UNITED STATES

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

December 21, 2016 

Mr. Eric McCartney 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300, Lafayette Road 

Seabrook, NH 03874 

SUBJECT: ALKALI SILICA REACTION MONITORING AGING MANAGEMENT PROGRAM 

AUDIT REPORT REGARDING THE SEABROOK STATION, UNIT 1, LICENSE 

RENEWAL (CAC NO. ME4028) 

Dear Mr. McCartney: 

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, to renew the operating license 

NPF-86 for Seabrook Station, Unit 1, for review by the U.S. Nuclear Regulatory Commission. 

During the week of October 24, 2016, the staff completed the on-site audit Alkali Silica Reaction 

Monitoring aging management program at Seabrook Station located in Seabrook, NH. The audit 

report is enclosed. 

If you have any questions, please contact me by telephone at 301-415-3617 or by e-mail at 

Tam.Tran@nrc.gov. 

Sincerely, 

 /RA/ ECS for 

Tam Tran, Project Manager 

 Projects Branch 1 

 Division of License Renewal 

 Office of Nuclear Reactor Regulation 

Docket No. 50-443 

Enclosure: 

Audit Report 

cc: Listserv 
December 21, 2016 

Mr. Eric McCartney 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300, Lafayette Road 

Seabrook, NH 03874 

SUBJECT: ALKALI SILICA REACTION MONITORING AGING MANAGEMENT PROGRAM 

AUDIT REPORT REGARDING THE SEABROOK STATION, UNIT 1, LICENSE 

RENEWAL (CAC NO. ME4028) 

Dear Mr. McCartney: 

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, to renew the operating license 

NPF-86 for Seabrook Station, Unit 1, for review by the U.S. Nuclear Regulatory Commission. 

During the week of October 24, 2016, the staff completed the on-site audit Alkali Silica Reaction 

Monitoring aging management program at Seabrook Station located in Seabrook, NH. The audit 

report is enclosed. 

If you have any questions, please contact me by telephone at 301-415-3617 or by e-mail at 

Tam.Tran@nrc.gov. 

Sincerely, 

 /RA/ ECS for 

Tam Tran, Project Manager 

 Projects Branch 1 

 Division of License Renewal 

 Office of Nuclear Reactor Regulation 

Docket No. 50-443 

Enclosure: 

Audit Report 

cc: Listserv 

DISTRIBUTION: See following page 

ADAMS Accession No.: ML16333A247 

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

NAME YEdmonds TTran ABuford BWittick 

DATE 12/ 14 /2016 12/ 14 /2016 12/ 15 /2016 12/ 15 /2016 

OFFICE BC:EMBC:DE BC:RPB1:DLR PM:RPB1:DLR 

NAME JQuichocho RChazell (a) TTran/ECS for 

DATE 12/ 20 /2016 12/ 19 /2016 12/ 21 /2016 

OFFICIAL RECORD COPY
Letter to Eric McCartney from Tam Tran dated December 21, 2016 

SUBJECT: ALKALI SILICA REACTION MONITORING AGING MANAGEMENT PROGRAM 

AUDIT REPORT REGARDING THE SEABROOK STATION, UNIT 1, LICENSE 

RENEWAL (CAC NO. ME4028) 

DISTRIBUTION 

EMAIL: 

Docket No. 50-443 

PUBLIC 

RidsNrrDlrRpb1 Resource 

RidsNrrDlrRarb Resource 

RidsNrrDlrRasb Resource 

RidsNrrDlrRerb Resource 

RidsNrrDraArcb Resource 

RidsOgcMailCenter Resource 

RidsNrrMailCenter Resource 

---------------------------------------------------- 

Tam.Tran@nrc.gov 

Lois.James@nrc.gov 

Russell.Chazell@nrc.gov 

Brian.Wittick@nrc.gov 

Justin.Poole@nrc.gov 

David.McIntyre@nrc.gov, OPA 

Jenny.Weil@nrc.gov, OCA 

Eugene.Dacus@nrc.gov, OCA 

Brian.Harris@nrc.gov, OGC 

Jeremy.Watchuka@nrc.gov, OGC 

Mel.Gray@nrc.gov, RI 

Fred.Bower@nrc.gov, RI 

Paul.Cataldo@nrc.gov, RI 

Peter.Meier@nrc.gov, RI 

Richard.Barkley@nrc.gov, RI 

Robert.Vadella@nrc.gov, RI 

Mark.Draxton@nrc.gov, State Liason 

Dough.Tiff@nrc.gov, State Liason 

Neil.Sheehan@nrc.gov, RI PAO 

Diane.Screnci@nrc.gov, RI PAO
 ENCLOSURE 

U.S. NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL 

SEABROOK ASR-MONITORING PROGRAM AUDIT REPORT 

Docket No: 50-443 

License No: NPF-86 

Licensee: NextEra Energy Seabrook, LLC 

Facility: Seabrook Station, Unit 1 

Location: P.O. Box 300, Lafayette Road 

Seabrook, NH 03874 

Dates: October 24-28, 2016 

Auditors: Angela Buford, Structural Engineer, Audit Team Leader, Division of License 

 Renewal (DLR), Office of Nuclear Reactor Regulation (NRR) 

George Thomas, Senior Structural Engineer, DLR, NRR 

Bryce Lehman, Structural Engineer, Division of Engineering (DE), NRR 

Brian Wittick, Branch Chief, DLR, NRR 

Benjamin Beasley, Acting Deputy Director, DLR, NRR 

Approved By: Brian Wittick, Chief 

 Aging Management of Structures, Electrical, and Systems Branch 

 Division of License Renewal 

 Office of Nuclear Reactor Regulation 

 Jessie Quichocho, Chief 

 Mechanical and Civil Engineering Branch 

Division of Engineering 

 Office of Nuclear Reactor Regulation 
- 2 - 

SEABROOK ASR-MONITORING AND BUILDING DEFORMATION AGING MANAGEMENT 

PROGRAMS AUDIT REPORT 

1. Introduction and Background 

1.1 Introduction 

The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor 

Regulation (NRR) Division of License Renewal and Division of Engineering performed an audit 

of the NextEra Energy Seabrook, LLC (NextEra, or the applicant) Alkali-Silica Reaction (ASR) 

Monitoring Aging Management Program (AMP) and Building Deformation AMP 

October 25-27, 2016. The audit was performed at the NextEra Energy Seabrook Station in 

Seabrook, NH and was focused on reviewing information related to the applicant’s submittal 

dated August 9, 2016 (ADAMS Accession No. ML16224B079). The purpose of the audit was to 

(1) gain a better understanding of revisions to the applicant’s plant-specific ASR Monitoring 

AMP, (2) review supporting documentation and technical bases information for the applicant’s 

newly submitted Building Deformation AMP, and (3) identify the need for any additional 

information on the docket. These programs were submitted for the staff’s review related to 

Open Item OI 3.0.3.2.18-1 in the safety evaluation report (SER) with Open Items (ADAMS 

Accession No. ML12160A374). 

The regulatory bases for the audit were 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;” 10 CFR 54.17, “Filing of Application,” which requires applicants for 

renewed licenses to send written correspondence to the NRC; 10 CFR 54.37, “Additional 

Records and Record Keeping Requirements,” which requires that license renewal applicants 

maintain documents demonstrating compliance with the requirements of 10 CFR Part 54 in 

auditable and retrievable form. The audit provided the staff the opportunity to review supporting 

information retained as records under 10 CFR 54.37 that may not necessarily be required to be 

submitted as part of the license renewal application (LRA), but which provide additional 

information and technical bases for the submitted information. The staff performed its review in 

accordance with guidance provided in NUREG-1800, Revision 2, “Standard Review Plan for 

Review of License Renewal Applications for Nuclear Power Plants” (SRP-LR), dated 

December 2010. 

This audit report documents the results of the staff’s activities during the audit. 

1.2 Background 

By letter dated May 25, 2010, the applicant submitted its application for license renewal for 

Seabrook Station, Unit 1. NextEra’s LRA requested renewal of the operating license for an 

additional 20 years beyond the current 40-year license, which expires on March 15, 2030. In its 

letter dated May 16, 2012, the applicant supplemented its application to include a plant-specific 

ASR Monitoring program to manage the effects of aging due to ASR. The NRC staff conducted 

audits of the plant-specific ASR Monitoring AMP in November 2013 and October 2015. On 

April 28, 2016, the staff and NextEra held a public meeting to discuss the applicants 

December 2015 submittal, and NextEra subsequently submitted a revision to the LRA regarding 

the ASR open item. This revision was submitted to the NRC by letter dated August 9, 2016, 
- 3 - 

and included a revised LRA Appendix B Section B.2.1.31A, “Alkali-Silica Reaction (ASR) 

Monitoring” AMP and a new LRA Section B.2.1.31B, “Building Deformation Monitoring” AMP. 

2. LRA AMP B.2.1.31A, ASR MONITORING PROGRAM AND AMP B.2.1.31B, 

BUILDING DEFORMATION MONITORING PROGRAM AUDIT SCOPE 

2.1 Summary of Information Provided by the Applicant 

The applicant’s August 9, 2016, letter describes the ten elements in both the ASR Monitoring 

and Building Deformation Monitoring AMPs. For the ASR Monitoring AMP, the LRA update 

states that the program uses periodic visual inspections to identify structures in the scope of the 

program (i.e., structures that have visible indications that ASR may be present). Once locations 

are identified, the type and frequency of monitoring is chosen based on a tiered criteria of ASR 

severity. The severity of ASR is initially determined based on combined cracking index (CCI) 

measurements of total crack widths in the “x”- and “y”- (i.e., horizontal and vertical) surface 

directions and also on individual crack width. In the most severe (“Tier 3”) locations, the 

program states that cracking through the thickness of the concrete (“z”-direction or through-wall) 

will be monitored using borehole extensometers installed in drilled core bore holes. The 

applicant stated that it plans to monitor CCI in the in-plane directions at frequencies dictated by 

the “Tier” assignment based on ASR severity. 

Acceptance criteria for monitoring through-wall thickness is based on data that NextEra 

obtained from a large-scale testing program it conducted at the University of Texas at Austin, 

Ferguson Structural Engineering Laboratory. The results of the large-scale beam and block 

tests are correlated to ASR impact on Seabrook structures. The applicant asserts that (1) the 

testing program validates the use of expansion to measure ASR severity and monitor ASR 

progression, and (2) that the testing program affirms that ASR has no adverse effect on 

structural performance up to the magnitude of ASR expansion tested. 

The LRA states that the program will determine expansion to date at locations selected for 

instrument installation. The methodology is discussed in a report MPR-4153, Revision 2, titled 

“Seabrook Station – Approach for Determining Through-Thickness Expansion from Alkali-Silica 

Reaction,” (hereafter referred to as MPR-4153), which was originally submitted to the NRC on 

June 30, 2015, and subsequently resubmitted on September 30, 2016. In this report, the 

applicant describes the basis for the proposed methodology to quantitatively relate the extent of 

ASR in existing plant structures at Seabrook to the large-scale testing results. The approach 

includes correlating measured through-wall expansion in large-scale test specimens and a 

corresponding reduction in modulus of elasticity with comparable loss in modulus of elasticity of 

cores drilled from Seabrook structures. 

For the Building Deformation Monitoring Program, the LRA update states that the program for 

monitoring of structures for building deformation will be implemented on a structure by structure 

basis. The program will use visual inspections associated with the Structures Monitoring 

Program and CCI measurements associated with the ASR Monitoring AMP to identify buildings 

that are experiencing deformation. The results of the visual inspections will be input into an 

analytical model which will determine the methods and frequency of required inspections. The 

LRA states that the program will use a three-step process to screen for deformation and analyze 

the effects on structures, and the process will result in identifying threshold parameters to be 
- 4 - 

monitored. The three steps are: Stage One – Susceptibility Screening Evaluation; Stage Two – 

Analytical Evaluation; and Stage Three – Detailed Evaluation. The analysis will also establish 

acceptance criteria (“threshold limits”) on a structure by structure basis. Once the parameters to 

be monitored and acceptance criteria are established for each structure, periodic inspections 

will obtain location-specific measurements, and those measurements will be compared against 

location-specific acceptance criteria to evaluate the acceptability of the condition. Frequency of 

examination is based on the Stage of evaluation or analysis (Stage 1, 2, or 3) that was used to 

baseline the structure. 

The LRA states that inspections will also be performed to identify structures and components 

whose functionality may be affected by the building deformation of supporting structures and 

that these items will be entered into the Seabrook corrective action program. 

2.2 Audit Activities 

During its audit, the staff conducted interviews and discussion with the applicant’s cognizant 

staff, consultants, and technical experts; performed walkdowns of the plant; and reviewed 

information generated by NextEra’s contractor that provided detailed insights about the ASR 

Monitoring and Building Deformation Monitoring programs. In addition, the staff reviewed site 

implementing procedures, work orders, corrective action program issue reports, and periodic 

maintenance plans associated with the ASR issue. Specific activities included the following: 

- Review of ASR Monitoring AMP implementation to date, including review of associated 

procedures and crack measurement results to date including document review, 

interviews with cognizant personnel, and walkdowns of areas that have installed 

extensometers in accordance with the program. The staff also witnessed sample testing 

of cores removed from areas of extensometer installation for modulus and compressive 

strength. 

- Review of operating experience related to ASR-related macro cracking and building 

deformation in the residual heat removal (RHR) and core spray (CS) equipment vault, 

and methodology/plans for aging management. Staff also performed walkdowns of the 

RHR and CS equipment vault, fuel storage building, secondary containment exterior, 

and condensate storage tank area which have been or will be evaluated under the 

building deformation monitoring program. 

- Review of recent operating experience related to ASR-related seismic gap reduction 

associated with a concrete missile shield and methodology/plans for aging management 

of the containment and containment enclosure building (CEB). Staff also performed a 

walkdown of the affected areas. 

- Observed demonstration and review of a complete analysis that has followed the 

program methodology, including finite element analysis input and results; and 

consideration of the three-stage evaluation process approach to building deformation 

analysis (e.g., CEB). 

- Observed demonstration and review of analyses being performed under each Stage of 

the Building Deformation Monitoring process for determining parameters monitored or 
- 5 - 

inspected and acceptance criteria (i.e., Containment Equipment Hatch Missile Shield, 

RHR vault, Condensate Storage Tank, and Containment Enclosure Building). 

- Discussed status of large-scale testing program, reviewed documentation, and gained 

insights on the application of the testing program to the AMPs. 

- 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. 

Relevant Documents Reviewed 

Document Title Revision / 

Date 

1. EDS 36180 Structures Monitoring Program Revision 9, 

08/18/16 

2. ES 1850.018 Structures Monitoring Program: Inspections, Data 

Gathering, and Evaluations 

Revision 0 

3. FP 100918 Approach for Determining Through-Thickness 

Expansion from Alkali-Silica Reaction 

Revision 2, 

09/08/16 

4. FP 100985 Confirmation of As-Deformed CEB Revision 1, 

08/01/16 

5. FP 101020 Seabrook Station Impact of Alkali-Silica Reaction 

on Structural Design Evaluations 

Revision 0, 

07/25/16 

6. FP 101039 Development of ASR Load Factors For Seismic 

Category 1 Structures (Including Containment) At 

Seabrook Station 

Revision 0, 

08/01/16 

7. FP 101050 Implications of Large-Scale Test Program Results 

on Reinforced Concrete Affected by Alkali Silica 

Reaction 

Revision 1, 

07/25/16 

8. MS0517.51 Installation of Geokon Snap-Ring Borehole 

Extensometers 

Revision 3 

9. Work Order 

40494076 

Task 01 

SMP ASR Monitoring – Perform 6 Month 

Frequency CCI Measurements – “B” Train/Interior 

10. PM Requirement 

00083478 01 

SMP Building Deformation – Seismic Gap Data 

Collection Stage 3 Blds 

11. PM Requirement 

00083486 01 

SMP ASR Monitoring – Perform 6 Month 

Frequency CCI Measurements 

12. PM Requirement 

00083479 01 

SMP Building Deformation – Annulus Width Data 

Collection 
- 6 - 

Document Title Revision / 

Date 

13. PM Requirement 

00083485 01 

SMP Building Deformation – Evaluate Data 

Collected for CEB 

14. PEG-98 CEB Extent of Condition Equipment Walkdown Revision 0 

15. MS0517.53 Periodic Monitoring of Concrete Expansions 

Geokon Snap-Ring Borehole Extensometers 

Revision 0 

 

Audit Results. In its review of program elements one through ten against the corresponding 

guidance for each element described in SRP-LR, Appendix A.1, the staff found that for the 

“Scope of Program,” “Parameters Monitored or Inspected,” “Detection of Aging Effects,” 

“Acceptance Criteria,” and “Operating Experience” program elements, either (1) there is 

information audited by the staff (but was not on the docket) that is needed for the staff to make a 

safety conclusion regarding the adequacy of the program, or (2) sufficient information was not 

available to evaluate whether the AMPs were adequate for aging management. In order to 

obtain the information necessary to verify whether these program elements are adequate for 

sufficient aging management, the staff will consider issuing RAIs for the subjects discussed 

below. 

ASR Monitoring Program

Parameters Monitored or Inspected 

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. The SRP-LR 

also states that the parameter monitored or inspected should be capable of detecting the 

presence and extent of aging effects. The staff noted that documentation regarding the 

applicant’s large-scale testing program identifies volumetric expansion as a measure of 

ASR progression, but that the proposed ASR Monitoring AMP does not measure or 

evaluate volumetric expansion. In addition, the AMP states that combined cracking 

index will be used to measure the effects of rebar strain due to ASR expansion, but the 

AMP and audited information do not provide information on what actions will be taken to 

do this. 

Detection of Aging Effects 

SRP-LR Section A.1.2.3.4 states that the “Detection of Aging Effects” program element 

should describe “when,” “where,” and “how” program data are collected (i.e., all aspects 

of activities to collect data as part of the program). The staff noted that the ASR 

Monitoring AMP “detection of aging effects” program element does not specify the 

inspection interval planned for monitoring through-wall expansion using snap-ring 

borehole extensometers. The staff may request additional information to clarify the 

methods and frequencies of inspection(s) for “Tier 3” monitoring locations after the 

installation of extensometers. 
- 7 - 

Acceptance Criteria 

The applicant’s updated LRA submittal states in the “Element 6 – Acceptance Criteria” 

section, “[a] structural evaluation is needed when the CCI reaches what is classified as 

Tier 3 (CCI > 1 mm/m).” It is not clear to the staff to what the term “structural evaluation” 

is referring. Specifically, it is not clear whether this statement refers to the analysis 

referred to in Section B.2.1.31B (Building Deformation Monitoring Program), or if it refers 

to a different analysis that would be performed if a structure reaches “Tier 3” expansion 

as determined by CCI. Also, it is not clear what evaluation would be performed if the 

structure is not within the scope of Section B.2.1.31B and whether all structures within 

Section B.2.1.31B receive an analysis regardless of CCI. The staff may request that the 

applicant provide clarification on this issue. 

Operating Experience 

SRP-LR Section A.1.2.3.10 states that an applicant should commit to a future review of 

plant-specific and industry operating experience to confirm the effectiveness of its aging 

management programs or indicate a need to develop a new AMP. 

The applicant’s August 9, 2016, letter states that, with regard to large-scale testing: 

- The results of the test program demonstrated that none of the assessed limit 

states are reduced by ASR when ASR expansion levels in plant structures are 

below those evaluated in the large-scale test programs. 

- Results from the large-scale testing program are also used to support 

evaluations of structures subjected to deformation. 

- Data from the structural testing programs have shown that expansion in the inplane direction plateaus at low expansion levels, while expansion in the throughthickness direction continues to increase. 

- A correlation relating expansion to reduction in elastic modulus was developed 

from the large scale testing program data. The correlation relating expansion to 

reduction in elastic modulus is applicable to reinforced concrete structures at 

Seabrook. 

The staff noted that the methodology for computing through-wall expansion to-date is 

described in Report MPR-4135, which was submitted to the staff. 

The “Operating Experience” program element of the ASR Monitoring AMP states 

“Seabrook will update the Aging Management Program for any new plant-specific or 

industry OE [Operating Experience].” 

The applicant’s statements indicate that there is an assumption that the actual structures 

subject to ASR at Seabrook will behave as observed in the test specimens. Although 

the test specimens have been created to be as “representative as practical” of Seabrook 

two-way reinforced concrete walls, the assumption that Seabrook ASR-affected concrete 
- 8 - 

will behave as seen in the test specimens has not been corroborated or validated. The 

staff has the following concerns: 

- The methodology described in MPR-4135 has not yet been corroborated or 

validated. It is not clear whether the applicant plans to corroborate or validate, 

over sufficient time and prior to period of extended operation that the behaviors 

observed due to ASR in the testing specimens and assumed to correlate to 

Seabrook concrete structures are consistent. 

- The effects of ASR degradation are being addressed as a first-of-a-kind issue in 

the United States nuclear power industry without a widely-accepted or 

standardized approach to addressing it, and the applicant’s AMP is based 

primarily on the scope and data of one “plant-specific” large-scale test program. 

It is not clear if and how the AMP will corroborate or validate assumptions made 

once there is data available from implementation of the program to confirm the 

effectiveness of the ASR Monitoring AMP to manage aging effects for which it is 

credited. 

The staff may consider requesting that the applicant explain whether and how the ASR 

Monitoring AMP will corroborate or validate assumptions (e.g., petrographic 

characteristics, reduction of elastic modulus at a given expansion, ‘plateau’ behavior of 

in-plane expansion, dominant out-of-plane expansion, lack of evidence of in-plane 

cracking) about how structures at Seabrook would behave under ASR expansion based 

on observations from the testing program and if not, to provide technical basis. 

Building Deformation Monitoring Program 

Scope of Program 

SRP-LR Section A.1.2.3.1 states that the “Scope of Program” program element should 

include the specific structures and components, the aging of which the program 

manages. The applicant’s August 9, 2016, submittal states “[t]he Seabrook Building 

Deformation Monitoring Program provides for management of the effect of building 

deformation on Seismic Category 1 structures and associated components within the 

scope of license renewal.” Also included is a list in Section B.2.1.31A of concrete 

structures within the scope of the license renewal structures monitoring program that will 

be monitored by the ASR Monitoring AMP and a list in Section B.2.1.31B of structures 

that will be managed by the Building Deformation program. The staff reviewed 

implementing documentation and a list of structures to be evaluated under the Building 

Deformation program and found discrepancy between the structures listed in the 

implementing documentation and the August 9, 2016, submittal. Specifically, the 

Seismic Category 1 Control Building, Diesel Generator Building, and Service Water 

Access (Inspection) Vault were not captured in the implementing documentation. It is 

not clear whether those structures are included in implementation of the Building 

Deformation program. It is also unclear why the list of structures managed does not 

match between Section B.2.1.31A and Section B.2.1.31B; specifically, why the nonCategory I structures in the ASR Monitoring AMP are not included in the Building 

Deformation Program. The staff may request that the applicant confirm whether the 

Seismic Category 1 Control Building, Diesel Generator Building, and Service Water 
- 9 - 

Access (Inspection) Vault are included in the Building Deformation Program or explain 

why not. In addition, the staff may request that the applicant explain why the nonCategory I structures in the ASR Monitoring AMP are not included in the Building 

Deformation Program. 

Parameters Monitored or Inspected/Detection of Aging Effects/Acceptance Criteria

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. The SRP-LR 

also states that the parameters monitored or inspected should be capable of detecting 

the presence and extent of aging effects. SRP-LR Section A.1.2.3.4 “Detection of Aging 

Effects” states that the program element describes “when,” “where,” and “how” program 

data are collected. For a condition monitoring program the discussion should provide 

justification that the [monitoring] method and frequency are adequate to detect aging 

effects before a loss of SC-intended function. SRP-LR Section A.1.2.3.6 “Acceptance 

Criteria” states that the acceptance criteria, against which the need for corrective actions 

are evaluated, could be specific numerical values or could consist of a discussion of the 

process for calculating specific numerical values of conditional acceptance criteria to 

ensure that the structure- and component-intended function(s) will be maintained under 

all current licensing basis (CLB) conditions. 

In Section B.2.1.31B of its updated LRA, the “Parameters Monitored or Inspected” 

program element describes a methodology for identifying parameters to monitor for each 

in-scope structure. The methodology includes three “Stages” of analysis or evaluation, 

one or more of which will be applied to each structure, that will result in threshold 

parameters to monitor, each with threshold limits (i.e., monitoring acceptance criteria), 

and a specified monitoring frequency depending on the “Stage” of analysis that was 

applied to the structure. The applicant stated that “[a] set of monitoring elements 

(consisting of strain measurements, deformation measurements, seismic gap 

measurements, and/or other quantifiable behaviors) is established along with threshold 

limits for each monitoring element.” The building deformation monitoring frequency for 

structures for each stage are provided in Table 1 of Enclosure 4 of the August 9, 2016, 

submittal. 

The staff reviewed implementing documentation for the Building Deformation monitoring 

program and interviewed cognizant staff. The staff noted that the program does not 

have one set of parameters monitored or acceptance criteria, but that the applicant 

establishes a set of parameters to monitor and acceptance criteria for each structure. 

The staff also noted that the baseline structural evaluations to establish the criteria for 

each structure’s individual building deformation monitoring were not complete for all 

structures in the scope of the program, and therefore the applicant could not provide the 

parameters monitored and monitoring method(s) for all of the structures. The staff was 

also not provided comprehensive documentation of the process for performing the 

evaluations, including, but not limited to: (1) a detailed list of the possible monitoring 

parameters and monitoring method(s) for those parameters; (2) the process for 

determining what stage of analysis will be used for a given structure; (3) the process for 

determining that another analysis (different stage) is necessary; and (4) the process for 
- 10 - 

selecting what parameters will be monitored and their monitoring method(s). For 

example, the section titled “Stage Two: Analytical Evaluation” states that “additional 

inspections are performed to measure structural strains and deformations at a broader 

range of critical locations of the structure.” It is not clear to the staff whether there is a 

procedure for performing the additional inspections, including location and number of 

additional inspections, or a repeatable process for determining when adequate 

information has been gathered. 

Without either the list of parameters monitored for each structure or comprehensive 

understanding of the procedures and methodology for determining the parameters to be 

monitored and monitoring method(s) such that it is clear that the process is repeatable, 

the staff is not able to verify that the “parameters monitored or inspected” and “detection 

of aging effects” program elements are adequate in accordance with the SRP-LR. The 

staff may request that the applicant provide, for each structure, a list of parameters 

monitored and their monitoring method(s), or provide a comprehensive discussion of the 

processes and procedures for determining the parameters to monitor and monitoring 

method(s) for structures within the scope of the Building Deformation Program in a 

manner that would demonstrate repeatability of the process. 

Aging Management Review (AMR) 

The staff also identified the need for additional information applicable to the applicant’s 

AMR. NRC regulations in 10 CFR 54.21(a)(3) state that for each structure and 

component (SC) subject to an AMR, as identified in an applicant’s integrated plant 

assessment, the applicant must demonstrate that the effects of aging will be adequately 

managed so that the intended function(s) will be maintained consistent with the CLB for 

the period of extended operation. The applicant stated in the “Scope of Program” 

program element that the Building Deformation AMP “provides for management of the 

effect of building deformation on Seismic Category 1 structures and associated 

components within the scope of license renewal. Program scope includes components 

within the scope of license renewal contained in concrete structures within the scope of 

the Structures Monitoring Program.” However, the LRA submittal does not include 

Table 2 AMR line items for those components. 

It is not clear whether the applicant identified whether building deformation would result 

in aging effects not previously considered in the LRA and if the applicant evaluated the 

need to revise the LRA AMR tables associated with the affected SCs such that 

management for this aging effect would be captured in the LRA. In addition, it is not 

clear if the other program(s) that manage any affected components employ the methods 

and frequency of inspection to bound those of the Building Deformation program to 

ensure adequate aging management for affected components. 

Therefore, the staff may consider requesting that the applicant provide the results of any 

evaluation in accordance with the requirements of 10 CFR 54.21(a) that demonstrates 

that for all SCs affected by building deformation caused by ASR expansion, that either 

(1) the Building Deformation program will specifically inspect and manage for the effects 

of building deformation; (2) building deformation will not result in behavior of supported 

SCs that was not previously considered; or (3) the other AMPs that manage aging of the 
- 11 - 

SCs are adequate to ensure that the effects of building deformation do not prevent the 

SCs from performing their intended functions. 

2.3 Exit Meeting 

A final briefing was held with the applicant on October 27, 2016, to discuss the results of the 

ASR Monitoring and Building Deformation Monitoring AMP audit. 

3. AUDIT PARTICIPANTS 

NRC 

- Brian Wittick, Branch Chief, DLR, NRR 

- Angela Buford, Audit Team Lead, DLR, NRR 

- George Thomas, Senior Structural Engineer, DLR, NRR 

- Bryce Lehman, Structural Engineer, DE, NRR 

- Benjamin Beasley, Acting Deputy Director, DLR, NRR 

NextEra and Contractors 

- Ken Browne, NextEra Energy Seabrook (NEE-SBK) 

- Edward Carley, NEE-SBK 

- Brian Brown, NEE-SBK 

- Jaclyn Hulbert, NEE-SBK 

- John W. Simons, MPR Associates (MPR) 

- Jim Moroney, MPR 

- Amanda Card, MPR 

- Said Bolourchi, Simpson, Gumpertz and Heger (SGH) 

- Ryan M. Mones, SGH 

- Liying Jiang, SGH 

- Robert Schofield, Enercon