UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Mr. Kevin Walsh 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box300 

Seabrook. NH 03874 

December 23, 2013 

SUBJECT: AGING MANAGEMENT PROGRAM AUDIT REPORT REGARDING THE 

SEABROOK STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4028) 

Dear Mr. Walsh: 

By letter dated May 25, 201 0, Next Era Energy Seabrook, LLC (NextEra or the applicant), 

submitted an application to renew the operating license for Seabrook Station, Unit 1 (Seabrook). 

By letter dated May 16, 2012, the applicant submitted a revision to the license renewal 

application to include a plant-specific Structures Monitoring Program Supplement- Alkali-Silica 

Reaction (ASR) Monitoring Program. In addition, by letter dated September 13, 2013, the 

applicant submitted revisions to the program description and program elements "parameters 

monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance 

criteria," and "operating experience." However, the applicant did not revise the "scope of 

program," "preventive actions," "corrective actions," "quality assurance," and "confirmation 

process" elements contained in the May 16, 2012 submittal. The staff reviewed each ASR 

Monitoring program element in accordance with the criteria in "Standard Review Plan for 

Review of License Renewal Applications for Nuclear Power Plants," Appendix A.1, for review of 

plant·specific aging management programs. 

On November 20, 2013, the staff of the U.S. Nuclear Regulatory Commission completed the 

on·site audit of documents used to develop the ASR aging management programs. The audit 

report is enclosed. 
If you have any questions, please contact me by telephone at 301-415-1427 or by e-mail at 

Richard. Plasse@ nrc. gov. 

Sincerely, 

~~ra~: Division of License Renewal 

Office of Nuclear Reactor Regulation 

Docket No. 50-443 

Enclosure: 

As stated 

cc w/encl: Listserv 
If you have any questions, please contact me by telephone at 301-415-1427 or by e-mail at 

Richard_ Plasse@ nrc.qov. 

Docket No. 50-443 

Enclosure: 

As stated 

cc w/encl: Listserv 

DISTRIBUTION: See following pages 

ADAMS Accession No .. · ML 133548785 

Sincerely, 

IRA Juan Uribe for! 

Richard Plasse, Project Manager 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

concurred via email * 

OFFICE LA:DLW PM:RPB1 :DLW BC:RASB:DLR PM:RPB1 :DLR BC:RPB1 :DLR 

NAME I King RPiasse MMarshall RPiasse SCJ for YDiaz-Sanabria Juan for 

DATE 12/23/13 12/20/13 12/23/13 12/23/13 12/23/13 

OFFICIAL RECORD COPY 
Letter to Kevin Walsh from Richard Plasse dated December 23, 2013 

SUBJECT: AGING MANAGEMENT PROGRAM AUDIT REPORT REGARDING THE 

SEABROOK STATION LICENSE RENEWAL APPLICATION (TAG NO. ME4028) 

DISTRIBUTION: 

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Lois.James@ nrc.qov 

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U.S. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL 

Docket No: 

License No: 

Licensee: 

Facility: 

Location: 

Dates: 

Reviewers: 

Approved By: 

50·443 

NPF·86 

NextEra Energy Seabrook, LLC 

Seabrook Station 

626 Lafayelte Rd. 

Seabrook. NH 03874 

November 18·20, 2013 

R. Plasse, Project Manager, Division of License Renewal (DLR) 

Y. Diaz-Sanabria, Branch Chief, Projects Branch 2, DLR 

A. Erickson, Structural Engineer, DLR 

A. Buford, Structural Engineer, DLR 

Division of License Renewal 

Michael Marshall, Chief 

Aging Management of Structures, Electrical, 

and Systems Branch 

Division of License Renewal 

ENCLOSURE 
1 INTRODUCTION AND BACKGROUND 

1.1 Introduction 

By tetter dated September 13, 2013, Next Era Energy Seabrook, LLC (NextEra), submitted to 

the U.S. Nuclear Regulatory Commission (NRC), a supplement to the license renewal 

application (LRA) regarding the plant-specific Alkali-Silica Reaction (ASR) Monitoring program. 

In support of the staff's safety review of the LRA, NRC staff from the Division of License 

Renewal, Aging Management of Structures, Electrical, and Plant Systems Branch, audited and 

reviewed the ASR Monitoring program and relevant documents used to develop this 

plant-specific aging management program (AMP). 

The NRC staff pertormed its work in accordance with the requirements of Title 10 of the Code of 

Federal Regulations Part 54 (10 CFR Part 54), Requirements for Renewal of Operating 

Licenses for Nuclear Power Plants; the guidance provided in Revision 2 of NUREG-1800, 

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" 

(SRP-LR); and the guidance provided in Revision 2 of NUREG-1801, "Generic Aging Lessons 

Learned (GALL) Report." 

The NRC staff conducted a three-day onsite audit on November 18- 20, 2013. During its audit, 

the NRC staff examined the applicant's ASR Monitoring Program and program bases 

documents, interviewed various applicant representatives, and conducted walkdowns of 

selected structures affected by ASR. This audit report documents the results of the staff's 

activities during the audit. 

1.2 Background 

By letter dated May 25, 2010, NextEra submitted, to the NRC, its application for a renewed 

facility operating license for Seabrook Station, Unit 1 (Seabrook). Following correspondence 

between the NRC staff and the applicant regarding the aging management of structures 

affected by ASR, NextEra supplemented its application by letter dated May 16, 2012, with a 

plant-specific ASR Monitoring Program to augment the Structures Monitoring AMP. On 

February 21, 2013, a public meeting was held at the NRC Headquarters in Rockville, MD, 

between NRC staff and NextEra, during which the NRC staff verbally communicated its 

concerns regarding elements of the ASR Monitoring Program that needed additional information 

and further technical basis to support the continued review of this plant-specific AMP. By letter 

dated September 13, 2013, NextEra supplemented the LRA to incorporate additional 

information. 

2 AUDIT SCOPE 

The purpose of the audit was to review the applicant's plant-specific ASR Monitoring Program 

against the requirements of 10 CFR Part 54, the guidance provided in Appendix A.1, "Aging 

Management Review- Generic," of the SRP-LR, and the GALL Report to verify that the 

applicant's AMP will adequately manage the effects of aging for structures affected by ASR, so 

that their intended functions will be maintained consistent with the Seabrook current licensing 

basis (CLB) for the period of extended operation. 

ENCLOSURE 1 
- 2 -

LRA AMP B.2.1.31A, PLANT-SPECIFIC ASR MONITORING PROGRAM 

Summary of Information in the Application. The LRA states that, to manage the effects of 

cracking due to expansion and reaction with aggregates (e.g., ASR) in concrete structures, the 

existing Structures Monitoring AMP, 8.2.1.31, has been augmented by this plant-specific ASR 

Monitoring program, B.2.1.31A. According to LRA Section B.2.1.31A, ASR developed at 

Seabrook because the concrete mix designs utilized an aggregate that was susceptible to ASR, 

which was not known at the time. Although testing was conducted in accordance with ASTM 

C289, "Standard Test Method for Potential Alkali-Silica Reactivity of Aggregates (Chemical 

Method)," this standard was subsequently identified as being limited in its ability to predict late 

or slow reactivity in concrete. This program proposes performing visual inspections of concrete 

for indications of ASR, and monitoring the combined cracking index (CCI) and individual crack 

widths for locations that meet the criteria prescribed by the program. The AMP further states 

that a CCI of less than the 1.0 mm/m and individual crack width of less than 1.0 mm can be 

deemed to be "Acceptable with Deficiencies," and areas with deficiencies determined to be 

acceptable with further review are trended for evidence of further degradation. CCI and 

individual crack widths that exceed those values require a structural evaluation. 

During its audit of this plant-specific AMP, the staff reviewed the basis documents and 

references used in developing each element of the applicant's program against criteria 

described in SRP-LR, Appendix A.1, which provides the staff's technical position and guidance 

for evaluating the demonstration of aging management through plant-specific programs. Issues 

identified but not resolved in this report will be addressed in the safety evaluation report. 

Audit Activities. During its on site audit, the staff interviewed the applicant's staff and reviewed 

supporting documentation for the AMP. In addition, the staff conducted walkdowns of selected 

locations currently being monitored for cracking due to expansion from reaction with 

aggregates. Specifically, the staff walked down areas of the Primary Auxiliary Building, 

Mechanical Penetration Area, and the Containment Enclosure Ventilation Area, which is the 

annulus area between the Containment Building and Containment Enclosure Building. The staff 

also conducted an independent review of the applicant's plant-specific operating experience 

database using keywords: "ASR," "alkali," "pattern cracking," "map cracking," "expansion," and 

"craze." 

The table below lists the documents that were reviewed by the staff and were found relevant to 

the audit. These documents were provided by the applicant or were identified in the staff's 

search of the applicant's plant-specific operating experience. 
- 3 -

Relevant Documents Reviewed --- - -- Document Title Revision I 

Date 

1_ LRAP-ASR Seabrook Station Revision 1 

Results Book License Renewal Project 

Aging Management Program Basis Document 

Alkali-Silica Reaction (ASR) Monitoring Program 

2_ FHWA-HIF-09- Report on the Diagnosis, Prognosis, and Mitigation January 2010 

004 of Alkali-Silica Reaction in Transportation Systems, 

U.S. Department of Transportation, Federal 

Hiohwav Administration 

3_ The Institution Structural Effects of Alkali-Silica Reaction- July 1992 

of Structural Technical Guidance on the Appraisal of Existing 

Enqineers Structures 

4_ ORNUNRC/LT In-service Inspection Guidelines for Concrete December 

R-95/14 Structures in Nuclear Power Plants 1995 

5_ MPR-3727 Seabrook Station: Impact of Alkali-Silica Reaction Revision 0 

on Concrete Structures and Attachments April 2012 

6_ EDS-36180 NextEra Energy Revision 4 

Structural Engineering Standard 

Technical Procedure ---- 7. ES1807_031 lnservice Inspection Procedure Primary Revision 3 

Containment Section XI IWL Program 

8_ AR 01703049 Emergent Work Associated with ASR Evaluation 11/03/2011 

9_ AR 01771909 Installation of ASR Crack Index Gage Points 05/31/2012 

10_ AR 01641413 Documented Concrete Inspection Results 04/14/2011 

Containment CEVA Area 

11_ AR 01643562 Issue Identified During Containment Suriace 04/20/2011 

Walkdown 

12_ AR 01664399 Concrete Test Results 06/27/2011 

13_ AR 01687131 ASR Action Plan Key Activities & Completion 09/16/20i 1-

Dates --- ' 

14_ AR 01749443 Alkali-Silica Reaction Project Activities 03/28/2012 

15_ AR 01757861 Additional Areas of Concrete Affected by ASR 04/22/2012 

16_ AR 01877634 ASR Walkdown Assessment of Concrete- Phase 3 05/28/2013 

Locations 

17_ wo 40209732 ASR Crack Mapping Indexing & Expansion 06/28/2013 

Measurements 

18_ AR 01862204 Evaluate Concrete Condition at Tihange 2 Nuclear 06/20/2013 

Power Plant 

19_ AR 1734230 DRI & ASR Rating SH&H "Damage Rating Index Revision 1 

and Visual Assessment of Alkali-Silica Reactivity in 

Concrete Core Sections of Three Partial-Depth 

Cores from the Bravo Electrical Tunnel at NextEra 

~-

Enerqy, Seabrook, NH 
- 4-

During the audit, the staff reviewed program elements one through ten against the 

corresponding guidance for each element described in SRP-LR, Appendix A.1. For each of the 

plant-specific ASR Monitoring Program elements, the staff made the following observations. 

Element 1 - Scope of Program 

• Each of the concrete structures listed in the scope of the Structures Monitoring 

AMP, which is based on the existing Structures Monitoring Program that satisfies 

the requirements of 10 CFR 50.65, Maintenance Rule, is within the scope of the 

ASR Monitoring Program. 

Element 2 - Preventive Actions 

• Program basis documents indicate that mitigative measures have been taken 

and/or were considered under the current licensing basis; however, the 

implementation of the ASR Monitoring Program does not rely on preventive 

actions. 

Element 3- Parameters Monitored or Inspected 

• The applicant proposes to identify the presence of ASR through general visual 

examinations of concrete surtaces which include the following visual 

characteristics of ASR: 

• pattern cracking on the surtace of the concrete 

• secondary deposits at the pattern cracking location 

• dark staining adjacent to the cracks 

• gel exudation in the cracks 

• The applicant proposes to monitor expansion of the concrete by measuring CCI 

and individual crack width as parameters. The applicant's decision to monitor 

these parameters is based on available literature. The applicant's supporting 

technical basis are discussed in a plant-specific structural evaluation, titled MPR3727, "Seabrook Station: Impact of Alkali-Silica Reaction on Concrete Structures 

and Attachments." This report is used to assess expansion due to ASR and is 

based on the following references: 

• "Report on the Diagnosis, Prognosis, and Mitigation of Alkali-Silica 

Reaction in Transportation Structures," U.S. Dept. of Transportation, 

Federal Highway Administration, January 2010, Report Number 

FHWA-HIF-09-004. 

• "Structural Effects of Alkali-Silica Reaction: Technical Guidance on the 

Appraisal of Existing Structures," Institution of Structural Engineers (ISE), 

July 1992. 

• "In-Service Inspection Guidelines for Concrete Structures in Nuclear 

Power Plants," ORNUNRC/L TR-95/14, December 1995. 

Element 4 - Detection of Aging Effects 

• Provisions for inspection of inaccessible areas of concrete are performed under 

the Structures Monitoring AMP. Engineering Design Standard (EDS) 36180 

states the following: 
- 5 -

... examination of areas not typically accessible, such as buried 

concrete foundations, will be completed during inspections of 

opportunity during work related excavations. An evaluation of 

these opportunistic inspections for buried concrete will be 

completed every 10 years to ensure that ... buried concrete 

foundations on site will periorm their intended function through the 

period of extended operation. Additional inspections may be 

perlormed in the event that an opportunistic inspection has not 

been conducted, or if visible portions of the concrete foundation 

reveal degradation due to the development of an aggressive 

groundwater environment. 

EDS 36180 also states that periodic inspections of plant structures shall 

be periormed at least once per five years (plus or minus one year) for 

structures exposed to a harsh environment. Portions of below-grade 

concrete structures are exposed to aggressive groundwater at Seabrook 

Station and would be considered to be exposed to a harsh environment. 

Element 5 - Monitoring and Trending 

• During the audit walkdown, the staff observed two locations meeting the Tier 3 

acceptance criteria being monitored at a 6-month frequency, and two locations 

meeting the Tier 2 acceptance criteria, which are being monitored at a 2.5-year 

frequency. 

• The current Structures Monitoring Program implementing procedures include 

inspection and monitoring criteria for the effects of ASR consistent with those 

described in the plant-specific ASR Monitoring Program. Although submitted as 

a plant-specific program in the LRA, to be implemented prior to the period of 

extended operation, a review of implementing procedures and operating 

experience indicates that this program is currently being implemented. 

Element 6 -Acceptance Criteria 

• The acceptance criteria was determined based on the applicant's review of the 

following reports: 

• "Report on the Diagnosis, Prognosis, and Mitigation of Alkali-Silica 

Reaction in Transportation Structures," U.S. Dept. of Transportation, 

Federal Highway Administration, January 2010, Report Number 

FHWA-HIF-09-004. 

• "Structural Effects of Alkali-Silica Reaction: Technical Guidance on the 

Appraisal of Existing Structures," Institution of Structural Engineers {ISE), 

July 1992. 

• "In-Service Inspection Guidelines for Concrete Structures in Nuclear 

Power Plants," ORNUNRC/LTR-95/14, December 1995. 

• Locations meeting Tier 3 acceptance criteria require a structural evaluation. The 

applicant currently uses the structural evaluation documented in MPR 3727, 

"Seabrook Station: Impact of Alkali-Silica Reaction on Concrete Structures and 

Attachments." This report assesses each affected structure by applying a 

strength reduction factor the applicant determined was representative of 
- 6 -

worst-case ASR degradation to each limit state in the design calculations and 

showing that the structures still meet the stress limit requirements. 

Elements 7-9- Corrective Actions, Confirmation Process, and Administrative Controls 

• The quality assurance attributes of the ASR Monitoring Program, which include 

the "Corrective Actions," "Confirmation Process," and "Administrative Controls" 

program elements are consistent with the staff's guidance in SRP-LR, Appendix 

A1, "Branch Technical Positions," Section A.2 "Quality Assurance for Aging 

Management programs (Branch Technical Position IQMB-1)." 

Element 10- Operating Experience 

• Review of the inspection reports, program implementing procedures, structural 

evaluations and crack indexing results indicate the ASR Monitoring Program is 

currently being implemented. 

• To the extent that it has been available, international industry operating 

experience has been considered and evaluated for its applicability, through the 

applicant's corrective action program (CAP). 

• The applicant's CAP is being used to review plant-specific operating experience 

in order to track, trend and evaluate plant issues. 

In order to obtain the information necessary to continue its review of the applicant's 

plant-specific ASR Monitoring Program, the staff will consider issuing requests for additional 

information (RAis) for the subjects discussed below. 

• For the "scope of program" program element, the ASR Monitoring Program indicates that 

the containment building, which is within the scope of the ASME Section XI, Subsection 

IWL Program, is also within the scope of the ASR Monitoring Program. However, the 

program description in LRA Section 8.2.1.31 A indicates that the ASR Monitoring 

Program only augments the Structures Monitoring Program described in LRA Section 

8.2.1.31. Although it is clear from onsite documentation that the current 

10-CFR-5055a-required ASME Section XI, Subsection IWL lnservice Inspection program 

includes visual inspection for ASR, it is not clear if the ASME Section XI, Subsection IWL 

AMP will also be augmented by the ASR Monitoring Program, or how the results from 

the containment inservice inspection will be incorporated into the ASR Monitoring 

Program. The LRA does not address the ASR monitoring program in the IWL AMP. 

• For the "parameters monitored or inspected" and "detection of aging effects" program 

elements, the applicant has proposed to monitor cracking due to expansion from 

reaction with aggregates by (1) using a CCI measurement as a relative measure of 

expansion; and (2) measuring individual crack widths at the suriace of the concrete. 

ASR causes concrete to expand in all directions, and the crack widths and number of 

cracks that appear on the suriace of the concrete may not be indicative or bounding of 

the expansion in the out-of-plane, or transverse direction. This may be the case for 

many of the structures at Seabrook which do not include transverse reinforcement, and 

therefore expansion is not restrained by reinforcing steel. It is not clear that the 

parameters being monitored (i.e., combined cracking index and individual crack width in 

the "x-y" direction at the suriace of the concrete) would provide sufficient information to 

appropriately monitor cracking due to expansion, since the suriace expansion of the 

concrete may not be indicative of the out-of-plane expansion. 
- 7 -

• For the "detection of aging effects" program element, the SAP-LA, Appendix A.1, 

Section A.1.2.3.4 states that for a condition monitoring program, when sampling is used 

to represent a larger population of structures and components (SCs), applicants should 

provide the basis for the inspection population and sample size. For the "monitoring and 

trending" program element, the applicant has proposed to monitor the cracking index 

and individual crack widths of at least 20 areas identified in the baseline inspection as 

having the largest CCI at 6-month intervals. During the audit, the applicant clarified that 

all locations meeting the Tier 3 acceptance criteria will be monitored at 6-month 

intervals. In its review of the ASR Monitoring Program, it is not clear that the locations 

being monitored at 6-month intervals include all locations meeting the Tier 3 acceptance 

criteria, as opposed to being a sample size representing a larger population. 

• For the "detection of aging effects" program element, the applicant credits the inspection 

of buried concrete performed under the Structures Monitoring AMP, which is 

implemented through the CLB Structures Monitoring Program (used to satisfy the 

requirements of 10 CFR 50.65, Maintenance Rule), for the evaluation of inaccessible 

areas of concrete affected by ASR. The applicant has an opportunity to evaluate an 

inaccessible area of the spent fuel pool through Commitment No. 67, which states that 

the applicant will "pertorm one shallow core bore in an area that was continuously wetted 

from borated water to be examined for concrete degradation and also expose rebar to 

detect any degradation such as loss of material." The staff may inquire as to whether 

Commitment No. 67 will include examination of concrete degradation due to ASR when 

it performs the shallow core bore. 

• For the "detection of aging effects" and "monitoring and trending" program elements, the 

SRP-LR, Appendix A.1, Section A.1.2.3.4 states that this discussion should provide 

justification that the technique and frequency are adequate to detect the aging effects 

before a loss of SC-intended function. The ASR Monitoring Program submittal does not 

specify a frequency for monitoring Tier 2 locations, although during the staff's audit, the 

applicant stated that that locations meeting Tier 2 acceptance criteria will be monitored 

at a 2.5-year frequency. In addition, the basis for the 2.5-year inspection frequency was 

not provided in the LRA. 

The staff also reviewed the description of the ASR Monitoring Program provided in the updated 

final safety analysis report (UFSAR) Supplement. The staff verified this description is consistent 

with the description provided in the SRP-LR. In order to obtain the information necessary to 

verify the sufficiency of the UFSAR Supplement program description, the staff will consider 

issuing RAis for the subject discussed below. 

• In its September 13,2013 supplement to the ASR Monitoring Program, the applicant 

added language to the UFSAR supplement, which suggests that the large-scale 

destructive testing being conducted at the University of Texas may provide the technical 

basis to show that the parameters monitored are appropriate. However, the objectives 

of the large scale testing described in the program description portion of the AMP do not 

link the testing to the basis for the parameters being monitored. It is not clear whether 

the testing provides the technical basis for the parameters monitored or if the testing is 

meant to be confirmatory in nature. 
- 8 -

Audit Results. Based on this audit, the staff verified that the "preventive action," "acceptance 

criteria," "corrective actions," "confirmation process," and "administrative controls" program 

elements of the ASR Monitoring Program contain sufficient information for the staff to continue 

its review and evaluation. The staff also identified certain aspects of the "scope of program," 

"parameters monitored or inspected," "detection of aging effects," and "monitoring and trending" 

program elements for which additional information or additional evaluation is required. 

Based on this audit, the staff also found that additional information is needed before the staff 

can determine that the applicant's operating experience supports the sufficiency of the LRA 

AMP. In addition, the staff identified a need for additional information regarding the adequacy of 

the program description in the UFSAR Supplement.