (Structural Monitoring Program) is the schedule of inspections. Table 5 in Section 3.5.1 of LAR 16-03 lays out the fixed schedule. Tier 2 structures - areas with up to .05% -.1% cracking- are scheduled to be monitored every 30 months, while Tier 3 areas with in-plane expansion measured at .1% or more are scheduled to be inspected every six months. At this time, there is no real knowledge of the speed of disintegration of concrete caused by advancing ASR. Further, there is no determination as to whether ASR progresses at a steady rate or at an accelerating (or decelerating) rate. Therefore, an SMP that relies on the LAR 16-03 set intervals is far from appropriately conservative. A lot can happen in six months, and even more in 30 months. What is known is that the FSEL Texas testing is a snapshot only, and, further, a snapshot not of the actual concrete at Seabrook Station to the maximum ext(LAR 16-03, Section 1.2.2) Not only is that not the same as testing the actual concrete at Seabrook Station, but also the same tests were not conducted on both concretes, which would at least have given a comparison and a base of data upon which future changes could have been compared. physical testing of concrete from those structures, a(Commentary on Seabrook Station License Amendment Request 16-03, P. W. Brown, Ph.D., September 30, 2016, page 1) ng cement paste microhardness values along with petrographic analyses. Such data could have been obtained from Seabrook structures and would have permitted a reasonable translation of the results on the test blocks to the actual structure. It would also provide data points against which future test results could have been compared a step which seems critical (ibid, page 2)

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 16 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 Due to these omissions in testing in the FSEL and due to the lack of knowledge of the speed of progression of ASR damage to the actual concrete at Seabrook Station, the LAR 16-03 needs to be rejected because it does not serve to adequately enhance the current license basis to account for the non-anticipated alkali-silica reaction that is now public health and safety. I. Completely omitted from LAR 16-03 is the vital factor of expected sea level rise on the progression of ASR at the portions of the plant exposed to possible sea water encroachment/ inundation. Seabrook Station is in a seaside location in a part of the world where sea levels are rising faster than in most other areas, making it more susceptible to extreme storms and coastal flooding. This factor needs to be taken into consideration in assessing the future impact of the potential damage to the plant due to ASR exacerbationas well as due to corrosion exacerbationand the impact of these factors on the health and safety of the population. It therefore needs to be a part of any LAR. There is no citation available for this contention, as the issue of sea level rise is not addressed within the LAR. For NextEra, a corporate enterprise dealing with highly toxic radioactive substances, to occupy coastal siting, yet not to be accounting for the effects of sea level rise during their remaining license period, is short-sighted and irresponsible. This, of course, makes the needed for in-situ analysis of the steel reinforcement corrosion, as well as the aggravating impact of high-salinity water at the foundations, all the more crucial. J. The language used in LAR 16-03 is inappropriate for a document written for the purpose of demonstrating objectivity in the testingand the conclusions of that testingby MPR / FSEL, on its manufactured concrete specimens. While LAR 16-03 purports to lay out new design basis standards testing to measure and monitor the effects of ASR degradation, its tone is extremely inappropriate and troubling. For example, the following is typical and repeated: The design basis to demonstrate will have strength close to or in excess of that envisaged in the original design or as required by code. These words, and others with their same import, are repeated throughout the document. It would seem that the additional monitoring/assessments/testing seeks to LEARN WHETHER the structures continue now and in the future to document to convey that the purpose of the new standards and methodologies is to CONFIRM that the structures are fit for continued service seems to pre-therefore to have completely removed objectivity in the assessment and in the methodology of the FSEL testing from the process. -03) indicates acknowledgement by MPR, the company conducting the Texas testing, and by NextEra, that the test materials are not in fact the same as the actual concrete being damaged by ASR at the Seabrook Nuclear Power Plant. IV. Summary Through the delineation of ten distinct yet interrelated issues, we have tried to convey the seriousness and scope of our contentions that nse Amendment Request (16-03) should receive a public hearing before the NRC. We see the LAR as a very flawed document, containing far-reaching conclusions for methodology to decipher the extent of Alkali-Silica Reaction at Seabrook Station. Many of these conclusions are based on completed erroneous, and sometimes spurious assumptions about the true behavior of ASR and how to accurately determine its advancement.

C-10 Foundation Petition for leave to intervene: NRC Docket No. 50-443 Page l 17 C-10 Foundation 44 Merrimac Street, Newburyport Mass. 01950 www.c-10.org (978) 465-6646 ment will appear smaller than otherwise, and because pore-filling during the one stage of ASR brings about a temporary strengthening effect, NextEra is asking the NRC to confirm what can only be described as a Not only is this false as explained in depth above, it is a conclusion contrary to decades of accumulated science on the subjectand one that they seek to defend with array of redacted studies that mainly protect them from the kind of peer review for their hypothesis from which they obviously have shied away. Furthermore, the rigidity of schedule and time-period intervals for the inspection protocol renders them inappropriate for accurate assessments of ASR advancement. This assumption of the mitigat, is built upon b whereby ASR-on by ASR. Although this is a claim without merit, it becomes a central justification for the use of FSEL-derived data and -situ concrete at Seabrook Station. While the FSEL data may have value there is zero justification for allowing FSEL data to represent degradation is non-linear. We have no way of knowing when failure is imminent. The only way known to ascertain the current-day extent of ASR degradation for structures as vital to the long-term safety, security and health of the seacoast as the safety-related structures at Seabrookis thorough petrographic analysis, including core-sample testing, of those structures. Seven years have passed since, to our knowledge, the only core-testing was done at Seabrook (showing a serious degradation in compressive strength); and we have presented expert testimony that the tensile strength of a concrete span may suffer more from ASR than compressive strength. We contend that the NRC should not allow NextEra to avoid the necessary testing of in-situ concrete because of a stack of false assumptions. This testing and its results should remain in the public sphereas a check and an assurancefor both the local community and the scientific community. Due to the presence of elevated salt levels in the water making contact with the base of concrete structures, the reinforcing steel itself must be analyzed through legitimate test practices for the extent of corrosion. The seeming lack of concern for the real condition of steel reinforcement is amplified by the total absence from the LAR of any accounting for the effect of sea level rise, and the resultant elevation in salt concentration for concrete. For all of the reasons stated, supported by the expert testimony given, the C-10 Foundation has called for the License Amendment Request to be denied. In this motion, we call upon the Nuclear Regulatory Commission to hold a public hearing relative to License Amendment Request 16-03, and we respectfully request intervenor status in this proceeding. On behalf of the board of directors and members of the C-10 Research and Education Foundation, thank you for your careful consideration of our contentions. Sincerely, Natalie Hildt Treat Executive Director C-10 Research & Education Foundation 44 Merrimac Street, Newburyport, Mass. 01950 Ph: (978) 465-6646 Email: natalie@c-10.org Submitted via the NRCs E-filing system on April 10, 2017.