ML19205A348

NRC005 - Jacob Phillip Testimony

ML19205A348
Person / Time
Site:	Seabrook
Issue date:	07/24/2019
From:	NRC/OGC
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-443-LA-2, ASLBP 17-953-02-LA-BD01, RAS 55104
Download: ML19205A348 (17)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC ASLBP No. 17-953-02-LA-BD01 (Seabrook Station, Unit 1)

Hearing Exhibit Exhibit Number: NRC005 Exhibit

Title:

Jacob Phillip Testimony

July 24, 2019 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of NEXTERA ENERGY SEABROOK, LLC Docket No. 50-443-LA-2 (Seabrook Station, Unit 1)

NRC STAFF TESTIMONY OF JACOB PHILIP INTRODUCTION Q.1. Please state your name, occupation, and by whom you are employed.

A.1. My name is Jacob Philip. I am a senior geotechnical (civil) engineer in the Structural, Geotechnical, and Seismic Engineering Branch, Division of Engineering, Office of Nuclear Regulatory Research (RES), at the U.S. Nuclear Regulatory Commission (NRC). A statement of my professional qualifications is attached hereto as Exhibit NRC006.

Q.2. Please describe the nature of your responsibilities on behalf of the NRC.

A.2. As relevant to this proceeding, I am the project manager of the RES research project, Structural Performance of Nuclear Power Plant (NPP) Concrete Structures Affected by Alkali Silica Reaction (ASR) being conducted at the National Institute of Standards and Technology (NIST).

Q.3. Please explain what your duties have been in connection with the Staff review of the NextEra Energy Seabrook, LLC (NextEra, the licensee) license amendment request (LAR) to revise the Seabrook Station, Unit No. 1 Updated Final Safety Analysis Report (UFSAR) to include a methodology to demonstrate that Seabrook structures with ASR (also known as alkali-

aggregate reaction (AAR)) continue to meet the design codes for original construction (INT010 (nonproprietary); INT011 (proprietary)).1 A.3. The NRC Office of Nuclear Reactor Regulation (NRR) requested that RES perform an independent review of the LAR. I was the primary reviewer who performed the independent review for RES.

Q.4. What is the purpose of your testimony?

A.4. The contention proffered by the C-10 Research and Education Foundation (C-10) and supported by its current expert, Dr. Victor Saouma, as reformulated and admitted by the Atomic Safety and Licensing Board,2 has to do with the large-scale test program (LSTP) that NextEra commissioned MPR Associates (MPR), in collaboration with the Ferguson Structural Engineering Laboratory (FSEL) at the University of Texas at Austin, to conduct. The contention claims that the LSTP yielded data that are not representative of the progression of ASR at Seabrook [and that, a]s a result, the proposed monitoring, acceptance criteria, and inspection intervals are not adequate.3 The purpose of my testimony is to explain that the conduct of the LSTP provided reasonable assurance that its data are representative and/or bounding of the progression of ASR at Seabrook. Based on this testimony, and the testimony of Angela Buford, Bryce Lehman, and George Thomas (NRC001), the Board should uphold the Staffs issuance of the LAR, as conditioned.

BACKGROUND 1

NextEra supplemented the LAR on September 30, 2016 (NRC011), October 3, 2017 (NRC013),

December 11, 2017 (NRC014), and June 7, 2018 (NRC015). Separately, on May 18, 2018, in updating its license amendment request, NextEra provided revised versions of MPR reports previously submitted as LAR supplements (NRC025).

2 NextEra Energy Seabrook, LLC (Seabrook Station, Unit 1), LBP-17-7, 86 NRC 59, 127 (2017) (LBP 7).

3 Id.

Q.5. Please explain the origin of the independent review by RES of the LAR.

A.5. On July 13, 2017, Dr. Kevin Coyne, acting Deputy Director, Division of Engineering, NRR, requested that RES perform an independent review of the LAR. Specifically, he requested that RES independently review the technical merits of the MPR and FSEL LSTP that supports the LAR. RES accepted this request as an Informal Assistance Request (IAR).

Q.6. Please describe your independent review of the LSTP.

A.6. As part of the IAR, I reviewed MPR-4153, Rev. 2 (NRC011 (nonproprietary);

NRC012 (proprietary)), MPR-4273, Rev. 0 (NRC008 (nonproprietary); NRC009 (proprietary)),

and MPR-4288, Rev. 0 (INT012 (non-proprietary); INT014 (proprietary)), as necessary. My review focused on the overall adequacy of the LSTP and the adequacy of the conclusions reached by the licensee based on the LSTP. The LSTP consisted of large reinforced concrete beams. These test specimens were designed to represent the configuration of the reinforced concrete structural members at Seabrook (see Fig 2-1, MPR-4153 (NRC012 at 2-1)

(proprietary)). Five distinct testing activities were conducted. They were:

1. ASR expansion and material property testing, which consisted of measuring ASR expansion for representative field conditions and related changes in mechanical properties of the concrete;

2. Anchor testing, which consisted of testing post-installed anchors in ASR concrete at different levels of ASR;

3. Shear testing, which consisted of evaluating the shear capacity of reinforced concrete beams at different levels of ASR;

4. Reinforcement anchorage testing, which consisted of evaluating the impact of different levels of ASR on lap splices and flexure; and

5. Instrumentation testing, which consisted of testing various instruments to be installed at the Seabrook structures to determine through-thickness expansion.

MPR-4153 primarily addresses the first set of tests related to ASR expansion and material property testing (NRC011 (nonproprietary); NRC012 (proprietary)). MPR-4273 addresses the other four testing activities (NRC008 (nonproprietary); NRC009 (proprietary)).

Q.7. Please summarize your understanding of MPR-4153 (NRC011 (nonproprietary);

NRC012 (proprietary)).

A.7. MPR-4153 presents a methodology relating ASR expansion to elastic modulus (the ratio of the applied stress to the corresponding strain) for determining the extent of through-thickness expansion of ASR-affected structures at Seabrook. The licensee stated that the methodology will enable it to apply the results of the LSTPs structural testing program to Seabrook to ensure that appropriate action is taken before the ASR at Seabrook exceeds the bounds of the LSTP. The structural testing program indicates that expansion in the in-plane direction plateaued at low expansion levels. The expansion in the out-of-plane direction (i.e.,

through-thickness direction) continued to increase with the increase of expansion levels due to ASR.

The licensee has also been installing extensometers in structures at Seabrook to measure in-situ expansion in the through-thickness direction of the structures. These measurements will continue through the life of the plant. An important aspect of the field measurements will be to determine expansion from original construction to when the extensometer is installed and beyond. The licensee has described a methodology to determine the pre-extensometer installation expansion based on data from the LSTP.

Q.8. Please describe the findings and conclusions you reached with respect to the methodology presented in MPR-4153 (NRC011 (nonproprietary); NRC012 (proprietary)).

A.8. Based on my review of MPR-4153, I agreed that the LSTP and the use of large specimens are appropriate to evaluating the mechanical properties (i.e., compressive and tensile strengths and elastic modulus) of ASR-affected concrete. In addition, anchor testing and

instrumentation testing are appropriate for their respective uses. These tests should enable the licensee to apply the LSTP results to ASR conditions existing at Seabrook. Importantly, the sizes of the specimens are of the same order as those at Seabrook and they are equipped with similar reinforcement. For example, if testing is done on small concrete samples, it is very difficult to scale up the data obtained to evaluate actual structural sizes. Using large samples approximating the size of the actual structure greatly mitigates this problem. Thus, the effects of scaling to evaluate large ASR-affected structures based on testing small samples are greatly mitigated. The use of large specimen sizes in ASR testing is rare. The literature is replete with testing at much smaller samples where large uncertainties are expected when transferring the results to full-scale structures.

Based on my review, I also agreed with the licensee that the reinforcement configuration explains the differences between the in-plane and the through-thickness expansions.

Specifically, expansion in the two in-plane directions is restrained by the configuration of the reinforcement, while in the through-thickness direction, the absence of through reinforcement encourages large expansion in that direction. The presence of reinforcement imparts a compressive force by the ASR-induced expanding concrete, creating a prestressing effect.

Tensile loads in the structure can only come into play after this prestressing effect is overcome.

During my review, I also concluded that the measurement of both the through-thickness and in-plane expansions of the concrete is the best indicator of ASR development at Seabrook based on the expansion behavior in the LSTP. NextEra is proceeding with installing extensometers in concrete structures at Seabrook to monitor expansion in the through-thickness direction complemented with the crack indexing (CI) / combined crack indexing (CCI) and/or pin-to-pin expansion measurements in the in-plane direction.

With respect to the correlation between elastic modulus and ASR expansion, I reviewed the curves depicting the impacts of ASR on the mechanical properties of ASR-affected concrete

(Figures 3-1, 3-2, 3-3, and 3-4 in MPR-4153) and the licensees explanations of the trend in the curves (NRC012 at 3-3-3-6) (proprietary)). Based on this review, I concluded that there appears to be a good relationship between the expansions due to ASR in concrete and the elastic modulus as shown in the LSTP and in published literature with some limited scatter in the trend. It is clear from the testing that relating the elastic modulus with ASR expansion is the preferred option for analyzing Seabrook structures.

As noted above, in MPR-4153, the licensee recommended an approach for determining ASR induced through-thickness expansion using extensometers at Seabrook. As of the date of my independent review, the licensee had installed 18 extensometers to monitor through-thickness expansion at Seabrook. An extensometer is a device that is used to measure changes in the length of an object, in this case the expansion of the concrete (i.e., through-thickness) as a result of ASR. Cores were taken at each extensometer location and elastic modulus testing performed to determine the current modulus and to support determination of the through-thickness expansion to date. These values are the present expansion value of the structure and will be added to the extensometer readings going forward. Based on my review, I agreed with the licensees recommended approach for determining ASR induced through-thickness expansion. However, I noted that:

1. The licensee should corroborate the normalized elastic modulus-expansion curves for each structure at Seabrook with elastic modulus tests of cores extracted close to the extensometer locations at appropriate intervals, particularly if abnormal spikes in extensometer readings occur; this could confirm the appropriateness and validity of the curve and

2. The licensee should take appropriate steps to confirm that the extensometers are recording adequately and are protected from environmental effects.

Q.9. How does the license condition described in the Staffs safety evaluation of the LAR address these concerns?

A.9. The Staff-required license condition states:

The licensee will perform the following actions to confirm the continued applicability of the [LSTP] conclusions to Seabrook structures (i.e., that future expansion behavior of ASR-affected concrete structures at Seabrook aligns with observations from the

[LSTP] and that the associated expansion limits remain applicable). The licensee shall notify the NRC each time an assessment or corroboration action is completed.

a. Conduct assessments of expansion behavior using the approach provided in Appendix B of Report MPR-4273, Revision 1 (Seabrook FP#101050), to confirm that future expansion behavior of ASR-affected structures at Seabrook Station is comparable to what was observed in the [LSTP] and to check margin for future expansion. Seabrook completed the first expansion assessment in March 2018; and will complete subsequent expansion assessments every ten years thereafter.

b. Corroborate the concrete modulus-expansion correlation used to calculate pre-instrument through-thickness expansion, as discussed in Report MPR-4153, Revision 3 (Seabrook FP#100918). The corroboration will cover at least 20 percent of extensometer locations on ASR-affected structures and will use the approach provided in Appendix C of Report MPR-4273, Revision 1 (Seabrook FP#101050). Seabrook will complete the initial study no later than 2025 and a follow-up study 10 years thereafter. (INT024, encl. 2 at 59-60).

The license condition ensures that NextEra continues to gather and analyze expansion data of in-situ structures and ensures that the structures expansion behavior continues to align with the expansion behavior seen in the LSTP. This is consistent with what I had noted regarding the licensees recommended approach for determining ASR-induced through-thickness expansion.

Q.10. Please provide a summary of MPR-4273 (NRC008 (nonproprietary); NRC009 (proprietary)).

A.10. In MPR-4273, the licensee documented its four structural and instrumentation testing programs at FSEL, conducted to address the ASR issue identified at Seabrook. Three of the test programs focused on the structural performance data used to complete the structural evaluation of Seabrook structures and the fourth focused on the evaluation of instruments to monitor ASR through-thickness expansion at Seabrook.

In the Anchor Test Program, MPR used large-scale concrete block specimens designed and fabricated to represent the ASR-affected reinforced concrete structures at Seabrook, as well as sections of a concrete bridge girder with ASR. Capacity tests (i.e., tests that measure the pull-out load that the anchor can withstand) of anchors of different lengths, sizes, and embedments were performed. In the Shear Test Program, MPR evaluated the impact of ASR on the shear capacity (i.e., the maximum shear load, that acts perpendicular to the length of the beam, that the beam can withstand) of reinforced concrete specimens. The testing consisted of three-point load tests (i.e., load testing of the beam with one loading point acting downwards on the beam and the two reaction loads acting upwards on the beam) on large beam specimens designed and built to represent the structural characteristics of the reinforced concrete structures at Seabrook. The testing focused on the shear capacity of the ASR-affected concrete. MPR used the Reinforcement Anchorage Test Program to evaluate ASR effects on the effectiveness of reinforcement anchorage of rebar test splices and gain insights on flexural strength and stiffness. The testing consisted of standard four-point flexural load tests (i.e., load testing of the beam with two loading points acting downwards on the beam and the two reaction loads acting upwards on the beam) on large beam specimens to represent the structural characteristics of the reinforced concrete structures at Seabrook. In the Instrumentation Test Program, MPR evaluated instruments for the measurement of through-thickness expansion, as described in MPR-4153 (see A.8, supra). Again, the test specimen was a large-scale reinforced concrete beam designed and fabricated to represent reinforced concrete structures at

Seabrook. The testing included a number of different instruments over different configurations, which monitored expansions for 1 year.

The licensee performed additional testing to compliment the testing discussed above and to gain additional insights regarding the large-scale beam testing outcomes. These tests included (1) expansion testing to monitor the total axial and volumetric expansion of concrete cubes with varying reinforcement, reinforcement density, and concrete mix design, (2) retrofit testing to test proof of concept testing for potential retrofits for structures experiencing expansion beyond desired ASR distress in the structures, and (3) uniform load testing of beam specimens to represent loading on subsurface walls that are subject to uniform hydrostatic loading rather than three-point loading for shear testing, as noted earlier.

Q.10. Please describe the findings and conclusions that you reached based on your review of MPR-4273 (NRC008 (nonproprietary); NRC009 (proprietary)).

A.10. Based on my review, I agreed that the LSTP and its use of large specimens are appropriate to evaluate the four testing programs summarized above. The LSTP should enable the licensee to apply the test results to the analysis of ASR at Seabrook. Importantly, the sizes of the specimens are of the same order as those at Seabrook and they are equipped with similar reinforcement. Thus, the effects of scaling to evaluate large ASR affected structures based on testing small samples are greatly mitigated. The instrumentation testing should provide data suitable to the measurement of through-thickness expansion at Seabrook structures after instruments are installed. The additional testing noted above is appropriate to support and inform the testing outcomes from the four testing programs.

In addition, based on my review of MPR-4273, I agreed that the evaluation of the impacts of ASR on Seabrook structures must take into account the structural context rather than relying on material testing alone. In the structural context, ASR imparts a prestressing effect on the structure as a result of confinement by reinforcement. Specifically, with respect to the

structural testing of beams, prestressing occurs in the beam because of ASR effects and, in effect, strengthens the structural member (because of the presence of confining reinforcement) allowing it to withstand a higher load imposed on it as compared to non-ASR-affected beams.

This aspect of prestressing would not be evident from concrete material testing alone. Hence, the licensee correctly concludes that evaluations of ASR-affected concrete need to place it in its appropriate structural context.

I also concluded that the use of large-scale fabricated specimens to test ASR development in Seabrook structures is preferable to testing harvested samples from the partially constructed Seabrook Unit No. 2 as depicted in Table 2-1 and Figure 2-2 in MPR 4273 (NRC008 at 2-6-2-7). The latter table notes the advantages and disadvantages of following the two approaches and the use of fabricated specimens is clearly the better approach due to the reasons discussed by the licensee in MPR 4273.

In addition, with respect to the designed and fabricated test specimens, I concluded that the specimens represent the Seabrook structures and are appropriate with respect to the LSTP to evaluate the shear and reinforcement anchorage at the ASR-affected structures at Seabrook.

The reinforcement configuration, concrete mix design, large size, and use of reactive aggregates, high-alkali cement, and sodium hydroxide, all ensure that the specimens are applicable and appropriate for testing to evaluate Seabrook structures for the present and going forward. Minor differences between specimens as indicated in Table 3-1 are of no or minor consequence as explained by the licensee (NRC009 at 3-2 (proprietary)). The bridge girder(s) and the fabricated test specimens on which anchor testing was conducted are appropriate to test for anchor capacity as is the specimen to evaluate instruments (several instruments and a selection based on the one with the best performance) for through-thickness expansion determinations at Seabrook.

With respect to the licensees characterization of ASR development, I concluded that the expansion is greater in the through-thickness direction than in the in-plane direction primarily because of the reinforcement configuration, and that this mode of expansion reflects that at Seabrook (see Figure 4-1, MPR 4273 (NRC009 at 4-2 (proprietary))). I also agreed, based on Figure 4-1, MPR 4273, that the CI/CCI measurements complement pin-to-pin measurements to measure in-plane expansion (NRC009 at 4-2 (proprietary)). The CI/CCI measurements provide an estimate of the in-plane expansion from the original construction of Seabrook particularly if the ASR effects are large as is the corresponding cracks. The use of pin-to-pin measurements, though, is a better indicator of in-plane expansion from the time of installation going forward.

In addition, I determined that the effects of reinforcement ratio in the shear, anchorage and instrumentation, and anchor test specimens did not have a noticeable effect on the in-plane expansion behavior of the test specimens. The magnitude of the in-plane expansion plateaued at low expansion levels as depicted in Figure 4-1, MPR 4273 (NRC009 at 4-2 (proprietary)).

Also, the preliminary results from the cube tests confirmed that the most significant factor for expansion is the presence of reinforcement and are consistent with the conclusions from the LSTP.

With respect to anchor testing, I concluded that the testing conducted by the licensee indicates that anchor capacity is appropriate for the range of in-plane expansion expected at Seabrook and shown through the LSTP. Out-of-plane expansion does not have an effect on anchor capacity because the cracks expected in that direction are parallel to the reinforcement mat. Anchor testing closes those cracks within the area of the influence of the anchors, installed perpendicular to the cracking. I would note, however, that another explanation of the satisfactory performance of the anchors is that ASR imparts an additional axial force in the in-plane direction of the specimens causing the anchors to perform adequately. This axial force is a result of the beneficial ASR prestressing of concrete.

With respect to shear testing, I concluded that the testing results for shear capacity indicate that the normalized shear test results exceed the theoretical shear capacity or shear load calculated in ACI 318-71 (NRC049). In part, this increased shear capacity can be explained by ASR imparting an additional axial force in the in-plane direction of the specimens causing the shear capacity to be exceeded. This axial force is a result of the beneficial ASR prestressing of concrete. As noted in the literature, ASR-affected concrete is triaxially loaded in the structural context and thus slightly affected by fairly severe ASR expansion.

Based on my review of the Reinforcement Anchorage Test Program, I concluded that there is ample reinforcement anchorage strength in spite of ASR. Also, the service level flexural stiffness for ASR-affected concrete is well above that allowed by ACI 318-71 and, in fact, increased with the level of ASR. As noted above, part of this explanation is that ASR imparts an additional axial force in the in-plane direction of the specimens causing both the reinforcement anchorage and flexural stiffness ACI 318 -71 code calculations to be exceeded in ASR-affected concrete. This axial force is a result of the beneficial ASR prestressing of concrete. The prestressing may also lead to adverse strain in the reinforcement. The LSTP did not measure the strains in the longitudinal reinforcing bars. Assuming good bond between these reinforcing bars and the concrete, these strains could be, on average, as large as the ASR expansion in the same direction (in-plane direction in the tests). The tests demonstrated that for the ASR expansions tested, the test specimens sustained loads in addition to the ASR and their own dead weight slightly greater than the control (i.e., without ASR) specimens and exhibited comparable ductility. The ASR-affected specimens also showed a somewhat stiffer behavior up to the yield point of the structure.

Based on my review, I also determined that the instrumentation testing based on Figure 5-11 in MPR 4273 shows that the SRBE performed adequately for the period tested from July 2014 through July 2015 (NRC009 at 5-17 (proprietary)). This is a relatively short period in that

the expansion measurements would extend to many years at Seabrook. The licensee plans to place two extensometers at each location as a check on the measurements and has indicated extensometer readings will be taken every 6 months.

In conclusion, based on my review of MPR-4273, I agreed with the licensees recommendations with respect to ASR expansion monitoring at Seabrook. MPR-4273 recommends that cores be removed once 2 years prior to the period of extended operations (PEO) for modulus testing. The requirement imposed by the Staff as a condition on the issuance of the LAR addresses this issue.

Q.11. Please provide a summary of MPR-4288 (INT012 (nonproprietary); INT014 (proprietary)).

A.11. MPR-4288 describes the effect of ASR on the structural design basis of affected concrete structures at Seabrook and provides guidance to evaluate the structural adequacy of those structures on the basis of the LSTP. The report discusses the impact of ASR on structural limit states (i.e., flexure, shear, and compression capacities and that of the attachments to concrete structures) as well as several additional design considerations (i.e.,

strain in reinforcing bars, fracture of reinforcing steel, seismic response, concrete material properties, and building deformation related issues).

MPR-4288 also summarizes the licensees interim structural assessment of selected ASR-affected structures at Seabrook performed to evaluate the adequacy of the structures given the presence of ASR. This assessment utilized a conservative evaluation of data from the literature, supplemented by limited testing of anchor bolts, in a manner suitable for the short-term structural assessment of the Seabrook structures.

Given the results of the LSTP, the licensee concluded that the assessment of the ASR-affected structures at Seabrook be performed in accordance with the provisions of the original design code and taking into account the ASR loads, chemical prestressing, and deformations

effects. The licensee also concluded that these structural evaluations should use the material properties in the original design basis.

Q.12. Please describe the findings and conclusions you reached with respect to the methodology presented in MPR-4288 (INT012 (nonproprietary); INT014 (proprietary)).

A.12. Based on my review of MPR-4288, I concluded that the ASR expansion and related prestressing effect may lead to tensile strains in the reinforcement. The LSTP did not measure the strains in the longitudinal reinforcing bars. Assuming good bond between these reinforcing bars and the concrete, these strains could be, on average, as large as the ASR expansion in the same direction (in-plane direction in the tests). In addition, the LSTP demonstrated that for the in-plane ASR expansions tested, the testing specimens sustained loads in addition to the ASR and their own dead weight slightly greater than those sustained by the control specimens and exhibited comparable ductility. The ASR-affected specimens also showed a somewhat stiffer behavior up to the yield point of the structure.

I also concluded that assessment of the ASR-affected structures at Seabrook performed in accordance with the provisions of the original design code and taking into account the ASR loads, chemical prestressing, and deformations effects, should be consistent with the conditions in the supporting LSTP. The applicable design code limit states should be used in this assessment in the same manner as used in the comparison of the test results against the code provisions for the calculation of the limit state capacities.

With respect to the licensees discussion of seismic analysis for Seabrook, I determined that the reinforcement anchorage tests were also flexural tests. These tests and their comparison with similar tests with concrete not affected by ASR shows an increase in the average flexural stiffness when the loads increase from the permanent loads to those at yielding. The related increase in the frequency of vibration of ASR-affected structures is

associated with a small decrease in the seismic demands in the Seabrook design response spectra.

I also concluded that the LSTP structural tests showed that the structural shear capacity of the ASR-affected specimens exceeded the capacity calculated using the code equations and the concrete properties in the original design specifications. Given the results of the LSTP tests, shear tests, and reinforcement anchorage tests, I agreed with the licensees conclusions and related approach for the assessment of the ASR-affected structures at Seabrook. In the assessment, the ASR loads should be consistent with the conditions in the supporting testing program at FSEL. The assessment also should use the applicable limit states in the design code in the same manner as used in the comparison of the test results against the code equations. The application of the design equations for the load combinations that include ASR loads also should be consistent with the comparisons of the testing results with the code provisions for the calculation of limit state capacities.

Q.13. After reviewing all of the information available to you since your independent review, including all of the information provided by C-10 and Dr. Saouma, is it still your expert opinion that the conduct of the LSTP provided reasonable assurance that its data are representative and/or bounding of the progression of ASR at Seabrook?

A.13. Yes.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of NEXTERA ENERGY SEABROOK, LLC Docket No. 50-443-LA-2 (Seabrook Station, Unit 1)

AFFIDAVIT OF JACOB PHILIP I, Jacob Philip, do hereby declare under penalty of perjury that my statements in the foregoing testimony and my statement of professional qualifications are true and correct to the best of my knowledge and belief.

Executed in Accord with 10 CFR 2.304(d)

Jacob Philip Senior Geotechnical Engineer U.S. Nuclear Regulatory Commission Washington, DC 20555 Telephone: (301) 415-3166 Email: Jacob.Philip@nrc.gov Execute in Rockville, Maryland this 24th day of July 2019