UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

Mr. Kevin Walsh 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300 

Seabrook, NH 0387 4 

January 15, 2014 

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION, LICENSE RENEWAL APPLICATION- SET 20 

(TAC NO. ME4028) 

Dear Mr. Walsh: 

By letter dated May 25, 2010, NextEra Energy Seabrook, LLC, submitted an application 

pursuant to Title 10 of the Code of Federal Regulations Part 54 (1 0 CFR Part 54), to renew the 

operating license NPF-86 for Seabrook Station, for review by the U.S. Nuclear Regulatory 

Commission (NRC or the staff). The staff is reviewing the information contained in the license 

renewal application and has identified, in the enclosure, areas where additional information is 

needed to complete the review. 

These requests for additional information were discussed with Edward Carley, and a mutually 

agreeable date for the response is within 60 days from the date of this letter. If you have any 

questions, please contact me at 301-415-1427 or e-mail Richard. Plasse@nrc.gov. 

Docket No. 50-443 

Enclosure: 

Requests for Additional Information 

cc w/encl: Listserv 

Sincerely, 

Richard Plasse, Project Manager 

Projects Branch 1 

Division of License Renewal 

Office of Nuclear Reactor Regulation 
Mr. Kevin Walsh 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300 

Seabrook, NH 0387 4 

January 15, 2014 

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION, LICENSE RENEWAL APPLICATION- SET 20 

(TAC NO. ME4028) 

Dear Mr. Walsh: 

By letter dated May 25, 2010, NextEra Energy Seabrook, LLC, submitted an application 

pursuant to Title1 0 of the Code of Federal Regulations Part 54 (1 0 CFR Part 54), to renew the 

operating license NPF-86 for Seabrook Station, for review by the U.S. Nuclear Regulatory 

Commission (NRC or the staff). The staff is reviewing the information contained in the license 

renewal application and has identified, in the enclosure, areas where additional information is 

needed to complete the review. 

These requests for additional information were discussed with Edward Carley, and a mutually 

agreeable date for the response is within 60 days from the date of this letter. If you have any 

questions, please contact me at 301-415-1427 or e-mail Richard.Piasse@nrc.gov. 

Docket No. 50-443 

Enclosure: 

Requests for Additional Information 

cc w/encl: Listserv 

DISTRIBUTION: See next page 

ADAMS Accession No .. · ML 13357 A628 

Sincerely, 

IRA/ 

Richard Plasse, Project Manager 

Projects Branch 1 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

OFFICE LA: RPB2:DLR PM:RPB1:DLR BC: RPB 1: DLR PM: RPB1:DLR 

NAME YEdmonds RPiasse YDiazSanabria RPiasse 

(JDaily for) 

DATE 1/14/14 1/14/14 1/15/14 1/15/14 

OFFICIAL RECORD COPY 
Letter to K. Walsh from Richard Plasse dated January 15, 2014 

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION, LICENSE RENEWAL APPLICATION (TAC NO. 

ME4028) 

DISTRIBUTION: 

HARD COPY: 

DLR RF 

E-MAIL: 

PUBLIC 

RidsNrrDir Resource 

RidsNrrDirRpb1 Resource 

RidsNrrDirRpb2 Resource 

RidsNrrDirRarb Resource 

RidsNrrDirRasb Resource 

RidsNrrDirRerb Resource 

RidsNrrDraApla Resource 

Listserv 

Lois.James@nrc.gov 

Richard. Plasse@nrc.gov 

Brian.Wittick@nrc.gov 

Yoira. Diaz-Sanabria@nrc.gov 

John. Lamb@nrc.gov 

David.Mclntyre@nrc.gov 

Eugene. Dacus@nrc.gov 

Brian.Harris@nrc.gov 

Glenn. Dental@nrc.gov 

Paui.Cataldo@nrc.gov 

Chris. Newport@nrc.gov 

Jasmine.Gilliam@nrc.gov 

Nancy. McNamara@nrc.gov 

Doug. Tiff@nrc.gov 

Neii.Sheehan@nrc.gov 

Diane.Screnci@nrc.gov 
SEABROOK STATION 

LICENSE RENEWAL APPLICATION 

REQUESTS FOR ADDITIONAL INFORMATION SET 20 

RAis relating to the Alkali-Silica Reaction (ASR) Monitoring Program for the Seabrook 

Station License Renewal Application 

RAI 8.2.1.31 A-1 

Background: 

By letter dated November 2, 2012, in response to follow-up RAI B.2.1.28-3, the applicant stated 

that "the Containment Building, which is within the scope of the American Society of Mechanical 

Engineers (ASME) Section XI, Subsection IWL Aging Management Program (AMP), is within 

the scope of the plant-specific ASR Monitoring Program." 

In the Program Description section of the September 13, 2013, revisions to the ASR Monitoring 

Program, the applicant stated "to manage these aging effects, the existing Structures Monitoring 

Program (SMP), B.2.1.31, has been augmented by this plant-specific ASR Monitoring Program, 

B.2.1.31A." The "scope of program" program element states that "License Renewal structures 

within the scope of this program include: Containment Building (including equipment hatch 

missile shield) ... " 

Issue: 

The staff noted in license renewal application (LRA) Section B.2.1.28 that the ASME Section XI, 

Subsection IWL AMP will be used to manage aging of Primary Containment. It is clear that the 

results from routine inspections as prescribed by the SMP feed into the acceptance criteria of 

the ASR Monitoring Program; however, it is not clear that the results of the containment 

inservice inspection will feed directly into the ASR Monitoring Program. The ASR Monitoring 

Program description does not indicate whether, similar to the SMP, the applicant's ASME 

Section XI, Subsection IWL AMP will also be augmented by the ASR Monitoring Program to 

manage cracking due to expansion from reaction with aggregates. Additionally, the ASME 

Section XI, Subsection IWL AMP has not been revised to indicate that the program will be 

augmented by the ASR Monitoring Program. 

Request: 

Clarify whether the ASME Section XI, Subsection IWL AMP will also be augmented by the ASR 

Monitoring Program. If so, make the necessary revisions to the LRA including the plant-specific 

ASR Monitoring and ASME Section XI, Subsection IWL AMPs, their respective updated final 

safety analysis report (UFSAR) supplements, and the Tier 1 acceptance criteria of the ASR 

Monitoring Program to indicate that the IWL AMP is also augmented by the ASR Monitoring 

Program. If not, explain how the results of the ASME Section XI, Subsection IWL examination 

are incorporated into the ASR Monitoring Program. 

ENCLOSURE 
- 2-

RAI 8.2.1.31A-2 

Background: 

Plant-specific AMPs are reviewed against the criteria described in NUREG 1800, Revision 2, 

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

(SRP-LR), Appendix A.1. The SRP-LR, 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, 

applicants should provide the basis for the inspection population and sample size. 

SRP-LR, Section A.1.2.3.5, states that the "monitoring and trending" activities should provide a 

prediction of the extent of degradation and thus affect timely corrective or mitigative actions. 

This program element should describe how the data collected are evaluated, which includes an 

evaluation of the results against the acceptance criteria and a prediction regarding the rate of 

degradation in order to confirm that timing of the next scheduled inspection will occur before a 

loss of structure and component intended function. 

The applicant's response to follow-up RAI 8.1.31-7 stated that "trend data may be used in the 

future to adjust inspection frequency." This is reflected in The Program Description and the 

Operating Experience program elements of the ASR Monitoring AMP, which state that "trend 

data from .. .follow-up inspections will be used in determining the progression of ASR 

degradation and a basis for any change to the frequency of the inspection of ASR-affected 

areas." 

Issue: 

LRA section 8.2.1.31A, ASR Monitoring Program, submitted by letter dated May 16, 2012, 

states in the "monitoring and trending" program element that NextEra has performed a baseline 

inspection and assessed 131 accessible areas to date. The May 16, 2012, letter also states 

that monitoring of combined cracking index (CCI) and individual crack widths of at least 20 

areas identified in the baseline inspection as having the largest combined cracking index will be 

performed at 6-month intervals. 

The applicant's response to RAI 8.2.1.31-7, by letter dated November 2, 2012, states that of the 

131 locations, at least 20 areas that have the largest CCI will be quantitatively monitored at six 

month intervals to establish a rate of progression. The applicant's response states that these 

areas are those that currently meet the Tier 3 criteria, and that all other locations exhibiting the 

presence of ASR will be qualitatively or quantitatively monitored according to Tier 2 acceptance 

criteria on a 2 ~-year inspection frequency. 

It is not clear if all areas that meet Tier 3 criteria will be inspected on a 6-month frequency, or if 

the 20+ areas referenced by the applicant that have the largest CCI are a sample size of a 

larger population of Tier 3 areas. 
- 3-

In addition, the ASR Monitoring Program and UFSAR supplement do not specify the inspection 

frequency for Tier 2 locations, nor the technical basis for the 2 %-year inspection frequency. 

The AMP also does not include criteria for reducing the inspection frequency. 

Request: 

1. Explain whether the ASR Monitoring Program will monitor all affected areas meeting Tier 

3 criteria on a 6-month inspection frequency, and revise the LRA and UFSAR 

supplement as necessary to reflect such clarification. 

2. If the ASR Monitoring Program is intended to monitor 20 areas having the largest 

combined cracking index on a 6-month inspection frequency, provide the technical basis 

for both the selection of locations and sample size. 

3. If all Tier 2 locations will be monitored on a 2 %-year inspection frequency, revise the 

LRA and UFSAR supplement to reflect the inspection frequency, and provide the 

technical basis for the 2 %-year inspection frequency. 

4. Describe the criteria to be used to change the inspection frequency, and include the 

supporting technical basis. 

RAI 8.2.1.31A-3 

Background: 

The "acceptance criteria" program element of the applicant's ASR Monitoring Program states 

that the program will use the thresholds stated in its report MPR-3727, Revision 0, "Seabrook 

Station: Impact of ASR on Concrete Structures and Attachments" as the acceptance criteria for 

evaluating ASR-affected structures. The acceptance criteria stated in that report is also 

described in the ASR Monitoring Program description. The acceptance criteria chart in the AMP 

program description indicates that there are two sub-categories of Tier 2 locations, one requiring 

"quantitative monitoring and trending", one requiring only "qualitative monitoring". 

Issue: 

The staff noted that the applicant has performed a baseline inspection and that structural 

evaluations were performed for locations exceeding the Tier 3 criteria, which require structural 

evaluations. For the remaining areas, the staff noted that those locations exceeding the Tier 2 

criteria for monitoring and trending will be inspected using crack indexing measurements and 

trended to monitor the progression of ASR. However, it is not clear how new locations will be 

identified for crack indexing at the Tier 2 frequency. If some of the Tier 2 locations are 

"qualitatively monitored", (i.e., visual examination with no crack indexing), the staff is unclear as 

to how the program will identify when new locations meet the threshold for quantitative 

monitoring. 
- 4-

Request: 

If crack indexing will only be used for locations that exceed a CCI of .5 mm/m or individual crack 

width of .2 mm (Tier 2 criteria), state how the program will identify when a location is required to 

change from "qualitative monitoring" to "quantitative monitoring and trending". 

RAI 8.2.1.31 A-4 

Background: 

In its September 13, 2013, revision to the ASR Monitoring Program, the applicant stated "large 

scale destructive testing of concrete beams with accelerated ASR will be conducted to 

determine actual structural impact of ASR. Structural performance will be established based on 

correlation between the structural testing results and observed expansion levels/crack mapping. 

Large scale tests will confirm that parameters being monitored are appropriate to manage the 

effects of ASR and that the acceptance criteria used provides sufficient margin." The 

September 13, 2013, letter also states, in LRA Section A.2.1.31A (UFSAR Supplement), that 

"large scale destructive testing of concrete beams with accelerated ASR confirms parameters 

being monitored are appropriate to manage the effects of ASR and that acceptance criteria 

used provides sufficient margin. Anchor bolt testing quantifies the impact of ASR on anchor 

capacity as a function of the severity of ASR degradation." 

Issue: 

The UFSAR Supplement suggests that the large-scale destructive testing may provide the 

technical basis to show that the parameters monitored are appropriate; however, the objectives 

of the large-scale destructive testing described in the Program Description portion of the ASR 

Monitoring Program do not link the testing to the technical 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. 

Request: 

Provide further clarification regarding the role that the large-scale testing has, if any, in 

developing the technical basis for the ASR Monitoring Program. 

RAI B.2.1.31A-5 

Background: 

Plant-specific AMPs are reviewed against the criteria described in SRP-LR, Appendix A.1. 

SRP-LR, Section A.1.2.3.3, states that the "parameters monitored or inspected" program 

element should identify the aging effects that the program manages and should provide a link 

between the parameter or parameters that will be monitored and how the monitoring of these 

parameters will ensure adequate aging management. It also states that for a condition 

monitoring program, the parameter monitored or inspected should be capable of detecting the 

presence and extent of aging effects. 

SRP-LR, Section A.1.2.3.4, states that the discussion for the "detection of aging effects" 

program element should address how the program element would be capable of detecting or 
- 5 -

identifying the occurrence of age-related degradation of an aging effect prior to a loss of 

structure and component intended function. 

Issue: 

The "parameters monitored or inspected" and "detection of aging effects" program elements of 

the applicant's plant-specific ASR Monitoring Program indicate that cracking due to expansion 

from reaction with aggregates will be detected by visual inspection of cracking on the surface of 

the concrete. The applicant proposes to monitor this aging effect using a combined cracking 

index method and measuring individual crack widths at select locations on the surface of the 

concrete. 

In its supplement dated September 13, 2013, the applicant provided its technical basis for using 

the crack index methodology in the "program description." However; ASR causes concrete to 

expand in all directions, and the crack widths and number of cracks that appear on the surface 

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 surface of the concrete) would provide sufficient 

information to appropriately monitor cracking due to expansion from reaction with aggregates, 

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

Request: 

1. Explain how the proposed crack index methodology provides sufficient information 

regarding cracking due to expansion from reaction with aggregates, when the proposed 

method only accounts for expansion in the in-plane direction, or 

2. Propose a method or technique to monitor expansion in the out-of-plane direction, 

considering that many of the affected walls do not have transverse reinforcement. 

RAI 8.2.1.31A-6 

Background: 

Plant-specific AMPs are reviewed against the criteria described in SRP-LR, Appendix A.1. 

SRP-LR, Section A.1.2.3.4, states that the "detection of aging effects" program element should 

address how the program element would be capable of detecting or identifying the occurrence 

of age-related degradation or an aging effect prior to a loss of structure and component 

intended function. GALL Report AMPs XI.S1, ASME Section XI, Subsection IWL and XI.S6, 

Structures Monitoring Program, recommend (1) evaluating the acceptability of inaccessible 

areas when conditions exist in accessible areas that could indicate the presence of, or result in, 

degradation to such inaccessible areas, and (2) examining representative samples of the 

exposed portions of the below grade concrete, when excavated for any reason. 

Issue: 

By letter dated November 2, 2012, in its response to RAI B.2.1.31-9, the applicant stated that 

examination of inaccessible areas, such as buried concrete foundations, will be completed 

during opportunistic or focused inspections for buried concrete performed under the 

Maintenance Rule Program every 5 years. However, it is not clear that an assessment of 
- 6-

inaccessible areas has been performed as part of the baseline inspection to provide for 

adequate monitoring and trending of inaccessible areas. 

The staff notes that the applicant has committed (Commitment No. 67) to perform a shallow 

core bore in an inaccessible area of the spent fuel pool concrete; however, it is not clear that the 

applicant will use this opportunity to identify and assess the potential presence of ASR in this 

area. 

Request: 

1. For inaccessible areas of concrete: 

a. State whether an evaluation has been performed, 

b. Provide a summary of the evaluation as recommended in the GALL Report, and 

c. Provide the supporting technical basis. 

2. Describe how the ASR Monitoring Program provides for adequate monitoring and 

trending for these inaccessible areas (i.e., will they be monitored the same as accessible 

areas). 

3. Clarify if the shallow core being removed from the spent fuel pool will also be examined 

for concrete degradation due to ASR.