The Story of Seabrook’s Concrete Concerns
I. Origins
Seabrook Station nuclear power plant was licensed for construction in 1976 by the NRC. It was built by the former utility company Public Service of New Hampshire and a consortium of other companies on a design basis provided by the US Nuclear Regulatory Comission. The Portland concrete used to form Seabrook’s floor, containment building, and most of its structures was done by Parini and came from Maine. The entire plant was built from the same aggregate. Construction was completed in 1986. The plant went online in 1990 with a 40-year operating license. The current owner is NextEra Energy Resources.
Although the current license does not expire until 2030, in 2010 NextEra applied for an extension of Seabrook’s license until 2050. That was granted in March 2019, after NRC staff ruled that there were "no significant hazards" with the plant.
II. Problems come to the surface
Flaws in Seabrook’s concrete began even during construction, as reported by several sources. Concrete was poured in below freezing temperatures contrary to procedure for proper solidification; cement which had been rejected by a safety inspector was poured anyway. There are reports of items such as beer bottles and cans tossed into the concrete, which could cause air pockets, and superficial patches were applied to cracks, resulting in improperly cured cement.
Settling of the structure caused cracking in the containment building before Seabrook began operating. The NRC told the owners to repair them with Vantex CP, which was known to be only a superficial solution, as stated by the dealer. (Employees Legal Project, CMSEP Inc.,1986) This shows that cracking of the concrete has been a persistent problem at Seabrook. These early repairs have not been re-examined.
In addition, steel rods designed to support the containment wall were improperly severed at the second storey level. In 1984 – during the construction process – an NRC report talks about groundwater infiltration into cracks affecting concrete and rebar, and stated a water-proofing membrane had not accomplished its purpose. Cracking of concrete could be heard by workers between the waste recessing building and the Diesel generator building, but this area was not inspected by the NRC. The cooling tower concrete was poured in 2 layers which are not connected to each other. The buildings have contained flaws and damages since before the plant went online, providing grounds for serious concern about the integrity and safety of the building and about the extent to which Seabrook’s owners care about the quality of the structure.
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III. Concerns for safety proliferate
Here is a brief overview of safety concerns since Seabrook went online:
- In 1999 a leak in the spent fuel pool caused a build-up of radioactive water in the space between the containment building and the containment enclosure building.
- In 2005, concrete degradation was first identified at the Seabrook nuclear power plant. 84 areas requiring engineering evaluation were listed by the NRC. Below and above grade cracking was identified.
- The groundwater was determined to be “aggressive” by testing results in 2008-9.
- Heavy corrosion of the containment liner plate was determined in 2009.
- In 2009 the NRC sent a relicensing team to Seabrook who evaluated the structures. Visual inspection revealed signs of alkali-silica reaction (ASR). Core samples were evaluated at a lab in Illinois, which confirmed ASR.
- In 2010, the NRC reported they were without a technical basis or regulatory basis for ASR, the industry had no experience or knowledge of ASR concrete degradation, and ASR research was limited and no long-term studies on nuclear plants exists.
- In 2011, the NRC reported that industry inspections must determine the extent and rate of ASR concrete degradation as it was an active, on-going form of degradation that was also not self-limiting and would continue to fail indefinitely.
*By this time ASR had been identified in 131 areas. ‘As of February 2012, there are safety concerns about concrete degradation at the plant. Concrete surrounding an electric control tunnel at the nuclear plant has lost almost 22 percent of its strength and is showing signs of an alkali–silica reaction
(ASR) because of more than a decade of ground-water infiltration, according to an NRC inspection report released in May 2011.’(“Seabrook Station Nuclear Power Plant.” Wikipedia. Wikimedia Foundation, 1 Mar. 2015. Web. 14 May 2015.)
- In 2014, the NRC and the National Institute of Standards and Technology (NIST) signed on a interagency agreement to study ASR’s structural performance on nuclear power plants.
An NRC report portrayed the situation as follows:
Safety concerns of a variety of kinds have continued since before Seabrook’s beginning operations. In particular, ASR has the potential to create a situation which could endanger humans and other populations of surrounding ecosystems.
Since Seabrook sits on a marsh, water exposure is constant. This is especially true as climate patterns change and extreme weather events such as flooding become more frequent. In addition, the salt content of the water is elevated as the marsh borders on the Atlantic Ocean. While there are some techniques that may mitigate ASR, the reaction will continue to occur and spread. Moreover, the NRC and the concrete industry have no known solution for ASR. Indeed, when ASR was first discovered in Seabrook, the NRC had no protocols or standards for dealing with this problem, and it still does not. Seabrook is the first nuclear power plant known to have ASR. C-10 is asking that the NRC carry out its responsibility to ensure that NextEra do the appropriate testing to determine the extent of the problem in order to keep the public safe from leaks of radioactive nuclides.
IV. Re-licensing and Uncovering the Problems
When Seabrook filed to extend its license for 20 years from 2030 – 2050 in 2010, 20 years before the expiration of its current license, C-10 looked into the reasons for this unusual application. At a re-licensing hearing held at Seabrook, a member of the NRC panel mentioned ASR. An inspection report also mentioned the issue. C-10 began researching degradation in Seabrook’s concrete.
NextEra failed to include this adverse condition in their application. This was a violation of federal code. This concerned C-10. In September 2010, the NRC published the first public acknowledgement of the issue; after a year and a half of investigation, this resulted in a stay of the safety portion of the re-licensing procedure.
Persistent problems have included a lack of adequate inspections due to unqualified workers being assigned to carry out required steps. Water leaks have continued to occur as well.
V. C-10 Takes Action
As soon as ASR was first mentioned by the NRC, C-10 began to study concrete in order to better understand what ASR might mean for the safety of the Seabrook plant. What we found was grounds for serious concern. The NRC had no technical specs or regulations concerning ASR. C-10 scoured industry reports and NRC reports.
C-10 formed a partnership with the Union of Concerned Scientists to promote further study of ASR. We needed scientists and a materials expert in concrete to educate us about the implications of ASR at Seabrook. Ultimately C-10 located an industry expert to answer questions, help us understand further questions we need to ask about safety and radiation issues and possible impact on the public. He subsequently wrote a
report on ASR
(see link for further detail.)
C-10 requested hearings on ASR to be held in Seabrook because there was so much public concern. Several NRC hearings were held at Seabrook which were attended by hundreds of local residents.
C-10 then went to Washington in 2012 to attend meetings between the NRC and members of the concrete industry and participated as concerned members of the public. They presented the research and made requests for next steps. The NRC invited the expert we had retained to testify at hearings of the Advisory Committee on Reactor Safety. Unrelenting pressure from C-10 helped hold the NRC accountable for following up on ASR concerns at Seabrook.
All this work has led to a delay in the licensing “until safety concerns are met.” C-10 has done years of research to educate the NRC and the public and to ensure that the focus stays on ensuring public safety. C-10 continues to diligently monitor the NRC’s work on Seabrook’s ASR and re-licensing application, as well as NextEra’s responses to the problems.
C-10 Granted Intervenor Status in Seabrook's License Amendment Review Case
On October 6, 2017, the C-10 Research & Education Foundation was granted standing following its pro se petition to intervene in a regulatory proceeding regarding the plant’s safety and operating license.
NextEra Energy Seabrook LLC’s pending
License Amendment Request
is relative to the
deteriorating concrete
at the plant, which has been operating since 1991. Citing serious safety concerns with the concrete and flaws in the concrete testing and monitoring methodologies, C-10 sought intervenor status in the docket, and requested a public hearing.
In a
100-page ruling
issued by the U.S. Nuclear Regulatory Commission’s Atomic Safety and Licensing Board (NRC/ASLB) on Friday, October 6, the three-judge panel wrote that C-10 has standing to intervene in Docket Number 50-443-LA-2, and admitted five of the group’s contentions, combining them into one reformulated contention.
Both NextEra and NRC staff attorneys had called for C-10’s petition to be thrown out, which the ASLB strongly refuted. In its ruling, the ASLB judges wrote that: “C-10 is not merely a nuclear watchdog or general environmental group; it is an organization focused on the safe operation of the Seabrook plant, and only that plant. It maintains and operates a ‘field monitoring network to measure real-time radiological emissions from the plant, under contract with the Massachusetts Department of Public Health’s Bureau of Environmental Health.”
Because of the chemical breakdown of the concrete known as ASR identified at several key structures at the plant beginning in 2009, NextEra began its own monitoring and testing program, including a large scale test at the Ferguson Structural Engineering Lab (FSEL) at the University of Texas, Austin. In 2016 NextEra submitted a License Amendment Request in effect stating that the concrete would continue to perform as designed, that it was degraded but operable.
In its ruling, the ASLB wrote a reformulated contention for C-10 : “The large-scale test program, undertaken for NextEra at the FSEL, has yielded data that are not ‘representative’ of the progression of ASR at Seabrook. As a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.”
“NUREG/CR-7171 (a publication of the NRC) supports C-10’s claim of a material deficiency in the test program. This is a disputed issue worthy of examination at an evidentiary hearing, given that the actual Seabrook concrete has been exposed to radiation for decades, even if at low levels in most places,” the ruling continued.
C-10 had alleged in its April 2017 petition to the NRC that the testing was inadequate and not representative of actual conditions at Seabrook, and that if the concrete failed and resulted in a radiological release, its monitoring operations, its members, and the public at large could face grave danger.
The outcome of this proceeding, which will culminate in an adjudicated hearing in September 2019, will not only impact the risks to health and safety of all who live near Seabrook; it will have national repercussions in how nuclear plants are regulated, since Seabrook is the first U.S. plant known to suffer from ASR.
Meanwhile, on June 1, 2010, NextEra Energy Seabrook Station submitted an application to the NRC for a license renewal to the year 2050, a full 20 years in advance of their current license expiration of 2030. The renewal was granted by NRC on March 12, 2019, despite serious concerns with the plant's degraded concrete.
But the case is not closed, as the NRC has indicated that it could be compelled to revisit the issue of Seabrook's concrete-aging management plan as a result of C-10's written and oral testimony in the case. We are fortunate to be represented by public interest attorney
Diane Curran, with
Dr. Victor Saouma
as our technical expert.
"In my expert opinion, the manner in which NRC Staff reviewed and accepted NextEra's testing and analysis programs was so devoid of scientific rigor or independence as to fatally undermine the credibility of its determinations regarding the safety of continuing to operate Seabrook in the presence of ASR," said Dr. Saouma.
Read more about C-10’s efforts relative to
ASR . See
C-10's blog for details on our involvement with the regulatory proceeding relative to Seabrook's license and the plant's degraded concrete, or visit the home page
for details on the Emergency Enforcement Petition we have filed with the NRC.