UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

December 12, 2016

Mr. Eric McCartney

Site Vice President

NextEra Energy Seabrook, LLC

P.O. Box 300, Lafayette Road

Seabrook, NH 03874

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION LICENSE RENEWAL APPLICATION (CAC NO. 

ME4028)

Dear Mr. McCartney:

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

pursuant to 10 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 15 days from the date of this letter. If you have any 

questions, please contact me at (301) 415-3617 or e-mail Tam.Tran@nrc.gov.

Sincerely,

/RA/

Tam Tran, Project Manager

License Renewal Branch, RPB1

Division of License Renewal

Office of Nuclear Reactor Regulation

50-443

Enclosure: 

Requests for Additional Information

cc w/encl: See next page
Mr. Eric McCartney

Site Vice President

NextEra Energy Seabrook, LLC

P.O. Box 300, Lafayette Road

Seabrook, NH 03874

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION LICENSE RENEWAL APPLICATION (CAC NO. 

ME4028)

Dear Mr. McCartney:

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

pursuant to 10 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 15 days from the date of this letter. If you have any 

questions, please contact me at (301) 415-3617 or e-mail Tam.Tran@nrc.gov.

Sincerely,

Tam Tran, Project Manager

License Renewal Branch, RPB1

Division of License Renewal

Office of Nuclear Reactor Regulation

50-443

Enclosure: 

Requests for Additional Information

cc w/encl: Listserv

DISTRIBUTION: See following pages

ADAMS Accession No.: ML16326a037

(*) concurred by e-mail

Publicly Available Non-Publicly 

A il bl 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 PM:RPB1:DLR BC:RASB:DLR BC:RPB1:DLR OGC PM:RPB1:DLR

NAME TTran* Brian Wittick* RChazell* *JWatchuka TTran

DATE 12/06/2016 12/06/2016 12/12/2016 12/07/2016 12/12/2016

OFFICIAL RECORD COPY
-2- Enclosure

SEABROOK STATION

LICENSE RENEWAL APPLICATION (LRA)

REQUESTS FOR ADDITIONAL INFORMATION (RAI)

RAI B.2.1.31A-A1 (PARAMETERS MONITORED OR INSPECTED)

Background

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 also states that the parameter 

monitored or inspected should be capable of detecting the presence and extent of aging effects. 

In its August 9, 2016, submittal, the applicant stated under the Section B.2.1.31A “Parameters 

Monitored or Inspected” program element that “initial screening for ASR [expansion] will be 

performed using combined cracking index (CCI) only and CCI values exceeding 1 mm/m will 

trigger additional actions.” The program also states that the large-scale test program conducted 

at the University of Texas indicated that direction of expansion is not significantly affected by the 

reinforcement when expansion is at or below 1 mm/m but that “beyond this level, throughthickness expansion dominates.” The staff noted in the “Acceptance Criteria” program element 

that 1 mm/m is the threshold for “Tier 3” and subject to enhanced ASR monitoring, such as 

through-wall expansion monitoring using Extensometers. The “Parameters Monitoring or 

Inspected” program element states that the periodic extensometer measurements of throughthickness expansion is the parameter to be monitored when an ASR location reaches the Tier 3 

monitoring criteria. 

The August 9, 2016, letter states that CCI is also used to measure the effects of associated 

rebar strain.

Issue

During its onsite audit the staff reviewed program basis information and reviewed 

implementation of the ASR Monitoring program to date, including the CCI monitoring at Tier 2 

locations and the through-wall extensometer measurements at “Tier 3” locations. The staff 

noted that the through-wall monitoring acceptance criteria values were based on the large-scale 

testing program results, and that the tests considered volumetric expansion (i.e. in the 

horizontal, vertical, and through-wall directions), and not just the through-wall expansion. From 

the staff’s review of the program, it is not clear to the staff whether the program considers the 

volumetric expansion, and whether strain in the horizontal and vertical directions is monitored, 

once a location is placed into the “Tier 3” category. Further, the staff noted that (a) the applicant 

has completed some of its core testing from Seabrook structure locations for installation of 

extensometers and (b) there have been variations in crack distribution depending on the 

location of the core such that in-plane strain may not be “insignificant” compared to out-of-plane 

expansion, contrary to the applicant’s claim. From its review of the “Acceptance Criteria” 

program element, the staff noted that acceptance criteria for volumetric expansion did not 

appear to be included. 
-3- Enclosure

In addition, it is not clear how the program explicitly uses CCI to “measure the effects of rebar 

strain due to ASR expansion” as is stated in the August 9, 2016 submittal.

Request

1. Considering (a) variations in boundary conditions of Seabrook structures compared to 

large-scale test beams and (b) results of plant-specific information regarding in-plane vs. 

out-of-plane expansion-to-date of concrete cores taken at Seabrook, state whether 

additional parameters such as volumetric expansion will be monitored such that ASR 

expansion effects are captured in their totality; or provide additional information 

supporting the use of through-wall monitoring as the only monitoring parameter for “Tier 

3” ASR locations. If volumetric expansion will be monitored, explain how this will be 

accomplished.

2. State how the program will use CCI to manage ASR-induced rebar strains and stresses 

such that they remain within design code limits, by the ASR-induced strains alone and in 

combination with design basis loads and load combinations, during the period of 

extended operation.

RAI B.2.1.31A-A2 (DETECTION OF AGING EFFECTS)

Background

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). 

Issue

The “Detection of Aging Effects” program element in the revised LRA Section B.2.1.31A of the 

August 9, 2016, submittal (including “Out-of-Plane Expansion” and “Snap-Ring Borehole 

Extensometers” sections) does not specify the inspection interval planned for monitoring 

through-wall expansion using snap-ring borehole extensometers. 

Request

Regarding the use of snap-ring borehole extensometers, clarify the methods and frequencies of 

inspection(s) for “Tier 3” monitoring locations and update the aging management program 

(AMP) as necessary.

RAI B.2.1.31A-A3 (ACCEPTANCE CRITERIA) 

Background

Section B.2.1.31A of the applicant’s updated LRA submittal dated August 9, 2016, states in the 

Element 6 – Acceptance Criteria section, “[a] structural evaluation is needed when the CCI 

reaches what is classified as Tier 3 (CCI > 1mm/m).” 

Issue

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 an analysis in accordance with the deformation program 
-4- Enclosure

(B.2.1.31B). Also, it is not clear what evaluation would be performed if the structure is not within 

the scope of B.2.1.31B and whether all structures within B.2.1.31B receive an analysis 

regardless of CCI.

Request

State whether the term “structural evaluation” in Section B.2.1.31A refers to an analysis in 

accordance with the deformation program (B.2.1.31B). State what evaluation would be 

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

B.2.1.31B receive an analysis regardless of CCI. If not, provide technical justification.

RAI B.2.1.31A-A4 (OPERATING EXPERIENCE)

Background:

SRP-LR Section A.1.2.3.10 states that an applicant should commit to a future review of plantspecific and industry operating experience to confirm the effectiveness of its aging management 

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

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 in-plane 

direction plateaus at low expansion levels, while expansion in the through-thickness 

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-4153, which was submitted to the staff.

The “Operating Experience” program element states “Seabrook will update the Aging 

Management Program for any new plant-specific or industry OE”

Issue:

The applicant’s above statements indicate that there is an assumption or hypothesis 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 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 4153 should be corroborated or validated. It is not 

clear whether the applicant plans to corroborate or validate, over sufficient time and prior 
-5- Enclosure

to PEO, such that the behaviors observed due to ASR in the testing specimens and 

assumed to correlate to Seabrook concrete are consistent.

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

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 program 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.

Request:

Explain whether and how the ASR Monitoring program 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. If the ASR Monitoring program is not expected to 

corroborate or validate these assumptions, provide the technical basis for these assumptions.

RAI B.2.1.31B-B1 (SCOPE OF PROGRAM)

Background

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.

Issue

During its onsite audit, the staff reviewed implementing documentation and a list of structures to 

be evaluated under the Building Deformation program and found discrepancies between the 

structures listed on 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 is not consistent between Section B.2.1.31A 

and Section B.2.1.31B; specifically, why the non-category I structures in the ASR Monitoring 

Program are not included in the Building Deformation Program. 

Request

Confirm whether the seismic Category 1 Control Building, Diesel Generator Building, and 

Service Water Access (Inspection) Vault are included in the Building Deformation Program. If 
-6- Enclosure

they are not included, explain why not. In addition, explain why the non-category I structures in 

the ASR Monitoring Program are not included in the Building Deformation Program.

RAI B.2.1.31B-B2 (PARAMETERS MONITORED OR INSPECTED, DETECTION OF AGING 

EFFECTS)

Background

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 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 structure and component (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.

The applicant’s Building Deformation AMP in Section B.2.1.31B of its August 9, 2016, submittal 

“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 “acceptance criteria” program 

element states that a systematic approach to evaluation [Stage 1, 2, or 3 process] of structures 

impacted by ASR expansion and building deformation is utilized to evaluate ASR and CLB load 

combinations to validate compliance with structural design code requirements.

Issue

During its onsite audit, 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 
-7- Enclosure

scope of the program, and therefore the applicant could not provide the parameters monitored 

and monitoring method(s) for all of the structures that are in scope of license renewal (i.e., that 

have license renewal intended functions). The staff was also not provided comprehensive 

documentation of the process for performing the evaluations, including, but not limited to: (a) a 

detailed list of the possible monitoring parameters and monitoring method(s) for those 

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

structure; (c) the process for determining that another analysis (different stage) is necessary; 

and (d) the process for selecting what parameters will be monitored and their monitoring 

method(s). 

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 (a) there is a procedure for performing the 

additional inspections, including location and number of additional inspections or (b) 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 their 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.

Request

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. As a 

minimum, the discussion of the process should address the items listed in the “Issue” section 

above.

RAI 3.5-A1 (AGING MANAGEMENT REVIEW)

Background

10 CFR 54.21(a)(3) states that for each structure and component (SC) subject to an aging 

management review (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’s letter dated August 9, 2016, states in the “Scope of Program” program element 

that the Building Deformation aging management program “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.”

Issue
-8- Enclosure

The applicant’s August 9, 2016, submittal does not include Table 2 AMR line items for SCs that 

may be subject to aging effects of building deformation, including supported SCs. Since 

building deformation (i.e., global manifestations of ASR expansion) is being managed by the 

Building Deformation program, it is not clear whether the applicant evaluated the need to revise 

the AMR tables associated with the affected SCs and identify whether building deformation 

would result in aging effects not previously considered in the license renewal application (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.

Request

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

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

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

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

performing their intended functions.
-9- Enclosure

SUBJECT: REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE 

SEABROOK STATION, LICENSE RENEWAL APPLICATION

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

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

Anita.Ghosh@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