UNITED STATES

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

October 13, 2016 

Mr. Eric McCartney 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300 

Seabrook, NH 03874 

SUBJECT: REGULATORY AUDIT PLAN - ALKALI SILICA REACTION AGING 

MANAGEMENT PROGRAM, REGARDING SEABROOK STATION, UNIT 1, 

LICENSE RENEWAL APPLICATION REVIEW (CAC NO. ME4028) 

Dear Mr. McCartney: 

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

renewal of operating license No. NPF-86 for the Seabrook Station, Unit 1. The staff of the U.S. 

Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance 

with the guidance in NUREG-1800, “Standard Review Plan for Review of License Renewal 

Applications for Nuclear Power Plants.” 

The staff plans to conduct its regulatory audit of the Alkali-Silica Reaction Aging Management 

Program (AMP) during the week of October 24, 2016, in accordance with the enclosed 

regulatory audit plan. This audit was discussed with Mr. Kenneth Browne and Mr. Edward 

Carley of your staff. 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/ 

 

 

 Tam Tran, Project Manager 

 Projects Branch 1 

 Division of License Renewal 

 Office of Nuclear Reactor Regulation 

Docket No. 50-443 

Enclosure: 

Audit Plan 

cc w/encl: Listserv 
Mr. Eric McCartney 

Site Vice President 

NextEra Energy Seabrook, LLC 

P.O. Box 300 

Seabrook, NH 03874 

SUBJECT: REGULATORY AUDIT PLAN - ALKALI SILICA REACTION AGING 

MANAGEMENT PROGRAM, REGARDING SEABROOK STATION, UNIT 1, 

LICENSE RENEWAL APPLICATION REVIEW (CAC NO. ME4028) 

Dear Mr. McCartney: 

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

renewal of operating license No. NPF-86 for the Seabrook Station, Unit 1. The staff of the U.S. 

Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance 

with the guidance in NUREG-1800, “Standard Review Plan for Review of License Renewal 

Applications for Nuclear Power Plants.” 

The staff plans to conduct its regulatory audit of the Alkali-Silica Reaction Aging Management 

Program (AMP) during the week of October 24, 2016, in accordance with the enclosed 

regulatory audit plan. This audit was discussed with Mr. Kenneth Browne and Mr. Edward 

Carley of your staff. 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/ 

 Tam Tran, Project Manager 

 Projects Branch 1 

 Division of License Renewal 

 Office of Nuclear Reactor Regulation 

Docket No. 50-443 

Enclosure: 

Audit Plan 

cc w/encl: Listserv 

DISTRIBUTION: See next page 

ADAMS Accession Number: ML16277A549

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box “C” = Copy without attach/encl, “E” = Copy with attach/encl, “N” = No copy 

OFFICE LA:RPB1:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR 

NAME IBetts* TTran* YDiaz-Sanabria* TTran 

DATE 10/ 11 /16 10/ 11 /16 10/ 12 /16 10/ 13 /16 

OFFICIAL RECORD COPY 
Letter to E. McCartney from T. Tran Dated October 13, 2016 

SUBJECT: REGULATORY AUDIT PLAN - ALKALI SILICA REACTION AGING 

MANAGEMENT PROGRAM, REGARDING SEABROOK STATION, UNIT 1, 

LICENSE RENEWAL APPLICATION REVIEW (CAC NO. ME4028) 

DISTRIBUTION: 

HARD COPY: 

DLR RF 

E-MAIL: 

RidsNrrDlrRpb1 Resource 

RidsNrrDlrRarb Resource 

RidsNrrDlrRasb Resource 

RidsNrrDlrRerp Resource 

RidsOgcMailCenter Resource 

Rids NrrMailCenter Resource 

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

Lois.James@nrc.gov 

Tam.Tran@nrc.gov 

Kevin.Folk@nrc.gov 

Brian.Wittick@nrc.gov 

Justin.Poole@nrc.gov 

David.Mclntyre@nrc.gov 

Eugene.Dacus@nrc.gov

Brian.Harris@nrc.gov 

Mel.Gray@nrc.gov 

Fred.Bower@nrc.gov

Paul.Cataldo@nrc.gov 

Rich.Barkley@nrc.gov 

Chris.Lally@nrc.gov 

Christopher.Newport@nrc.gov 

Christopher.Highley@nrc.gov 

Doug.Tifft@nrc.gov 

Neil.Sheehan@nrc.gov 

Diane.Screnci@nrc.gov 
ENCLOSURE 

Audit Plan 

Alkali-Silica Reaction Aging Management 

Program Review for the Seabrook Station, Unit 1 

License Renewal Application 

OCTOBER 24, 2016

Division of License Renewal 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

 
- 2 - 

Alkali-Silica Reaction Aging Management Program Audit Plan 

Seabrook Station, Unit 1

1. Background 

By letter dated May 25, 2010, NextEra Energy Seabrook (NextEra or the applicant) submitted to 

the U.S. Nuclear Regulatory Commission (NRC or the staff) its application for renewal of its 

operating license for Seabrook Station, Unit 1 (Seabrook). The applicant 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 Alkali-Silica Reaction (ASR) Monitoring program to 

manage the effects of aging due to ASR. The NRC staff conducted audits of the plant-specific 

ASR Monitoring program in November 2013 and October 2015. On April 28, 2016, the staff and 

NextEra conducted a public meeting to discuss submittal expectations associated with staff’s 

review of ASR aging management programs (AMPs), and NextEra subsequently submitted a 

revision to the license renewal application (LRA) regarding the ASR Monitoring Program. This 

revision was submitted to the NRC by letter dated August 9, 2016, 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 Aging Management Program.” 

Staff from the Office of Nuclear Reactor Regulation will conduct a regulatory audit, in 

accordance with LIC-111 “Regulatory Audit,” to (1) gain a better understanding of revisions to 

the applicant’s ASR Monitoring AMP and (2) review supporting documentation and technical 

bases information for the applicant’s new Building Deformation AMP. 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 with open items (ADAMS Accession No. ML12160A374). Consistent with LIC-111, an 

Audit Summary will be provided to NextEra within 90 days following the audit. 

2. Regulatory Audit Bases 

License renewal requirements are specified in Title 10 of the Code of Federal Regulations

(10 CFR) Part 54 (10 CFR Part 54), “Requirements for Renewal of Operating Licenses for 

Nuclear Power Plants.” 10 CFR 54.17, “Filing of Application,” requires applicants for renewed 

licenses to send written correspondence to the NRC. 10 CFR 54.37, “Additional Records and 

Record Keeping Requirements,” requires that license renewal applicants maintain documents 

demonstrating compliance with the requirements of 10 CFR Part 54 in auditable and retrievable 

form. During review of an LRA, there may be supporting information retained as records under 

10 CFR 54.37 that, although may not necessarily be required to be submitted as part of the 

LRA, provide additional information and technical bases for the submitted information, and 

therefore the staff may determine an audit is necessary. Staff guidance is provided in NUREG1800, Revision 2, “Standard Review Plan for Review of License Renewal Applications for 

Nuclear Power Plants” (SRP-LR), dated December 2010, and in NUREG-1801, Revision 2, 

“Generic Aging Lessons Learned (GALL) Report,” dated December 2010. 
- 3 - 

3. Regulatory Audit Scope and Methodology 

The scope of this audit is to examine the applicant’s supporting documentation for LRA AMPs 

B.2.1.31A and B.2.1.31B. These plant-specific AMPs will be evaluated for the 10 program 

elements in accordance with the guidance provided in SRP-LR Appendix A.1 “Aging 

Management Review Branch Technical Position RLSB-1.” The SRP-LR states that an applicant 

can choose to establish one or more plant-specific AMPs. It is incumbent on the applicant to 

ensure that the plant program contains adequate descriptions and depth of bases for all 10 

elements of the AMP. 

During this audit, the staff will examine the applicant’s program basis documents and related 

references for the AMPs, review supporting calculations and evaluations, conduct related 

walkdowns as needed, and interview applicant representatives to obtain additional clarification 

related to the AMP. The staff will also assess whether it needs additional information to be 

submitted to the NRC in support of the AMPs. 

The scope of this audit includes the following tasks (i.e., audit needs) to support the staff’s 

review of adequacy of the ASR Monitoring Program and new Building Deformation Program. 

The audit will include an entrance meeting (introductions and review of scheduling of breakout 

sessions, document review, and walkdowns) and an exit meeting to discuss any outstanding 

issues. 

- Review of ASR Monitoring Program implementation to date, including review of 

associated procedures and crack measurement results to-date. This review consists of 

document review, interviews with cognizant personnel, and walkdown of areas that have 

installed extensometers in accordance with the program. 

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

deformation in the residual heat removal and core spray equipment vault and 

methodology/plans for aging management. This review consists of document review 

and interviews with cognizant personnel, as well as walkdown of the affected area. 

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

methodology/plans for aging management of containment and containment enclosure 

building (CEB). This review consists of document review and interviews with cognizant 

personnel, as well as walkdown of the affected area. 

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

deformation in the fuel storage building and methodology/plans for aging management. 

This review consists of document review and interviews with cognizant personnel, as 

well as walkdown of the affected area. 

- If available and applicable, review of a complete analysis that has followed the ASR 

AMP methodology, including finite element analysis input and results; and consideration 

of the three-stage evaluation process approach to building deformation analysis (e.g. 

CEB). This review consists of document review and interviews with cognizant 

personnel. 

(The Seabrook LRA indicated that computational analysis (e.g., computer simulation) will 

be used to manage the ASR AMP. NextEra will inform the staff early whether or not 
- 4 - 

these analyses are available for review so that staff may arrange for appropriate 

reviewer(s) to be available for this review during the audit.) 

- Review of calculations, evaluations, analyses, procedures, and any supporting 

information related to the determination of internal strain and/or external loads 

contributing to the “Sa” ASR factor that will be added to finite element models of 

structures affected by building deformation. In addition, information regarding if, when, 

and how the “Sa” factor would be recalculated. This review consists of document review 

and interview with cognizant personnel. 

- Demonstration of how the AMP takes into account irreversible plastic deformation of 

rebar consistent with the current licensing basis. This review consists of document 

reviews and interview with cognizant personnel. 

- Methodology and results of the stage 1 “susceptibility analysis” process. This review 

consists of document review and interviews with cognizant personnel. 

Based on the results of the audit, staff will identify what, if any, information would need to be 

submitted on the docket subsequent to the audit, as supplements to the LRA or response to 

the request for additional information. This will be discussed during the exit meeting. 

4. Special Requests 

For a successful outcome, the staff requests that: 

(1) at least one hard copy of relevant materials be available to the staff in addition to 

electronic files 

(2) availability of a projector to facilitate information exchange to the entire group (when 

such exchange is necessary) 

(3) availability of cognizant technical staff for interview and walkdown 

(4) internet access (not necessary to allow access to NextEra/Seabrook internal sites) 

(5) reviewing staff be granted unescorted access for feasibility and efficiency of access to 

working area, not necessarily to perform unescorted walkdowns, and consistent with site 

requirements. 

5. Team Assignments 

NRC staff participation is projected as follows (some deletions, additions, or substitutions may 

occur on an as-needed basis): 

Area of Review Assigned Auditor 

Project Manager Tam Tran 

Technical Lead Angela Buford, Structural Engineer 

Technical Reviewer George Thomas, Senior Structural Engineer 

Technical Reviewer Bryce Lehman, Structural Engineer 

Management Benjamin Beasley, Acting Deputy Director 

Management Brian Wittick, Branch Chief 

 
- 5 - 

6. Logistics 

The audit will be conducted on location at the Seabrook site, with rooms and space to be 

provided by NextEra. Working hours are from 8:00 am to 4:30 pm. Further daily logistics items 

or revisions will be coordinated with the Seabrook project manager (and appropriate Seabrook 

management) during a daily debrief, as necessary.