View source for SBK-L-17133, Clarification to Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program

{{Adams
| number = ML17223A022
| issue date = 08/11/2017
| title = Clarification to Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program
| author name = Mccartney E
| author affiliation = NextEra Energy Seabrook, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000443
| license number = 
| contact person = 
| case reference number = SBK-L-17133
| document type = Letter type:SBK, Response to Request for Additional Information (RAI)
| page count = 30
| project = 
| stage = Response to RAI
}}

=Text=
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SEABROOK August 11, 2017 10CFR54 Docket No. 50-443 SBK-L-17133 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington , DC 20555-0001 Seabrook Station Clarification to Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program

==References:==
: 1. NextEra Energy Seabrook LLC, letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010 (Accession Number ML101590099).
: 2. NextEra Energy Seabrook LLC, letter SBK-L-12258, "LRA Commitment Update and RAI B.1.4-4 Clarification," December 10, 2012 (Accession Number ML12349A214).
: 3. NRC, "Final Request for Additional Information Regarding Seabrook License Renewal Application - Set 26 (CAC NO. ME4028), RAI B.2 .1.9 Bolting Integrity, "
May 24, 2017 (Accession Number ML17139B835).
: 4. NextEra Energy Seabrook LLC, Letter SBK-L-17103, "Supplement 55 - Response to Request for Additional Information for the Review of Seabrook Station License Renewal Application - Bolting Integrity Program ," June 20, 2017 (Accession Number ML17173A065).
In Reference 1, NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in NextEra Energy Seabrook, LLC P.O. Box 300, Lafayette Road , Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-17133 I Page 2 accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.
In Reference 2, NextEra Energy Seabrook submitted letter SBK-L-12258, which revised License Renewal Application Appendix A, A.2.1.9, and Appendix B, B.2.1.9 .
In Reference 3, the NRC requested additional information (RAI) related to NextEra Energy Seabrook's Bolting Integrity Program and how the aging effects for closure bolting associated with air filled, gas filled, and systems at atmospheric pressure will be managed.
In Reference 4, NextEra Energy Seabrook submitted letter SBK-L-17103, responding to the Request for Additional Information in Reference 3.
On July 11, 2017, the NRC Staff and NextEra Energy Seabrook had a clarification call discussing the response (SBK-L-17103) to the Bolting Integrity RAI set in Reference 3. of this letter clarifies the RAI response provided within SBK-L-17103. provides the revised License Renewal Application (LRA), Appendix B -
Aging Management Programs, B.2 .1.9 - Bolting Integrity.
To facilitate understanding, the changes are explained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and balded italics for inserted text.
This letter contains one new Commitment, #51 . Enclosure 3 provides the revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List.
If there are any questions or additional information is needed, please contact Mr.
Edward J. Carley, Engineering Supervisor - License Renewal, at (603) 773-7957.
If you have any questions regarding this correspondence, please contact Mr. Kenneth Browne, Licensing Manager, at (603) 773-7932.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on August      IQ      , 2017 .
Sincerely, NextEra Energy Seabrook, LLC
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U.S. Nuclear Regulatory Commission SBK-L-17133 I Page 3 : Clarification to Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program : Revised License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity : Revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List cc:    D. H. Dorman         NRC   Region I Administrator J.C. Poole         NRC   Project Manager P. C. Cataldo        NRC   Senior Resident Inspector L. M. James          NRC   Project Manager, License Renewal Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 perry.plummer@dos.nh.gov Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 John. Giarrusso@massmail .state. ma. us

Enclosure 1 to SBK-L-17133 Clarification to Supplement 55 - Response to Request for Additional Information for the Review of the Seabrook Station License Renewal Application - Bolting Integrity Program

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 1IPage2 On June 20, 2017, NextEra Energy Seabrook submitted letter SBK-L-17103 to supplement the License Renewal Application. The letter responded to a Request for Additional Information (RAI) on the station's License Renewal Bolting Integrity Program and how the aging effects for closure bolting associated with air filled, gas filled, and systems at atmospheric pressure will be managed. On July 11, 2017, the Staff and NextEra Energy Seabrook had a clarification call discussing the response to the RAI set. The response provided herein supersedes the previous response provided in SBK-L-17103.
RAI # B.2.1.9-3

===Background===
Section 54.21(a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21(a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.
GALL Report AMP Xl.M18 states:
Degradation of pressure boundary closure bolting due to crack initiation, loss of preload, or loss of material may result in leakage from the mating surfaces or joint connections of pressure boundary components. Periodic inspection of pressure boundary components for signs of leakage ensures that age-related degradation of closure bolting is detected and corrected before component leakage becomes excessive. Accordingly, pressure retaining bolted connections should be inspected at least once per refueling cycle.
LRA Section B.2.1.9 states that the Bolting Integrity program "includes periodic inspection of closure bolting assemblies to detect signs of leakage that may be indicative of loss of preload ...
Periodic inspection of bolted closures in conjunction with the Seabrook Station In Service Inspection Program and Seabrook Station External Surfaces Monitoring Program will detect the aging effects and joint leakage." The LRA states that the External Surfaces Monitoring and In Service Inspection Programs use visual inspections to detect leakage which could indicate a loss of preload for closure bolting.
Issue While the staff notes that visual inspections will be capable of detecting leakage of liquid filled systems, a visual inspection may not be sufficient to detect leakage for air- or gas filled systems.
LRA Table 3.3.2-8, "Containment Online Purge System," and 3.3.2-20, "Instrument Air System,"
are examples of systems that cite the Bolting Integrity Program to manage aging effects associated with closure bolting that could be or are air-filled or gas-filled. Based on a review of LRA Section B.2.1.9 and SER with Open Items Section 3.0.3.1.7, "Bolting Integrity," it is not clear how aging effects for closure bolting installed in air-filled or gas-filled systems will be effectively managed because in these systems there is typically limited or no visual signs of leakage.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure I I Page 3 NRC Request #1 For air-filled systems, gas-filled systems, and systems at internal atmosphere pressure for which aging effects for closure bolting will be managed by the Bolting Integrity Program, state how the aging effects will be managed.
NextEra Energy Seabrook's Response to RAI B.2.1.9-3, Request #1 Seabrook will manage aging effects for the Bolting Integrity Program closure bolting in air and gas filled systems by using an applicable inspection technique that ensures the integrity of bolted joints will be demonstrated. These inspection techniques will be one of the following:
Visual inspection for discoloration when the inside environment would discolor the external surface of the pipe if leakage would occur.
Monitoring and trending of pressure decay when the bolted connection is within an isolable boundary.
Soap like solution to promote surface bubbling.
Thermography when the piping's internal fluid temperature is higher than the ambient environment.
Operations personnel will identify and monitor leaks as part of their routine walk downs. Plant Engineering also perform system walkdowns which also provides an opportunity to discover bolted joint leakage.
For Bolting Integrity Program closure bolting associated with systems at internal atmospheric pressure, Seabrook will perform a tightness check on 20 percent of in scope bolts with a maximum of 25 bolts per population. Populations will be of the same material and environment combination. Inspections will occur before the period of extended operation (PEO}, and then every 10 years after the initial inspection date. By checking the tightness of these closure bolting samples, the inspections verify that potential loss of material, loss of preload, or cracking is not occurring.
The revised License Renewal Application, Appendix B -Aging Management Programs, B.2.1.9
- Bolting Integrity, Program Description and Enhancements sections, are provided within  of this letter.
NRC Request #2 State any enhancements to plant-specific procedures and/or to the Bolting Integrity Program necessary to incorporate how these aging effects will be managed.
NextEra Energy's Seabrook Response to RAI B.2.1.9-3, Request #2 The revised License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9
- Bolting Integrity, Program Description and Enhancements sections, are provided within  of this letter.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 1IPage4 Commitment #51 is used to track the enhancements provided in Enclosure 2, and Enclosure 3 provides the revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List.
E1th{[1tce the program to lll{[lt([ge the
{[gi11g effects for closure bolti11g wit/tin (fir mu/ g{[s filled systems by using (Ill
{[pp/iC(lb/e i11spectio11 teclt11ique tlwt e11sures the integrity of bolted joints will be demonstrated.
For closure bolting wit/tin systems (If                   Prior to the period Bolting Integrity   {[fmosplteric pressure, tigltt11ess checks        A.2.1.9 of extended 51 will be pe1for111ed 011 20 percent of bolts               operation.
with {[ 11wximu111 of 25 bolts per pop11/{[fio11. Popu[{[tions will be of the smne 111([/erfol m1d e11viro11me11t combilwtio11. J11spectio11s will occur before the period of extended operation,
{[lid tit en every I 0 ye{[rs <ifter the i11itfol inspection <fote.

Enclosure 2 to SBK-L-17133 Revised License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 2 I Page 2 Enclosure bolting of air filled, gas filled, and systems at atmospheric pressure within the Bolting Integrity program will have the appropriate aging management. As transmitted previously in SBK-L-12258 (Reference 2), and in SBK-L-17103 (Reference 4), the second paragraph of Seabrook Station's License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity, Program Description, is revised below.
The program includes periodic inspection of closure bolting assemblies to detect signs of leakage that may be indicative of loss of preload, loss of material, or crack initiation. Leak detection inspections are performed on in scope closure bolting in air filled and gas filled systems using a method that detects leakage. Prior to the period of extended operation, readily accessible in scope closure bolting within systems at internal atmospheric pressure will have a tightness check performed. Tightness checks will be perlormed on 20 percent of bolts with a maximum of 25 bolts per population. Populations will be of the same material and environment combination. Inspections will occur before the period of extended operation (PEO), and then every 10 years after the initial inspection date.
Periodic inspections of bolted closures in conjunction with the Seabrook Station lnservice Inspection Program and Seabrook Station External Surfaces Monitoring Program, will detect the aging effects and joint leakage. Operator rounds and system walkdowns will also identify joint leakage. Bolted connections in buried, underground, and inaccessible submerged piping will be inspected for indication of leakage caused by loss of preload when the associated piping is inspected by the Buried Piping and Tanks Inspection program. In instances where hydrostatic testing, flow testing, or fire protection jockey pump monitoring are used in lieu of visual inspections, these methods will also be credited to identify leakage caused by loss of preload at bolted connections. Additionally, the service water pump column bolted connections are submerged in raw water and cannot be inspected for leakage due to loss of preload. Service water pump column bolting will be inspected for loss of material and loss of preload when the service water pumps are removed for maintenance.
The Seabrook Station's License Renewal Application, Appendix B - Aging Management Programs, B.2.1.9 - Bolting Integrity, Enhancements, is revised below. Commitment #51 is used to track the enhancements.
Enhancements The following enhancements will be made prior to entering the period of extended operation.
Seabrook will manage aging effects for the Bolting Integrity Program closure bolting in air and gas filled systems by using an applicable inspection technique that ensures the integrity of bolted joints will be demonstrated. These inspection techniques will be one of the following:
: a.      Visual inspection for discoloration when the inside environment would discolor the external surlace of the pipe if leakage would occur.
: b.      Monitoring and trending of pressure decay when the bolted connection is within an isolable boundary.
: c.      Soap like solution to promote surlace bubbling.
: d.      Thermography when the piping's internal fluid is higher than the ambient environment.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 2 I Page 3 Closure bolting associated with systems at internal atmospheric pressure will have a tightness check performed. Tightness checks will be performed on 20 percent of bolts with a maximum of 25 bolts, per population. Populations will be of the same material and environment combination. Inspections will occur before the period of extended operation (PEO), and then every 10 years after the initial inspection date.
Program Elements Affected: Element 1 (Scope of Program), Element 4 (Detection of Aging Effects).

Enclosure 3 to SBK-L-17133 Revised LRA Appendix A - Updated Final Safety Analysis Report Supplement Table A.3, License Renewal Commitment List

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 2 A.3    LICENSE RENEWAL COMMITMENT LIST UFSAR No.            PROGRAM or TOPIC                                COMMITMENT                                                 SCHEDULE LOCATION Provide confirmation and acceptability of the implementation ofMRP-227-A by addressing the plant-I.       PWR Vessel Internals                                                                        A.2.1.7    Complete specific Applicant/Licensee Action Items outlined in section 4.2 of the NRC SER.
Enhance the program to include visual inspection for Prior to the period of
: 2.       Closed-Cycle Cooling Water      cracking, loss of material and fouling when the in-scope    A.2.1.12 extended operation.
systems are opened for maintenance.
Inspection of Overhead Heavy    Enhance the program to monitor general corrosion on the Prior to the period of
: 3.       Load and Light Load (Related to crane and trolley structural components and the effects of  A.2.1.13 extended operation.
Refueling) Handling Systems     wear on the rails in the rail system.
Inspection of Overhead Heavy Enhance the program to list additional cranes for                      Prior to the period of
: 4.       Load and Light Load (Related to                                                             A.2.1.13 monitoring.                                                            extended operation.
Refueling) Handling Systems Enhance the program to include an annual air quality test Prior to the period of
: 5.       Compressed Air Monitoring       requirement for the Diesel Generator compressed air sub     A.2.1.14 extended operation.
system.
Enhance the program to perform visual inspection of                    Prior to the period of
: 6.       Fire Protection                                                                             A.2.1.15 penetration seals by a fire protection qualified inspector.            extended operation.
Enhance the program to add inspection requirements such as spalling, and loss of material caused by freeze-thaw,               Prior to the period of
: 7.       Fire Protection                                                                             A.2.1.15 chemical attack, and reaction with aggregates by qualified             extended operation.
inspector.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 3 Enhance the program to include the performance of visual Prior to the period of
: 8.       Fire Protection        inspection of fire-rated doors by a fire protection qualified A.2.1.15 extended operation.
inspector.
Enhance the program to include NFPA 25 (2011 Edition) guidance for "where sprinklers have been in place for 50 Prior to the period of
: 9.       Fire Water System      years, they shall be replaced or representative samples       A.2.1.16 extended operation.
from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing".
Enhance the program to include the performance of Prior to the period of
: 10. Fire Water System      periodic flow testing of the fire water system in             A.2.1.16 extended operation.
accordance with the guidance ofNFP A 25 (2011 Edition).
Enhance the program to include the performance of periodic visual or volumetric inspection of the internal surface of the fire protection system upon each entry to the system for routine or corrective maintenance to evaluate wall thickness and inner diameter of the fire protection piping ensuring that corrosion product buildup will not result in flow blockage due to fouling. Where surface irregularities are detected, follow-up volumetric Within ten years prior to the
: 11. Fire Water System      examinations are performed. These inspections will be         A.2.1.16 period of extended operation.
documented and trended to determine if a representative number of inspections have been performed prior to the period of extended operation. If a representative number of inspections have not been performed prior to the period of extended operation, focused inspections will be conducted. These inspections will commence during the ten year period prior to the period of extended operation and continue through the period of extended operation.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 4 Enhance the program to include 1) In-scope outdoor tanks, except fire water storage tanks, constructed on soil or concrete, 2) Indoor large volume storage tanks (greater than 100,000 gallons) designed to near-atmospheric internal pressures, sit on concrete or soil, and exposed internally to water, 3) Visual, surface, and volumetric examinations of the outside and inside surfaces for                   Within 10 years prior to the
: 12.      Aboveground Steel Tanks                                                              A.2.1.17 managing the aging effects of loss of material and cracking,          period of extended operation.
: 4) External visual examinations to monitor degradation of the protective paint or coating, and 5) Inspection of sealant and caulking for degradation by performing visual and tactile examination (manual manipulation) consisting of pressing on the sealant or caulking to detect a reduction in the resiliency and pliability.
Enhance the program to perform exterior inspection of the fire water storage tanks annually for signs of degradation and include an ultrasonic inspection and evaluation of the            Within ten years prior to the
: 13.      Fire Water System                                                                    A.2.1.16 internal bottom surface of the two Fire Protection Water              period of extended operation.
Storage Tanks per the guidance provided in NFPA 25 (2011 Edition).
Enhance program to add requirements to 1) sample and analyze new fuel deliveries for biodiesel prior to Prior to the period of
: 14. Fuel Oil Chemistry      offloading to the Auxiliary Boiler fuel oil storage tank and A.2.1.18 extended operation.
: 2) periodically sample stored fuel in the Auxiliary Boiler fuel oil storage tank.
Enhance the program to add requirements to check for the presence of water in the Auxiliary Boiler fuel oil storage            Prior to the period of
: 15. Fuel Oil Chemistry                                                                   A.2.1.18 tank at least once per quarter and to remove water as                 extended operation.
necessary.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 5 Enhance the program to require draining, cleaning and Prior to the period of
: 16. Fuel Oil Chemistry           inspection of the diesel fire pump fuel oil day tanks on a   A.2.1.18 extended operation.
frequency of at least once every ten years.
Enhance the program to require ultrasonic thickness measurement of the tank bottom during the IO-year draining, cleaning and inspection of the Diesel Generator             Prior to the period of
: 17.      Fuel Oil Chemistry                                                                       A.2.1.18 fuel oil storage tanks, Diesel Generator fuel oil day tanks,          extended operation.
diesel fire pump fuel oil day tanks and auxiliary boiler fuel oil storage tank.
Enhance the program to specify that all pulled and tested Prior to the period of
: 18.      Reactor Vessel Surveillance capsules, unless discarded before August 31, 2000, are       A.2.1.19 extended operation.
placed in storage.
Enhance the program to specify that if plant operations exceed the limitations or bounds defined by the Reactor Vessel Surveillance Program, such as operating at a lower Prior to the period of
: 19. Reactor Vessel Surveillance cold leg temperature or higher fluence, the impact of plant A.2.1.19 extended operation.
operation changes on the extent of Reactor Vessel embrittlement will be evaluated and the NRC will be notified.
Enhance the program as necessary to ensure the appropriate withdrawal schedule for capsules remaining in the vessel such that one capsule will be withdrawn at an outage in which the capsule receives a neutron fluence Prior to the period of
: 20.      Reactor Vessel Surveillance that meets the schedule requirements of 10 CFR 50            A.2.1.19 extended operation.
Appendix H and ASTM E 185-82 and that bounds the 60-year fluence, and the remaining capsule(s) will be removed from the vessel unless determined to provide meaningful metallurgical data.
Enhance the program to ensure that any capsule removed, without the intent to test it, is stored in a manner which            Prior to the period of
: 21.      Reactor Vessel Surveillance                                                              A.2.1.19 maintains it in a condition which would permit its future             extended operation.
use, including during the period of extended operation.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 6 Within ten years prior to the
: 22.      One-Time Inspection                Implement the One Time Inspection Program.                  A.2.1.20 period of extended operation.
Implement the Selective Leaching of Materials Program.
The program will include a one-time inspection of Within five years prior to the 1~
_.)_     Selective Leaching of Materials    selected components where selective leaching has not        A.2.1.21 period of extended operation.
been identified and periodic inspections of selected components where selective leaching has been identified.
Implement the Buried Piping And Tanks Inspection Buried Piping And Tanks            Program.                                                             Within ten years prior to the
: 24.                                                                                                     A.2.1.22 Inspection                                                                                              period of extended operation.
One-Time Inspection of ASME        Implement the One-Time Inspection of ASME Code Class                 Within ten years prior to the
: 25.                                                                                                     A.2.1.23 Code Class 1 Small Bore-Piping     I Small Bore-Piping Program.                                         period of extended operation.
Enhance the program to specifically address the scope of the program, relevant degradation mechanisms and effects Prior to the period of
: 26.      External Surfaces Monitoring       of interest, the refueling outage inspection frequency, the A.2.1.24 extended operation.
training requirements for inspectors and the required periodic reviews to determine program effectiveness.
Inspection of Internal Surfaces in Implement the Inspection oflnternal Surfaces in                      Prior to the period of
: 27.      Miscellaneous Piping and                                                                       A.2.1.25 Miscellaneous Piping and Ducting Components Program.                 extended operation.
Ducting Components Enhance the program to add required equipment, lube oil Prior to the period of
: 28.      Lubricating Oil Analysis           analysis required, sampling frequency, and periodic oil     A.2.1.26 extended operation.
changes.
Enhance the program to sample the oil for the Reactor                Prior to the period of
: 29.      Lubricating Oil Analysis                                                                       A.2.1.26 Coolant pump oil collection tanks.                                   extended operation.
Enhance the program to require the performance of a one-time ultrasonic thickness measurement of the lower                   Prior to the period of
: 30.      Lubricating Oil Analysis                                                                       A.2.1.26 portion of the Reactor Coolant pump oil collection tanks             extended operation.
prior to the period of extended operation.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 7 ASME Section XI, Subsection       Enhance procedure to include the definition of                  Prior to the period of
: 31.                                                                                              A.2.1.28 IWL                              "Responsible Engineer".                                         extended operation.
Enhance procedure to add the aging effects, additional Prior to the period of
: 32.      Structures Monitoring Program    locations, inspection frequency and ultrasonic test    A.2.1.31 extended operation.
requirements.
Enhance procedure to include inspection of opportunity
   ,.,,.,                                                                                                    Prior to the period of
   .).). Structures Monitoring Program    when planning excavation work that would expose        A.2.1.31 extended operation.
inaccessible concrete.
Electrical Cables and Implement the Electrical Cables and Connections Not Connections Not Subject to 10                                                                    Prior to the period of
: 34.                                       Subject to 10 CFR 50.49 Environmental Qualification    A.2.1.32 CFR 50.49 Environmental                                                                          extended operation.
Requirements program.
Qualification Requirements Electrical Cables and Connections Not Subject to 10    Implement the Electrical Cables and Connections Not Prior to the period of
: 35.      CFR 50.49 Environmental          Subject to 10 CFR 50.49 Environmental Qualification    A.2.1.33 extended operation.
Qualification Requirements Used  Requirements Used in Instrumentation Circuits program.
in Instrumentation Circuits Inaccessible Power Cables Not Implement the Inaccessible Power Cables Not Subject to Subject to IO CFR 50.49                                                                          Prior to the period of
: 36.                                       IO CFR 50.49 Environmental Qualification Requirements  A.2.1.34 Environmental Qualification                                                                      extended operation.
program.
Requirements Prior to the period of
: 37.      Metal Enclosed Bus               Implement the Metal Enclosed Bus program.              A.2.1.35 extended operation.
Prior to the period of
: 38.      Fuse Holders                     Implement the Fuse Holders program.                    A.2.1.36 extended operation.
Electrical Cable Connections Not Implement the Electrical Cable Connections Not Subject Subject to IO CFR 50.49                                                                          Prior to the period of
: 39.                                       to 10 CFR 50.49 Environmental Qualification            A.2.1.37 Environmental Qualification                                                                      extended operation.
Requirements program.
Requirements

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 8 Prior to the period of
: 40. 345 KV SF6 Bus                    Implement the 345 KV SF6 Bus program.                    A.2.2.1 extended operation.
Enhance the program to include additional transients Metal Fatigue of Reactor Coolant                                                                     Prior to the period of
: 41.                                       beyond those defined in the Technical Specifications and A.2.3.1 Pressure Boundary                                                                                   extended operation.
UFSAR.
Enhance the program to implement a software program, to Metal Fatigue of Reactor Coolant                                                                    Prior to the period of
: 42.                                       count transients to monitor cumulative usage on selected A.2.3.1 Pressure Boundary                                                                                   extended operation.
components.
The updated analyses will be Pressure -Temperature Limits,    Seabrook Station will submit updates to the P-T curves             submitted at the appropriate
: 43.      including Low Temperature        and LTOP limits to the NRC at the appropriate time to    A.2.4.1.4 time to comply with I 0 CFR Overpressure Protection Limits   comply with 10 CFR 50 Appendix G.                                  50 Appendix G, Fracture Toughness Requirements.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 9 NextEra Seabrook will perform a review of design basis ASME Class 1 component fatigue evaluations to determine whether the NUREG/CR-6260-based components that have been evaluated for the effects of the reactor coolant environment on fatigue usage are the limiting components for the Seabrook plant configuration. If more limiting components are identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage. If the limiting location identified consists of nickel alloy, the environmentally-assisted fatigue calculation for nickel alloy will be performed using the rules ofNUREG/CR-6909.
(1) Consistent with the Metal Fatigue of Reactor Coolant Pressure Boundary Program Seabrook Station will update the fatigue usage calculations using refined fatigue analyses, if necessary, to determine acceptable CUFs (i.e., less than 1.0) when accounting for the effects of the reactor water Environmentally-Assisted environment. This includes applying the appropriate Fen factors                At least two years prior to the
: 44.                                                                                                    A.2.4.2.3 Fatigue Analyses (TLAA)  to valid CUFs determined from an existing fatigue analysis valid               period of extended operation.
for the period of extended operation or from an analysis using an NRC-approved version of the ASME code or NRC-approved alternative (e.g., NRC-approved code case).
(2) If acceptable CUFs cannot be demonstrated for all the selected locations, then additional plant-specific locations will be evaluated. For the additional plant-specific locations, ifCUF, including environmental effects is greater than 1.0, then Corrective Actions will be initiated, in accordance with the Metal Fatigue of Reactor Coolant Pressure Boundary Program, B.2.3.1. Corrective Actions will include inspection, repair, or replacement of the affected locations before exceeding a CUF of 1.0 or the effects of fatigue will be managed by an inspection program that has been reviewed and approved by the NRC (e.g.,
periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method accepted by theNRC).

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 10 NextEra will obtain additional cores in the vicinity of three extensometers and perform modulus testing. Using these test results, NextEra will determine the change in Alkali-Silica Reaction (ASR)   through-thickness expansion since installation of the                      At least 2 years prior to the
: 45.                                                                                                    A.2.1.31.A Monitoring Program            extensometers and compare it to change determined from                     period of extended operation.
extensometer readings. Consistency between these results will provide additional corroboration of the methodology in MPR-4153.
Enhance the program by designating and qualifying an Protective Coating Monitoring                                                                            Prior to the period of
: 46.                                    Inspector Coordinator and an Inspection Results                 A.2.1.38 and Maintenance                                                                                          extended operation.
Evaluator.
Enhance the program by including, "Instruments and Equipment needed for inspection may include, but not be Protective Coating Monitoring limited to, flashlight, spotlights, marker pen, mirror,                    Prior to the period of
: 47.                                                                                                    A.2.1.38 and Maintenance               measuring tape, magnifier, binoculars, camera with or                      extended operation.
without wide angle lens, and self sealing polyethylene sample bags."
Protective Coating Monitoring Enhance the program to include a review of the previous                    Prior to the period of
: 48.                                                                                                    A.2.1.38 and Maintenance               two monitoring reports.                                                    extended operation.
Enhance the program to require that the inspection report Protective Coating Monitoring is to be evaluated by the responsible evaluation personnel,                Prior to the period of
: 49.                                                                                                    A.2.1.38 and Maintenance               who is to prepare a summary of findings and                                extended operation.
recommendations for future surveillance or repair.
Baseline inspections were completed during ORI 6.
Perform UT of the accessible areas of the containment ASME Section XI, Subsection                                                                              Repeat containment liner UT
: 50.                                    liner plate in the vicinity of the moisture barrier for loss of A.2.1.27 IWE                                                                                                      thickness examinations at material. Perform opportunistic UT of inaccessible areas.
intervals of no more than five (5) refueling outages.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 11 Enhance the program to manage the aging effects for closure bolting within air and gas filled systems by using an applicable inspection technique that ensures the integrity of bolted joints will be demonstrated.
For closure bolting within systems at atmospheric                   Prior to the period of
: 51. Bolting Integrity            pressure, tightness checks will be peiformed 011 20        A.2.1.9 extended operation.
percent of bolts with a maximum of 25 bolts per population. Populations will be of the same material and environment combination. Inspections will occur before the period of extended operation, and then every 10 years after the initial inspection date.
Implement measures to maintain the exterior surface of ASME Section XI, Subsection
: 52.                                  the Containment Structure, from elevation -30 feet to +20  A.2.1.28 Complete IWL feet, in a dewatered state.
Replace the spare reactor head closure stud(s)
Prior to the period of
: 53.      Reactor Head Closure Studs  manufactured from the bar that has a yield strength> 150   A.2.1.3 extended operation.
ksi with ones that do not exceed 150 ksi.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 12 NextEra will address the potential for cracking of the primary to secondary pressure boundary due to PWSCC oftube-to-tubesheet welds using one of the following two options:
I) Perform a one-time inspection of a representative sample oftube-to-tubesheet welds in all steam generators to determine if PWSCC cracking is present and, if cracking is identified, resolve the condition through engineering evaluation justifying continued operation or repair the condition, as appropriate, and establish an ongoing monitoring program to perform routine tube-to-
: 54.      Steam Generator Tube Integrity tubesheet weld inspections for the remaining life of the   A.2.1.10 Complete steam generators, or
: 2) Perform an analytical evaluation showing that the structural integrity of the steam generator tube-to-tubesheet interface is adequately maintaining the pressure boundary in the presence oftube-to-tubesheet weld cracking, or redefining the pressure boundary in which the tube-to-tubesheet weld is no longer included and, therefore, is not required for reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary must be approved by the NRC as part of a license amendment request.
: 55.      Number Not Used Revise the station program documents to reflect the EPRI Closed-Cycle Cooling Water                                                                         Prior to the period of
: 56.                                     Guideline operating ranges and Action Level values for     A.2.1.12 System                                                                                             extended operation.
hydrazine and sulfates.
Revise the station program documents to reflect the EPRI Closed-Cycle Cooling Water                                                                         Prior to the period of
: 57.                                     Guideline operating ranges and Action Level values for     A.2.1.12 System                                                                                             extended operation.
Diesel Generator Cooling Water Jacket pH.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 13 Update Technical Requirement Program 5.1, (Diesel Fuel Oil Testing Program) ASTM standards to ASTM D2709-                   Prior to the period of
: 58.      Fuel Oil Chemistry                                                                    A.2.1.18 96 and ASTM D4057-95 required by the GALL XI.M30                     extended operation.
Rev 1.
The Nickel Alloy Aging Nozzles and Penetrations Nickel Alloy Nozzles and                                                                        Prior to the period of
: 59.                                program will implement applicable Bulletins, Generic        A.2.2.3 Penetrations                                                                                   extended operation.
Letters, and staff accepted industry guidelines.
Implement the design change replacing the buried Buried Piping and Tanks                                                                        Prior to the period of
: 60.                                Auxiliary Boiler supply piping with a pipe-within-pipe      A.2.1.22 Inspection                                                                                     extended operation.
configuration with leak detection capability.
Replace the flexible hoses associated with the Diesel Compressed Air Monitoring                                                                      Within ten years prior to the
: 61.                                Generator air compressors on a frequency of every 10        A.2.1.14 Program                                                                                        period of extended operation.
years.
Enhance the program to include a statement that sampling Prior to the period of
: 62.      Water Chemistry           frequencies are increased when chemistry action levels are A.2.1.2 extended operation.
exceeded.
Ensure that the quarterly CVCS Charging Pump testing is continued during the PEO. Additionally, add a precaution to the test procedure to state that an increase in the eves          Prior to the period of
: 63.      Flow Induced Erosion Charging Pump mini flow above the acceptance criteria       A.2.1.2  extended operation.
may be indicative of erosion of the mini flow orifice as described in LER 50-275/94-023.
Soil analysis shall be performed prior to entering the period of extended operation to determine the corrosivity of the soil in the vicinity ofnon-cathodically protected             Within ten years prior to the
: 64.      Buried Piping and Tanks                                                               A.2.1.22 steel pipe within the scope of this program. If the initial          period of extended operation.
Inspection                analysis shows the soil to be non-corrosive, this analysis will be re-performed every ten years thereafter.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 14 Implement measures to ensure that the movable incore                   Prior to the period of
: 65.      Flux Thimble Tube             detectors are not returned to service during the period of             extended operation. - In extended operation.                                         NIA        Progress NextEra will perform an integrated review of expansion trends at Seabrook Station by conducting a periodic assessment of ASR expansion behavior to confirm that the MPR/FSEL large-scale test programs remain applicable to plant structures. This review will include the following specific considerations:
* Review of all cores removed to date for trends of any indications of mid-plane cracking.
At least 5 years prior to the Alkali-Silica Reaction (ASR)
* Comparison of in-plane expansion to through-
: 66.                                            thickness expansion of all monitored points by      A.2.1.31.A period of extended operation Monitoring Program plotting these data on a graph of CCI versus                   and every 10 years thereafter.
through-thickness expansion.
* Comparison of in-plane expansions and through-thickness expansions recorded to date to the limits from the MPR/FSEL large-scale test programs and check of margin for future expansion. Also, the calculated volumetric expansion will be compared to the range observed in the beam test programs and margin for future expansion will be checked.
Perform 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
: 67.      Structures Monitoring Program any degradation such as loss of material. The removed       A.2.1.31   Complete core will also be subjected to petrographic examination for concrete degradation due to ASR per ASTM Standard Practice C856.
Perform sampling at the leak off collection points for
: 68.      Structures Monitoring Program                                                             A.2.1.31   Complete chlorides, sulfates, pH and iron once every three months.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 15 Replace the Diesel Generator Heat Exchanger Plastisol Open-Cycle Cooling Water
: 69.                                        PVC lined Service Water piping with piping fabricated     A.2.1.11  Complete System from AL6XN material.
Inspect the piping downstream of CC-V-444 and CC-V-446 to determine whether the loss of material due to Closed-Cycle Cooling Water                                                                            Within ten years prior to the
: 70.                                        cavitation induced erosion has been eliminated or whether A.2.1.12 System                                                                                                period of extended operation.
this remains an issue in the primary component cooling water system.
NextEra has completed testing at the University of Texas Ferguson Structural Engineering Laboratory which demonstrates the parameters being monitored and acceptance criteria used are appropriate to manage the Alkali-Silica Reaction (ASR)      effects of ASR.                                           A.2.l.31A Prior to the period of
: 71.      Monitoring Program I Building NextEra will Implement the Alkali-Silica Reaction (ASR)   A.2.l.31B extended operation.
Deformation Monitoring Program Monitoring Program and Building Deformation Monitoring Program described in B.2.1.3 lA and B.2.1.3 IB of the License Renewal Application.
Enhance the program to include management of wall                   Prior to the period of
: 72.      Flow-Accelerated Corrosion                                                                  A.2.1.8 thinning caused by mechanisms other than FAC.                       extended operation.
Enhance the program to include performance of focused Inspection oflnternal Surfaces in examinations to provide a representative sample of20%,
: 73.      Miscellaneous Piping and          or a maximum of25, of each identified material,           A.2.1.25  Prior to the period of Ducting Components                environment, and aging effect combinations during each              extended operation.
I 0 year period in the period of extended operation.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 16 Enhance the program to perform sprinkler inspections annually per the guidance provided in NFPA 25 (2011 Edition). Inspection will ensure that sprinklers are free of corrosion, foreign materials, paint, and physical damage Prior to the period of
: 74.      Fire Water System       and installed in the proper orientation (e.g., upright,      A.2.1.16 extended operation.
pendant, or sidewall). Any sprinkler that is painted, corroded, damaged, loaded, or in the improper orientation, and any glass bulb sprinkler where the bulb has emptied, will be evaluated for replacement.
Enhance the program to a) conduct an inspection of piping and branch line conditions every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting for the presence of foreign organic and inorganic material per the guidance provided in NFPA 25 (2011 Edition) and b) If the presence of sufficient foreign organic or inorganic material to obstruct A.2.1.16 Prior to the period of
: 75.      Fire Water System pipe or sprinklers is detected during pipe inspections, the           extended operation.
material will be removed and its source is determined and corrected.
In buildings having multiple wet pipe systems, every other system shall have an internal inspection of piping every 5 years as described in NFPA 25 (2011 Edition), Section 14.2.2.
Enhance the Program to conduct the following activities annually per the guidance provided in NFP A 25 (2011 Edition).                                                             Prior to the period of
: 76.      Fire Water System                                                                    A.2.1.16
* main drain tests                                                 extended operation.
* deluge valve trip tests
* fire water storage tank exterior surface inspections

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 17 The Fire Water System Program will be enhanced to include the following requirements related to the main drain testing per the guidance provided in NFPA 25 (2011 Edition).
* The requirement that if there is a 10 percent reduction          Prior to the period of
: 77.      Fire Water System                 in full flow pressure when compared to the original     A.2.1.16 extended operation.
acceptance tests or previously performed tests, the cause of the reduction shall be identified and corrected if necessary.
* Recording the time taken for the supply water pressure to return to the original static (nonflowing) pressure.
Enhance the program to include periodic inspections of in-scope insulated components for possible corrosion under insulation. A sample of outdoor component surfaces that are insulated and a sample of indoor insulated components             Prior to the period of
: 78.      External Surfaces Monitoring                                                              A.2.1.24 exposed to condensation (due to the in-scope component                extended operation.
being operated below the dew point), will be periodically inspected every 10 years during the period of extended operation.
Enhance the program to include visual inspection of Open-Cycle Cooling Water     internal coatings/linings for loss of coating integrity.              Within 10 years prior to the
: 79.                                                                                                A.2.1.11 System                                                                                             period of extended operation.
Enhance the program to include visual inspection of internal coatings/linings for loss of coating integrity.              Within 10 years prior to the
: 80.      Fire Water System                                                                         A.2.1.16 period of extended operation.
Enhance the program to include visual inspection of internal coatings/linings for loss of coating integrity.              Within 10 years prior to the
: 81.      Fuel Oil Chemistry                                                                        A.2.1.18 period of extended operation.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 18 Inspection oflntemal Surfaces in Enhance the program to include visual inspection of internal coatings/linings for loss of coating integrity.               Within I 0 years prior to the
: 82.      Miscellaneous Piping and                                                                      A.2.1.25 period of extended operation.
Ducting Components Enhance the ASR AMP to install extensometers in all Tier 3 areas of two dimensional reinforced structures to monitor expansion due to alkali-silica reaction in the out-Alkali-Silica Reaction            of-plane direction.
: 83.                                                                                                    A.2.l.31A February 28, 2017 Monitoring                        Monitoring expansion in the out-of-plane direction will commence upon installation of the extensometers and continue on a six month frequency through the period of extended operation.
Evaluate the acceptability of inaccessible areas for ASME Section XI, Subsection                                                                             Prior to the period of
: 84.                                       structures within the scope of ASME Section XI,              A.2.1.28 IWL                                                                                                     extended operation.
Subsection IWL Program.
Enhance the program to perform additional tests and inspections on the Fire Water Storage Tanks as specified in Section 9.2.7 ofNFPA 25 (2011 Edition) in the event
: 85.                                                                                                              Prior to the period of Fire Water System                that it is required by Section 9.2.6.4, which states "Steel  A.2.1.16 extended operation.
tanks exhibiting signs of interior pitting, corrosion, or failure of coating shall be tested in accordance with 9.2.7."
: 86.                                       Enhance the program to include disassembly, inspection,                Prior to the period of Fire Water System                                                                             A.2.1.16 and cleaning of the mainline strainers every 5 years.                  extended operation.
Increase the frequency of the Open Head Spray Nozzle
: 87.                                       Air Flow Test from every 3 years to every refueling                    Prior to the period of Fire Water System                                                                             A.2.1.16 outage to be consistent with LR-ISG-2012-02, AMP                       extended operation.
XI.M27, Table 4a.

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 19 Enhance the program to include verification that a) the drain holes associated with the transformer deluge system are draining to ensure complete drainage of the system after each test, b) the deluge system drains and associated
: 88.                                                                                                              Within five years prior to the Fire Water System                  piping are configured to completely drain the piping, and   A.2.1.16 period of extended operation.
c) normally-dry piping that could have been wetted by inadvertent system actuations or those that occur after a fire are restored to a dry state as part of the suppression system restoration.
Incorporate Coating Service Level III requirements into the RCP Motor Refurbishment Specification for the Inspection of Internal Surfaces in internal painting of the motor upper bearing coolers and Prior to the period of
: 89.      Miscellaneous Piping and           motor air coolers. All four RCP motors will be              A.2.1.25 extended operation.
Ducting Components                 refurbished and replaced using the Coating Service Level III requirements prior to entering the period of extended operation.
Implement the PWR Vessel Internals Program. The program will be implemented in accordance with MRP-Prior to the period of PWR Vessel Internals               227-A (Pressurized Water Reactor Internals Inspection       A.2.1.7
: 90.                                                                                                              extended operation and Evaluation Guidelines) and NEI 03-08 (Guideline for the Management of Materials Issues).

U.S. Nuclear Regulatory Commission SBK-L-17133 I Enclosure 3 I Page 20 Implement the Building Deformation Monitoring Program Enhance the Structures Monitoring Program to require structural evaluations be performed on buildings and components affected by deformation as necessary to ensure that the structural function is maintained. Evaluations of structures will validate structural performance against the design basis, and may use results from the large-scale test programs, as appropriate. Evaluations for structural deformation will also consider the impact to functionality of affected systems and components (e.g., conduit expansion joints). NextEra will evaluate the specific circumstances against the design basis of the affected system or component.
Building Deformation    Enhance the Building Deformation AMP to include 91                                                                                          A.2.l.31B March 15, 2020 Monitoring              additional parameters to be monitored based on the results of the CEB Root Cause, Structural Evaluation and walk downs. Additional parameters monitored will include:
alignment of ducting, conduit, and piping; seal integrity; laser target measurements; key seismic gap measurements; and additional instrumentation.
Develop a design standard to implement Aging Management Program B.2.1.31 B Building Deformation, Program Element 3 - Parameters Monitored/Inspected.
The design standard will clarify the deformation evaluation process and provide an auditable format to assess it. The design standard will include steps for each of the three evaluation stages that include parameters monitored, basis for why the parameter is monitored, and conditions that prompts action for the subsequent step.}}