ML19339H135
| ML19339H135 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/05/2019 |
| From: | Bessette P Morgan, Morgan, Lewis & Bockius, LLP, NextEra Energy Seabrook |
| To: | Curran D C-10 Research & Education Foundation, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-443-LA-2, ASLBP 17-953-02-LA-BD01, RAS 55445 | |
| Download: ML19339H135 (3) | |
Text
Paul M. Bessette Partner
+1.202.739.5796 paul.bessette@morganlewis.com December 5, 2019 Diane Curran Counsel for C-10 Research and Education Foundation Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 Docket No.: 50-443-LA-2, NextEra Energy Seabrook, LLC (Seabrook Station Unit 1)
Re: Mineralogical Data
Dear Ms. Curran:
On November 25, 2019, the Atomic Safety and Licensing Board (Board) issued an Order directing NextEra Energy Seabrook, LLC (NextEra) to submit to C-10 Research and Education Foundation (C-10) all documents not previously produced that contain data regarding the tested mineralogical components of aggregate in Seabrook concrete.1 Pursuant to that Order, NextEra hereby submits the attached document, titled Santa Ana Aggregates.2 Please note that the Santa Ana Aggregates document does not explicitly contain any data regarding the tested mineralogical components of aggregate in Seabrook concrete. Rather, it includes an examination of aggregate samples from a New Mexico quarry (which was not used in Seabrooks concrete), along with a comparison of that aggregate to Seabrooks aggregate.
Nevertheless, NextEra is producing that document in an abundance of caution because the Boards Order cites a discussion during the evidentiary hearing in which Mr. Sherman referred to a petrography report that had not been submitted as an exhibit.3 Mr. Sherman was referring to the 1
ASLB Order (Granting C-10s Motion to Compel Mineralogical Data and Request to Submit Supplemental Written Testimony concerning the data; Denying C-10s Motion to Submit Additional Exhibits) at 17 (Nov. 25, 2019).
2 SGH Project No. 120766, Examination of Aggregate Samples from New Mexico by the University of Texas, in Support of the On-Going Evaluation [of] the Impact of ASR, Seabrook Nuclear (Sept. 17, 2012) (FP100750, Rev. 1, Santa Ana Aggregates).
3 Order at 11 (citing Tr. at 1076-77, 1079-80).
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 +1.202.739.3000 United States +1.202.739.3001
D. Curran December 5, 2019 Page 2 Santa Ana Aggregates document. This document was discussed in MPR-42624 (including the documents title and date, and a summary of conclusions),5 which was disclosed and produced to C-10 in early 2018.6 The basis for the comparison of the Santa Ana Aggregates to Seabrooks aggregate is provided in four reference documents listed therein. As explained in NextEras Answer to C-10s original motion on this topic, all of those documents also were disclosed and produced to C-10 in early 2018.7 NextEra has previously disclosed and produced dozens of other documents with information related to aggregate petrography and mineralogy. After a thorough supplemental review of documents and consultations with NextEra personnel and consultants, we are aware of no other documents responsive to the Boards Order that have not previously been disclosed and produced to C-10.
Sincerely, Executed in accord with 10 C.F.R. § 2.304(d)
Paul M. Bessette
Attachment:
Santa Ana Aggregates 4
See Tr. at 1079 (Mr. Simons noting the document was listed as a reference in MPR-4262 Shear and Reinforcement Anchorage Testing of Concrete Affected by Alkali-Silica Reaction, Vol. I, Rev. 1 (July 2016) & Vol. II, Rev. 0 (Jan. 2016) (FP100994) (NER022-R)).
5 MPR-4262 at 4-11 (providing a summary), 10-1 (providing document title and date).
6 Letter from P. Bessette to N. Hildt-Treat, Initial Disclosures Pursuant to 10 C.F.R. § 2.336; NextEra Energy Seabrook, LLC (Seabrook Station Unit 1), Docket No. 50-443-LA-2, Encl. 3 at 8 (item no. 170) (Jan. 4, 2018); Letter from P. Bessette to N. Hildt-Treat, NextEra Energy Seabrook, LLC (Seabrook Station Unit 1), Docket No. 50-443-LA-2 (Mar. 20, 2018).
7 NextEras Answer Opposing C-10s Motions to Compel Production of Mineralogical Data and to Submit Additional Post-Hearing Testimony at 3-4 (Oct. 9, 2019).
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 December 5, 2019 (Seabrook Station Unit 1)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, the foregoing letter from Paul M. Bessette to Diane Curran and its attachment were served upon the Electronic Information Exchange (the NRCs E-Filing System) in the above-captioned proceeding.
Signed (electronically) by Ryan K. Lighty Ryan K. Lighty, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5274 Fax: (202) 739-3001 E-mail: ryan.lighty@morganlewis.com Counsel for NextEra Energy Seabrook, LLC DB1/ 110249335.2