ML20262G967

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Memorandum and Order (Providing Parties' Proposed Questions for the Official Record)
ML20262G967
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 09/17/2020
From: Ronald Spritzer
Atomic Safety and Licensing Board Panel
To:
SECY RAS
References
50-443-LA-2, ASLBP 17-953-02-LA-BD01, RAS 55791
Download: ML20262G967 (67)
v • d • e


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Ronald M. Spritzer, Chairman Nicholas G. Trikouros Dr. Sekazi K. Mtingwa In the Matter of Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC ASLBP No. 17-953-LA-BD01 (Seabrook Station, Unit 1) September 17, 2020 MEMORANDUM AND ORDER (Providing Parties Proposed Questions for the Official Record)

The documents attached to this Memorandum and Order are the proposed witness questions submitted to this Licensing Board by the NRC Staff, C-10, and licensee NextEra during the evidentiary hearing in this proceeding held from September 24-27, 2019, in Newburyport, Massachusetts, at the Newburyport City Hall Auditorium.1 The Board issued its initial decision in this proceeding on August 21, 2020.2 1 See Tr. at 214-1203.

2 LBP-20-9, 92 NRC __ (slip op.) (Aug. 21, 2020).

Out of an abundance of caution, the attached questions were first transmitted to the Office of the Secretary on September 11, 2020, for placement into the NONPUBLIC docket.

After input from the parties to this proceeding regarding the potential proprietary nature of the enclosed questions, the Board, in accord with 10 C.F.R. § 2.1207(a)(3)(iii), hereby reissues the attached questions in the PUBLIC official record of this proceeding.

It is so ORDERED.

FOR THE ATOMIC SAFETY AND LICENSING BOARD

/RA/

Ronald M. Spritzer, Chairman ADMINISTRATIVE JUDGE Rockville, Maryland September 17, 2020 2

Proposed Question NRC Staff Question 1 Wachutka, Jeremy I f-) Rep~ Reply All Forward To O Mattison, Molly Tue 09/24/2019 10:59 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 Q) You forwarded this message on 09/24/201 9 12:56 PM.

Is an in-depth understanding of the specifics of ASR necessary to determine whether NextEra's Method provides reasonable assurance?

RE: Proposed Question NRC Staff Question 2 Wachutka, Jeremy I ~ Repi l l Reply A_"~-- Forward 7 To O Mattison, Molly Tue 09/24/2019 11 :28 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/ 31/2020 3:52 PM.

Is knowing the exact kinetics and rate of ASR expansion at Seabrook necessary to find that NextEra's Method provides reasonable assurance?

RE: Proposed Question NRC Staff Question 3 Wachut ka, Jeremy I~ Rep_lY_ ~<~

_ Reply ~ For w ~ * ** I To O M attison, M olly Tue 09/24/2019 11:56 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/31/2020 3:52 PM.

Dr. Sauoma compares this situation to Gentilly-2. Is this an appropriate comparison?

RE: Proposed Question NRC Staff Question 4 Wachutka, Jeremy ~ Rep_lY~ _<~

_ Reply ~ Forwa~

To O Mattison, Molly Tue 09/24/2019 12:08 PM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/31/2020 3:52 PM.

Is CCI a reliable measurement of ASR expansion?

NRC Staff Question 5 RE: Proposed Question Wachut ka, Jeremy I ~ Repi l l Reply A_"_~- Forward To O Mattison, Molly Tue 09/24/2019 3:07 PM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/31/2020 3:53 PM.

Does it matter where Seabrook is on the sigmoid curve? Would even the steepest slope of the curve challenge the inspection intervals at Seabrook (i.e., demonstrate that they are not short enough)?

RE: Proposed Question NRC Staff Question 6 Wachutka, Jeremy I ~ Repi l l Reply ~ Fo rwa rd To O Mattison, Mo lly Tue 09/24/2019 3:22 PM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/31/2020 3:53 PM.

Will the 6-month inspection interval catch all possible expansions before they hit the limits?

RE: Proposed Question NRC Staff Question 7 Wachut ka,Jeremy ~ Repi l l Repl y ~ Forw~ 9 To O Mattison, Mo lly Tue 09/24/ 2019 4:43 PM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/22/2026 (D You forwarded this message on 08/3 1/2020 3:53 PM.

Are the monitoring, acceptance cri teria, and inspection intervals of the ASR expansion monitoring program and the structure deformation monitoring program the same or different?

C-10 Questions 8-14 September 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 (Seabrook Station, Unit 1) )

_____________________________________)

C-10 RESEARCH AND EDUCATION FOUNDATION, INC.

PROPOSED QUESTIONS FOR ASLB TO POSE DURING ADJUDICATORY HEARING (SUBMITTED TO ASLB ONLY)

C-10 proposes that the ASLB ask two sets of questions regarding Exhibits NER076 and NRC090, which respond to Dr. Saoumas Supplemental Rebuttal Testimony:

1. In Exhibit NER076, NextEra testifies that:

The test data used to determine the correlation were from concrete that had cured to the point that the increase in compressive strength had already been realized (for the great majority of the data) or was insignificantly different from being fully realized (for three other data sets that were used).

Id., A5 at page 2.

Questions. We propose the following clarifying questions to NextEra:

Question 8

  • How many concrete specimens were tested within 60 days of casting?

Question 9

  • How many concrete specimens were tested after two years? Or if you dont know, what was the percentage of the original samples?

Question 10

  • Does NextEra have records of these tests that can be provided to the ASLB?

And we request the ASLB to give Dr. Saouma an opportunity to comment on the information given.

Justification for questions. This phrase great majority of the data can mean anything, and therefore should be clarified. The statement also implies that Seabrook concrete was tested at least two years after it was cast, because it takes concrete about two years to gain its full strength.

That implication should be queried, for the reason that it is most unusual to wait that long to test

concrete during construction. Concrete specimens typically are tested within a month or two after casting the concrete, in order to make sure the contractor has provided the right mix. If not, part of the concrete cast has to be destroyed.

2. The NRC Staff testifies in Exhibit NRC090 that:

NextEra provided two approaches by which the original modulus could be determined 1) use the equation from American Concrete Institute (ACI) 318-71, Section 8.3.1 (NRC049 at 22) to estimate the modulus based on the measured 28-day compressive strength of concrete cylinders cast at the time of Seabrook construction or 2) use reference Seabrook cores representative of original construction and not impacted by ASR.

Id., A5 at page 3.

Questions. We propose the following questions to NextEra:

Question 11

  • What is the margin of error in estimating the elastic modulus based on the ACI equation from ACI 318-71, Section 8.3.1, relating compressive strength to elastic modulus?
  • What is the margin of error in estimating the elastic modulus based on direct Question 12 experimental measurement of the elastic modulus in a laboratory?
  • In casting the Seabrook concrete, there is a great variability in the compressive Question 13 strengths as shown by Exhibit NER001, A115 (3,000 psi to 7,000 psi). Accordingly, what would be the margin of error if NextEra takes the approach of testing samples from areas believed not to be subjected to ASR?

Question 14

  • How do you reconcile the asserted reliability of the corroboration study with the large variability in compressive strength that you specified for the LSTP?

And we request the ASLB to give Dr. Saouma an opportunity to comment on the information given.

Justification for questions: Given that compressive strength varies considerably from batch to batch (i.e., 3,000 psi to 7,000 psi), that would cause a large margin of uncertainty if NextEra were to test cores representative of original construction and not impacted by ASR. Laboratory tests per ASTM standards would provide a reference value.

The answers to these questions (as well as the answer to the question in section 1. above) will have a significant impact on the margin of error/uncertainty in determining the total concrete expansion based on the corroboration study.

Respectfully submitted,

___/signed electronically by/__

Diane Curran

Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com Sept. 25, 2019

NRC Staff Question 15 RE: Proposed Question Wachut ka, Jeremy I f-) Rep~ Reply A_n_~- Forward ~

To O Mattison, Molly Wed 09/25/2019 10:04 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/23/2026 Q) You forwarded this message on 08/3 1/2020 3:58 PM.

Dr. Saouma states that there has been significant shrinkage at Seabrook. Wouldn't this mean that the CCI method is conservative because it counts all surface cracks as from ASR including shrinkage cracks?

RE: Proposed Question NRC Staff Question 16 Wachutka, Jeremy I ~ Rep~ Repl y +/- Forwa~ , ..

  • I To O Mattison, Molly Wed 09/25/2019 10:09 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/31/2020 3:58 PM.

Action Items + Get more add-ins Many of the locations with surface cracking at Seabrook are underground, correct? Therefore, there would be no relative humidity across these walls, correct?

RE: Proposed Qu estion NRC Staff Question 17 Wachut ka, Jeremy I~ Rei l l Reply All Forwa~ D To O Mattison, Molly Wed 09/25/2019 10: 11 AM Cc O Curry, Ian Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/31/2020 3:59 PM.

Action Items + Get more add-ins What evidence does Dr. Saouma have that the surface of the Seabrook walls is less than 80% relative humidity?

RE: Proposed Question NRC Staff Question 18 Wachutka, Jeremy ~ Rep_lY_ ~<~

_ Reply ~ Forward ***

To O Mattison, Molly Wed 09/25/2019 10:25 AM Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/31/2020 4:00 PM.

Seabrook has volumetric expansion limits. Are these monitored using extensometer and pin-to-pin measurements? If so, doesn't this mean that CCI is not necessarily needed for determining whether limits are approached and, thus, CCI uncertainty is not relevant?

NRC Staff Question 19 RE: Proposed Question Wachutka, Jeremy I ~ Rei l l Reply A_II_~- Forward 7 To O Mattison, Molly Wed 09/25/2019 10:49 AM Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/ 31/2020 4:01 PM.

Action Items + Get more add -ins Won't all expansion be caught because the limit is volumetric expansion and the inputs to measuring volumetric expansion are extensometer and pin-to-pin measurements - which are separate fro m CCI?

RE: Proposed Question NRC Staff Question 20 Wachut ka, Jeremy I ~ Rep_lY_ ~<~_ Reply All Forwa~ D To O Mattison, Molly Wed 09/25/2019 12:23 PM Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/31/2020 4:01 PM.

Dr. Saouma advocates for "Direct tension tests" - does he present this in his original testimony or is this a new argument?

RE: Proposed Question NRC Staff Question 21 Wachutka, Jeremy I f-:) Reply <~ Reply ;-r Forwa~ D To O Mattison, Molly Wed 09/ 25/20191:41 PM Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/ 23/ 2026 (D You forwarded this message on 08/3 1/2020 4:0 1 PM.

Dr. Saouma argues that CCI is useful in the early stages of ASR. Isn't that exactly how NextEra proposes to use it (i.e., only until a minimal level of expansion and then switching over to pin-to-pin and extensometer measurements for volumetric expansion)?

RE: Proposed Question NRC Staff Question 22 Wachutka, Jeremy I ~ Rep~ Reply ~ Fo rwa~ D To O Mattison, Mo lly Wed 09/25/2019 2:21 PM Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/31/2020 4:02 PM.

Did Dr. Saouma's original arguments ever address impact loads?

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NRC Staff Question 23 RE: Proposed Question Wachutka, Jere my I~ Rep_lY_ ~<~

_ Reply All Forwa~ E To O Mattison, Molly Wed 09/25/2019 2:38 PM Cc O Curry, Ian;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/23/2026 (D You forwarded this message on 08/3 1/2020 4:04 PM.

Dr. Saouma discusses additional stresses from ASR. Aren't these accounted for by the structure deformation monitoring program?

C-10 Questions 24-28 September 26, 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 (Seabrook Station, Unit 1) )

_____________________________________)

C-10 RESEARCH AND EDUCATION FOUNDATION, INC.

PROPOSED SECOND SET OF QUESTIONS FOR ASLB TO POSE DURING ADJUDICATORY HEARING (SUBMITTED TO ASLB ONLY)

C-10 asks the ASLB to pose two additional sets of questions to NextEra witnesses. The first set of questions consists of follow-up regarding Exhibits NER076 and NRC090, which respond to Dr. Saoumas Supplemental Rebuttal Testimony. The second set consists of follow-up related to representativeness.

1. Follow-up questions related to concrete sampling:

Question 24

  • How many concrete samples (cylinders) did NextEra take during construction?
  • What is the mean value of the compressive strength from these samples? Question 25
  • What is the corresponding standard deviation? Question 26 And we request the ASLB to give Dr. Saouma an opportunity to comment on the information given.

Justification for questions.

The reliability of the corroboration study to determine the total amount of expansion that has occurred so far hinges on - among other things - the reliability of the compressive strength measurements taken during construction. This issue was raised yesterday, and NextEra indicated that they have this data. To be clear about what information is needed from the data, we need to know: how many data points they have, what is the mean, and what is the corresponding standard deviation. These questions elicit that information:

2. Follow-up questions related to representativeness:

Question 27

  • Please provide documentation of the mineralogy analysis of all the constituents of aggregate and sand in both locations.
  • Please provide documentation of the gradation of the aggregates in both locations. Question 28 And please provide Dr. Saouma with an opportunity to comment.

Justification for questions. To fully address the degree of representativeness of the concrete in the LSTP, as compared to concrete in Seabrook, one would need two critical pieces of information. They are: 1) the mineralogy analysis of all the constituents of aggregate and sand in both locations and 2) the gradation of the aggregates in both locations. Both appear to be missing.

Respectfully submitted,

___/signed electronically by/__

Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1725 DeSales Street N.W., Suite 500 Washington, D.C. 20036 240-393-9285 dcurran@harmoncurran.com Sept. 26, 2019

Wachutka,Jeremy I ' ) KeP_IY_..__"_~) Kep1y An I~ t orwara J L.:_" :J To O Mattison, Molly Thu 09/26/2019 12: 13 PM Cc O Curry, Ian;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/24/2026 NRC Staff Question 29 (D You forwarded this message on 08/31/2020 4:04 PM.

Action Items + Get more add-ins Why is the non-linear issue even relevant? Isn't the entire point of the LSTP approach so that the codes can continue to be used? If the LSTP is representative than the non-linear issue is irrelevant, correct?

NRC Staff Question 30 RE: Proposed Question Wachut ka, Jere my ~ Repi l l Repl y ~ Fo rw~ 7 To O Mattison, Mo lly Thu 09/26/2019 2: 10 PM Cc O Curry, Ian;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/24/2026 (D You forwarded this message on 08/31/2020 4:05 PM.

Isn't the purpose of conducting the LSTP so that the fin ite element analysis does not have to use degraded material properties?

NRC Staff Question 31 RE: Proposed Question Wachut ka, Jeremy 2 Rep~ Reply All Forwa~

To O Mattison, Molly Thu 09/26/2019 2:26 PM Cc O Curry, Ian;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/24/2026 (D You forwarded this message on 08/31/2020 4:05 PM.

Action Items + Get more add-ins Dr. Saouma says that ASR causes cracking on the surface. Previously, he said that ASR can happen without surface cracking. Why the inconsistency?

RE: Proposed Question NRC Staff Question 32

~ Scro, Jennifer

~ Repi l l Reply All Forward 3

'Ye To O Mattison, Molly; 0 Mayhall, Taylor Thu 09/26/ 2019 2:45 PM Cc O Curry, Ian;

  • Wachutka, Jeremy Retention Policy 7 Years (7 years) Expires 09/24/2026 (D You forwarded this message on 08/31/2020 4:05 PM.

On PDF page 11 of Exhibit INT001-R, Dr. Saouma states that the FHWA report (NER013) provides "a road map on how to deal with ASR using modern tools." He now implies that the FHWA report is not a "guideline" and not relevant to reviewing ASR at Seabrook. Can he explain this inconsistency?

NRC Staff Question 33 RE: Proposed Question Wachut ka, Jere my I ~ Rep~ Reply +/- Fo rwa~ D To O Mattison, Molly Thu 09/26/2019 3:09 PM Cc O Mayhall, Taylo r;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/24/2026 (D You forwarded this message on 08/31/2020 4:06 PM.

Can the results of later generic research into ASR be applied by the NRG to Seabrook, as appropriate?

NRC Staff Question 34 RE: Proposed Question Wachutka, Jeremy I ~ Rep_lY_ ~<~

_ Repl y +/- For w ~ 3 To O Mattison, Molly Thu 09/26/2019 3:13 PM Cc O Mayhall, Taylor;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/24/2026 (D You forwarded this message on 08/31/2020 4:06 PM.

Does the NRC need generic guidance on ASR in order to approve NextEra's ASR license amendment request?

NRC Staff Question 35 RE: Proposed Question Wachut ka, Jeremy I f-) Repi l l Reply A_II~-- Forward To O Mattison, Molly Fri 09/27/2019 9:51 AM Cc O Mayhall, Taylor;

  • Scro, Jennifer Retention Policy 7 Years (7 years) Expires 09/25/2026 (D You forwarded this message on 08/31/2020 4:07 PM.

Dr. Saouma, look at the line on th e graph of LSTP data of micro-cracked test specimens, isn't it linear?

From: Wachutka, Jeremy NRC Staff Question 36 Sent: Friday, September 27, 2019 9 :51 AM To: Mattison, Molly <Molly.Mattison@nrc.gov>

Cc: Mayha ll, Taylor <Taylor.Mayhall@nrc.gov>; Scro, Jen nife r <Jennifer.Scro@nrc.gov>

Subject:

RE: Proposed Question Dr. Saouma, look at the line on the graph of LSTP data of micro-cracked test specimens, isn't it linear?

RE: Proposed Question NRC Staff Question 37

~ Scro, Jennifer I~ Repi l l Reply ~ Forwa~ E

~ To O Mattison, Molly; 0 Mayhall, Taylor Fri 09/27/2019 10:34 AN Cc

  • Wachutka, Jeremy Retention Policy 7 Years (7 years) Expires 09/ 25/ 2026 (D You forwarded this message on 08/ 31/ 2020 4:08 PM.

Action Items + Get more add-ins The Sigmoid curve did not factor into the staffs review because the staff determined that 6 months would be a sufficient interval even assuming the fastest known ASR expansion (i.e., no matter where Seabrook is on the Sigmoid curve, the inspection intervals are adequate),

correct?

NRC Staff Questions 38-72 September 19, 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)

PROPOSED QUESTIONS Pursuant to 10 C.F.R. § 2.1207(a)(3) and the Boards Initial Scheduling Order, 1 the U.S.

Nuclear Regulatory Commission Staff hereby submits, in camera, proposed questions for the Board to consider asking. The proposed questions are directed to the Staffs expert witnesses or to C-10 Research and Education Foundations expert witness, as specified below. The Staff has no proposed questions for NextEra Energy Seabrook, LLCs expert witnesses.

I. Proposed Questions for Staff Witnesses A. NRC Licensing Practices and the Relevance of C-10s Arguments The Staff is concerned that C-10 appears to have numerous misconceptions regarding NRC licensing practices and what is relevant to these licensing practices. These proposed questions explore this issue.

Question 38

1. Please explain how the NRC initially licenses nuclear power plants, what general design criteria are, and how the documents supporting initial licensing become part of the plants licensing basis.

1 Initial Scheduling Order, at 4-5 (Nov. 29, 2017) (unpublished) (ML17333A981).

Question 39

2. Please explain the concept of reasonable assurance of adequate protection of public health and safety.

Question 40

3. Which general design criteria are relevant to this proceeding?

Question 41

4. What licensing basis documents are at issue in this proceeding?

Question 42

5. What are consensus codes and standards? How are they developed? How are they used in NRC licensing?

Question 43

6. Please explain how licensees typically use monitoring programs to ensure that a plant remains in compliance with its licensing basis. How does the method proposed by NextEra in its license amendment request compare to this? How does the method proposed by Dr. Saouma in his testimony compare to this?

Question 44

7. What methods are available to change a plants licensing basis after initial licensing? How is the reasonable assurance standard relevant to these changes? Question 45
8. Is a licensee required to change its licensing basis documents just because they are old?

Question 46

9. Dr. Saouma states that the NRC should have done more to ensure that standards and guidance would be established for ASR (INT028 at 9-10). Does the NRC need to have existing standards or guidance on an issue before it can address a site-specific license amendment regarding that issue?

Question 47

10. Dr. Saouma argues that instead of the method advanced in the license amendment request (i.e., replicating the effect of ASR on Seabrook structures out to a bounding level of expansion and then monitoring the Seabrook structures themselves to ensure that they stay within this bounding level), NextEra should have used a different method (i.e., accelerated expansion tests on Seabrook cores, periodic damage rating index measurements, and predictive modeling). Is the assertion that a different method should have been used relevant to

the Staffs finding that the method actually proposed in the license amendment request provided reasonable assurance?

B. Scope of the Proceeding The Staff believes that there is a fundamental disagreement between it and Dr. Saouma on the scope of this proceeding. These proposed questions explore this issue.

Question 48

1. Please explain how the monitoring for ASR expansion is based on the LSTP.

Question 49

2. Please explain how the acceptance criteria for ASR expansion are based on the LSTP.

Question 50

3. Please explain how the inspection intervals for ASR expansion are based on the LSTP.

Question 51

4. The license amendment request also proposed a structure deformation monitoring program. What monitoring is a part of this program? What are the acceptance criteria for this program? What are the inspection intervals for this program? How are these different from the monitoring, acceptance criteria, and inspection intervals for the ASR expansion monitoring program?

Question 52

5. Are any data from the LSTP used as direct inputs for the structure deformation monitoring program?

Question 53

6. Please explain the relationship between the LSTP and the structure deformation monitoring program?

C. Peer/Independent Reviews C-10 faults the Staff for not having peer review as part of its licensing process. These proposed questions explore whether peer review is a part of this process. Question 54

1. One of Dr. Saoumas main criticisms is his claim that an independent peer review was not conducted for the method used by NextEra in its license amendment request. Do the

Commissions regulations or the Staffs practices require independent peer review for license amendment requests? Was independent peer review required for the Staff to make its reasonable assurance finding? Question 55

2. Even if it was not required, did the Staff obtain independent reviews of NextEras method? What did these independent reviews find?

D. Comparison of ASR at Seabrook to Other Situations C-10 compares the ASR at Seabrook to other situations. These proposed questions explore whether these situations are actually comparable.

Question 56

1. Dr. Saouma states that the approach he advocates was used in the analysis of the Gentilly-2 nuclear power plant (INT028 at 4-5). Is this relevant to Seabrook? Does this affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request? Question 57
2. Dr. Saouma points to a Swiss publication regarding dams (INT028 at 4-5). Is this relevant to Seabrook? Does this affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request?

Question 58

3. Dr. Saouma argues that a delamination crack at Seabrook similar to the cracks discovered at Crystal River is in the realm of possibilities (INT028 at 26-33). Is this relevant to Seabrook? Does this affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request?

E. Dr. Saoumas Challenges to the Staffs Reasonable Assurance Finding Although the majority of Dr. Saoumas arguments seem to support an alternative to the method proposed in the license amendment request (i.e., Dr. Saoumas Method vs. NextEras Method), which is not the subject of this proceeding, a few of his arguments, interpreted in a

light most favorable to C-10, challenge NextEras Method. These proposed questions explore whether such challenges affect the Staffs reasonable assurance determination. Question 59

1. Dr. Saouma argues that ASR poses a risk to structures at Seabrook. Based on your knowledge, experience, and analysis of the license amendment request, what is the risk posed by ASR at Seabrook? Question 60
2. Dr. Saouma argues that the LSTP was not representative of Seabrook because it did not use identical concrete (INT001 at 10). Does this argument affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request?

Question 61

3. Dr. Saouma states that ASR follows a sigmoid curve and that at some point it takes off and progresses much faster (INT028 at 13). Based on your knowledge, experience, and analysis of the license amendment request, do you agree with this claim regarding the behavior of ASR at Seabrook? Even assuming that this argument is correct as applied to Seabrook, does it affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request? Question 62
4. Does the Staff need to know the potential ultimate expansion of ASR at Seabrook, as Dr. Souma claims (INT001 at 11), to make a reasonable assurance finding with respect to the license amendment request?

Question 63

5. Dr. Saouma argues that there are relative humidity and temperature gradients in the walls at Seabrook. He further argues that these gradients, coupled with the rebar being located close to the surfaces of the walls, will result in cracking on the surfaces of the walls that is not representative of the cracking in the interior. Based on these arguments, Dr. Saouma concludes that CI/CCI is not reliable (INT028 at 21-24, 26). Do you agree with these arguments? Do these arguments affect the Staffs reasonable assurance determination regarding the method proposed in the license amendment request?

Question 64

6. Dr. Saouma argues that the process for calculating through-thickness expansion to date in Seabrook concrete does not sufficiently account for uncertainties (INT028 at 36-40).

What is your response?

Question 65

7. Dr. Saouma discusses the rupture of rebar due to ASR (INT028 at 20-21).

Based on your knowledge, experience, and analysis of the license amendment request, do you agree with Dr. Saoumas discussion on this point?

Question 66

8. Dr. Saouma argues that the edge-effect crack that developed during the LSTP may have impacted the validity of the shear tests (INT028 at 26-29). Based on your knowledge, experience, and analysis of the license amendment request, do you agree with this argument? Question 67
9. Dr. Saouma argues that the test specimens were not properly scaled. Based on your knowledge, experience, and analysis of the license amendment request, do you agree with this argument?

Question 68

10. How does the license condition provide additional assurance?

II. Proposed Questions for C-10 Witness A. Inconsistency in Dr. Saoumas Arguments It appears to the Staff as though Dr. Saouma makes inconsistent statements regarding the FHWA Report. These proposed questions explore this issue. Question 69

1. The FHWA Report notes that CI/CCI provides a quantitative rating of the surface deterioration affecting the structure as a whole (NER013 at 23). In your direct testimony, you state that the FHWA Report (NER013) provides a road map on how to deal with ASR using modern tools (INT001 at 6) but you also state that Surface measurements of CI/CCI [are]

misleading (INT001 at 36). How do you reconcile these statements?

Question 70

2. In your direct testimony, you fault NextEra for not using CI/CCI in conjunction with petrography studies, consistent with your interpretation of the FHWA Report (INT001 at 20). However, in your rebuttal testimony, you seem to imply that the FHWA Report is wholly inapplicable to nuclear reactors as the report was written for bridges (INT028 at 25). How do you reconcile these statements?

B. Apparent Lack of Evidence to Support Dr. Saoumas Arguments Dr. Saouma appears to make assertions without any exhibits to support them. These proposed questions explore this issue. Question 71

1. You state that a delamination crack at Seabrook similar to the cracks discovered at Crystal River is in the realm of possibilities (INT028 at 26-33). Is there any support in the record for a delamination crack resulting from ASR? Question 72
2. You state that the cracking on the surface of Seabrook structures will not represent the cracking in the interior of the structures and that, therefore, the use of CI/CCI at Seabrook is not reliable (INT028 at 21-24, 26). Is there any support in the record for internal expansion affecting a structure without any outward indication, such as surface cracks or deformation?

Respectfully submitted,

/Signed (electronically) by/

Jeremy L. Wachutka Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O14-A44 Washington, DC 20555 Telephone: (301) 287-9188 E-mail: Jeremy.Wachutka@nrc.gov Executed in Accord with 10 CFR 2.304(d)

Anita Ghosh Naber Counsel for the NRC Staff

U.S. Nuclear Regulatory Commission Mail Stop O14-A44 Washington, DC 20555 Telephone: (301) 415-0764 E-mail: anita.ghoshnaber@nrc.gov Executed in Accord with 10 CFR 2.304(d)

Jennifer E. Scro Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O14-A44 Washington, DC 20555 Telephone: (301) 287-9081 E-mail: Jennifer.Scro@nrc.gov Dated at Rockville, Maryland this 19th day of September 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)

CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that copies of the foregoing PROPOSED QUESTIONS, dated September 19, 2019, have been filed, in camera, through the Electronic Information Exchange, the NRCs E-Filing System, in the above-captioned proceeding, this 19th day of September 2019.

/Signed (electronically) by/

Jeremy L. Wachutka Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O14-A44 Washington, DC 20555 Telephone: (301) 287-9188 E-mail: Jeremy.Wachutka@nrc.gov Dated at Rockville, Maryland this 19th day of September 2019

NextEra Questions73-142 Confidential Pending Release by the Licensing Board Per 10 C.F.R. § 2.1207(a)(3)(iii)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of: )

) Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC )

) September 19, 2019 (Seabrook Station Unit 1) )

)

NEXTERAS PROPOSED QUESTIONS FOR THE BOARD TO PROPOUND TO DR. SAOUMA Steven Hamrick, Esq. Paul M. Bessette, Esq.

NextEra Energy Seabrook, LLC Morgan, Lewis & Bockius LLP 801 Pennsylvania Ave., NW Suite 220 1111 Pennsylvania Avenue, N.W.

Washington, D.C. 20004 Washington, D.C. 20004 Phone: (202) 349-3496 Phone: (202) 739-5796 Fax: (202) 347-7076 Fax: (202) 739-3001 E-mail: steven.hamrick@fpl.com E-mail: paul.bessette@morganlewis.com 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

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TABLE OF CONTENTS I. INTRODUCTION ............................................................................................................. 1 II. EXAMINATION PLAN FOR DR. SAOUMA ................................................................. 2 A. Structural Evaluations / FEMs Do Not Use LSTP Values .................................... 2 B. Many of Dr. Saoumas Comments Are Unrelated to the Key Issue In This Proceeding: the Representativeness of the LSTP Specimens .................... 3 C. Many of Dr. Saoumas Claims Are Unsupported or Counterfactual ..................... 4 D. Dr. Saoumas Commentary on Seismic Analysis Contradicts NRC Guidance ................................................................................................................ 7 E. Abandonment of Code-Based Analysis Is Unnecessary and Impractical.............. 9 F. The Use of Identical Concrete Mix Is Unnecessary and Impractical ............... 11 G. Nonlinear Analysis Is Unnecessary Because Seabrooks Structures Are Required to Remain Within Linear-Elastic Limits .............................................. 12 H. Dr. Saoumas Assertion that ASR Expansion Is Not a Load Is Incorrect and Contradicts Consensus Codes ....................................................................... 13 I. ASR Expansion Behavior Is Different in Confined vs. Unconfined Concrete ............................................................................................................... 13 J. Many of Dr. Saoumas Recommendations Are Unnecessary in the Context of the LAR ........................................................................................................... 15 K. Most of Dr. Saoumas Rebuttal Testimony Seeks to Comment on Aspects of the LAR That Were Available Before His Initial Testimony Was Filed ........ 16 L. Dr. Saouma Lacks Experience in Practical Structural Engineering .................... 19

Confidential Pending Release by the Licensing Board Per 10 C.F.R. § 2.1207(a)(3)(iii)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of: )

) Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC )

) September 19, 2019 (Seabrook Station Unit 1) )

)

NEXTERAS PROPOSED QUESTIONS FOR THE BOARD TO PROPOUND TO DR. SAOUMA I. INTRODUCTION Pursuant to 10 C.F.R. § 2.1207(a)(3), and in accordance with the Atomic Safety and Licensing Boards (Board) Initial Scheduling Order,1 and Case Management Instructions,2 NextEra Energy Seabrook, LLC (NextEra) submits the following proposed questions for the Board to consider propounding to C-10 Research and Education Foundation, Inc.s (C-10) witness, Dr. Victor Saouma.

As requested by the Board,3 this submittal provides a brief description of the issues that require further examination, the objectives of the examination, and the proposed questions that may logically lead to achieving the objectives. For the convenience of the Board, NextEra has included a table of contents.

1 ASLB, Initial Scheduling Order at 4-5 (Nov. 29, 2017) (unpublished) (ISO) (directing parties to file any proposed questions for the Board to propound to witnesses at least five (5) days before the date of the hearing). The hearing in this matter is set to begin September 24, 2019. ASLB, Order (Scheduling Evidentiary Hearing) at 1 (Apr. 5, 2019) (unpublished). Therefore, this filing is timely. See also ASLB, Memorandum and Order (Revised Scheduling Order) at 2 n.9 (Feb. 15, 2018) (unpublished) (revising certain milestone dates but stating [t]he remainder of the Initial Scheduling Order continues to be in effect).

2 ASLB, Order (Providing Case Management Instructions at 5 (May 23, 2019) (unpublished).

3 ISO at 5.

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II. EXAMINATION PLAN FOR DR. SAOUMA A. Structural Evaluations / FEMs Do Not Use LSTP Values

1. Brief Description of the Issue In his testimony, Dr. Saouma claims that data from the LSTP became inputs to the finite element analysis relied on by NextEra.4 C-10 previously argued that this alleged linkage opens the door for their challenge the Deformation Monitoring portion of the LAR (which was not explicitly challenged in the original Petition).5 But as noted in NextEras Testimony, the finite element models do not use values from the LSTP. They only use: (1) values from Seabrooks existing UFSAR, and (2) ASR load and load factor values calculated from field measurements of Seabrooks concrete.6 NextEras experts confirmed that [n]o specific measurements, calculations, data, or other information from the LSTP are direct inputs into the SEM or structural evaluations.7
2. Objective of the Examination To demonstrate that Dr. Saoumas assertion is incorrect and unsupported.
3. Proposed Line of Questioning Question 73 In your Testimony, you assert that data from the LSTP became inputs to the finite element analysis relied on by NextEra. But your Testimony points to no place in the FEM where numerical data from the LSTP was used, correct? Question 74

[If Dr. Saouma argues that numerical data from the LSTP was used in the FEMs]: Which exhibits support your claim?

4 Saouma Testimony at 17 (INT001-R); see also id. at 8.

5 C-10 Research and Education Foundations Opposition to NextEras Motion in Limine at 6-7 (May 3, 2019).

6 MPR Testimony at A209 (NER001).

7 Id. at A40.

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[If Dr. Saouma discusses the use of unreduced elastic modulus or other material properties from the original design calculations rather than the LSTP]:

Question 75 o Those values are specified in Seabrooks existing license and do not come from the LSTP, correct?

Question 76 o Are you aware that the LSTP is not the sole basis for using the strength and stiffness values in Seabrooks existing license?

Question 77 o Did you review NextEras response to RAI D-10 (NRC015),

which explains that both existing literature and independent confirmatory analysis by SGH support the conclusion that the existing strength and stiffness values can be used?

Question 78 o But your written testimony did not challenge the representativeness of those other bases for using the original design calculations did it?

B. Many of Dr. Saoumas Comments Are Unrelated to the Key Issue In This Proceeding: the Representativeness of the LSTP Specimens

1. Brief Description of the Issue Dr. Saoumas testimony offers a wide-ranging commentary on all aspects of the LAR.

But most of this commentary is unrelated to the admitted contention. For example, Dr. Saouma comments on the method of seismic analysis used in the individual structural evaluations. But the LAR does not propose to change the method, which is already specified in the UFSAR.

Moreover, that method is explicitly approved for use by consensus codes and NRC guidance.

Dr. Saouma offers no explanation of any purported connection between the method of seismic analysis (or his other wide-ranging comments) and the representativeness of the LSTP.

2. Objective of the Examination To demonstrate that much of Dr. Saoumas testimony is outside the scope of this adjudicatory proceeding.

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3. Proposed Line of Questioning Question 79 In Section A.11 of your Testimony (INT001-R), you contrast the approach used at Gentilly-2 with NextEras approach. But this material is unrelated to the question of the representativeness of the LSTP, isnt it?

Question 80 In Section 3.4.1 of your Testimony (INT001-R), you offer 18 criticisms of various aspects of the Rev. 0 CEB Evaluation. But none of these criticisms relate to the question of the representativeness of the LSTP, do they?

C. Many of Dr. Saoumas Claims Are Unsupported or Counterfactual

1. Brief Description of the Issue A large portion of Dr. Saoumas testimony is devoted to discussing alleged benefits of new and experimental methods for ASR analysis, primarily a method developed by Dr. Saouma himself. But his criticisms of the LAR are largely conclusory and speculative.8 In fact, many of his claims are factually unsupported or contradicted by documents that have long been available to C-10. For example, he asserts that NextEra did not address potential failure of reinforcement from chemical pre-stressing.9 But Section 6.2 of MPR-4288 addresses this topic directly. It is therefore unclear whether Dr. Saouma reviewed this material. As another example, he claims (without citation to any basis) that expansion inside concrete structures at Seabrook is almost certain to be much higher than what can be observed on the surface of the structure via crack-width measurements.10 But this assertion is contrary to the actual observed condition of Seabrooks concrete, as shown in over 200 cores that have been extracted and visually 8

See, e.g., SGH Testimony at A104 (NER004).

9 Rebuttal Testimony § D.5.1 (INT028).

10 Rebuttal Testimony at 23-24 & fig.8 (INT028).

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) examined.11 Moreover, literature cited by Dr. Saouma himself (the Swiss Dam Report (NER075)) describes crack-width indexing as state of the art.

2. Objective of the Examination To contrast the extensive research and development that went into the LAR with the speculative and conclusory assertions made by Dr. Saouma, which are frequently unsupported.
3. Proposed Line of Questioning Question 81 In section D.5.1 of your Rebuttal Testimony, you claim that NextEra and its consultants failed to address potential failure of reinforcement from chemical pre-stressing. However, Section 6.2 of MPR-4288 evaluates the potential for reinforcement fracture and leverages work at FSEL that was supervised by Dr. Bayrak prior to the LSTP. Are you aware of this effort and its conclusions?

Question 82 o So do you now acknowledge that NextEra explicitly considered potential reinforcement failure?

In your Rebuttal Testimony, including figure 8, you state that expansion inside concrete structures at Seabrook is almost certain to be much higher than what can be observed on the surface of the structure via crack-width measurements.

Question 83 o Are you aware that Section 1.3.2. of NextEras Structures Monitoring Program (SMP) (NER007) requires that all cores that are taken for extensometer installations must be subjected to visual examination to confirm the absence of mid-plane cracks?

Question 84 o Are you aware that, to date, over 200+ visual examinations of Seabrook cores have been performed and have not shown this phenomenon that you claimed was almost certain to be present?

Question 85 o And your written Testimony fails to cite any technical basis, using data from actual nuclear plant structures, for your speculation in figure 8?

11 See MPR Testimony at A167 (NER001); MPR 0326-0062-88, Rev. 2, Initial Expansion Assessment of ASR Affected Reinforced Concrete Structures at Seabrook Station (Mar. 2018) (NER020) (explaining that mid-plane cracks have not been observed in the cores).

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Question 86 In Section A.10 of your rebuttal testimony, you reference a 2017 report from the Swiss Committee on Dams, titled Concrete Swelling of Dams in Switzerland. Were you aware that this report characterizes crack-width measurement as being the state of the art technique for ASR detection and monitoring?

Question 87 In Section C.2.3.1 of your Testimony (INT001-R), you include a figure 5, which shows stirrups were present in the test region. Further your discussion postulates that shear reinforcement was present and influenced the test results. Testimony from MPR (A205) and the NRC Staff (A41) indicates that shear reinforcement was not, in fact, present in the test region. Given that your statement is counterfactual, there is no longer a basis for your disagreement, is there?

Question 88 o In that same discussion, your figure 5 shows a shear crack.

NextEras Testimony (A205) points out that the crack is shown in the wrong location (low shear region) and points in the wrong direction. Do you acknowledge that your figure 5 was erroneous in both respects?

Question 89 In your Testimony, you suggest that NextEras characterization of the slow rate of ASR development is inappropriate. But your written testimony provides no technical basis and cites no technical authority suggesting that the 6-month monitoring frequency for extensometers is inadequate, does it?

Question 90 o And your Testimony points to no examples of ASR-affected structures where monitoring at an interval of less than 6 months was important for the purpose of ensuring that the structure can perform its design function?

Question 91 You performed no independent structural calculations or finite element modeling for Seabrook structures to support your Testimony, is that correct?

Question 92 You did not run the Saouma Model (or any other constitutive / chemo-mechanical / predictive models) and compare the results with the LSTP results, did you?

Question 93 o [If yes to either of these]: In which exhibits are those results presented?

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D. Dr. Saoumas Commentary on Seismic Analysis Contradicts NRC Guidance

1. Brief Description of the Issue Seabrooks existing UFSAR specifies that seismic analysis of structures be performed using the lumped-mass stick model methodology, and that an analysis of soil-structure interaction (SSI) need not be included because Seabrooks structures are founded on hard rock with shear wave velocity greater than 8,000 ft/sec.12 The seismic analyses for structural evaluations performed pursuant to the LAR are consistent with these requirements. In his testimony, Dr. Saouma criticizes the stick model as an unacceptable model of the past, and criticizes NextEras structural evaluations for not performing SSI analyses.13 However, the most recent versions of NRC guidance on seismic analysis (revised in 2013) and industry code ASCE-SEI 4-16 (revised in 2016) explicitly approve the use of the stick model methodology,14 and confirm that SSI analysis is unnecessary when shear wave velocities are greater than 8,000 ft/sec.15
2. Objective of the Examination To demonstrate that Dr. Saoumas criticisms of the seismic analyses are unsupported and contrary to consensus codes and NRC-approved seismic methodologies.
3. Proposed Line of Questioning Question 94 Regarding seismic analysis, in your testimony, you claim that the stick model is a model of the past when computers did not have sufficient capability to handle the time history analysis of 3D model. Are you 12 SGH Testimony at A114, A115 (NER004).

13 Saouma Testimony at 27 (item 14) and 29 (item 18 & fig. 17) (INT001-R).

14 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Plants: LWR Edition, Chapter 3, Design of Structures, Components, Equipment, and Systems, Section 3.7.2, Seismic System Analysis, Rev. 4 at 11 (Sept. 2013); ASCE Standard ASCE/SEI 4-16, Seismic Analysis of Safety-Related Nuclear Structures § 3.1.3.3 (2016) (NER036).

15 Id. at 15.

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) aware that the 2013 version of the NRCs Standard Review Plan (NUREG-0800) Section 3.7.2, and ASCE/SEI § 3.1.3.3 explicitly approve the use of this methodology?

Question 95 o Are you aware that NRC guidance is entitled to special weight?

Question 96 o Are you aware that ASCE/SEI 4-16 also explicitly approves the use of this methodology?

Question 97 Your written Testimony does not challenge any specific aspect of the ASCE/SEIs and NRCs technical basis regarding the acceptability of the stick model, does it?

Question 98 o Your written Testimony cites no studies or other evidence to demonstrate that the ASCE/SEIs and NRCs technical basis is unsound, is that correct?

Question 99 o Which exhibits supposedly support this challenge?

You criticized Revision 0 of the structural evaluation for the Containment Question 100 Enclosure Building because it did not account for soil structure interaction (or SSI), which you assert is required by ASCE/SEI 4-16. Are you aware that ASCE/SEI 4-16 § 5.1.1(a)(3) specifies that SSI is unnecessary if the shear wave velocity is 8,000 ft/s or greater?

Question 101 o Are you aware that SRP § 3.7.2 says the same?

o Are you aware that Seabrooks UFSAR explains that the site Question 102 has a shear wave velocity between 8,000-10,000 ft/s?

Question 103 o Do you still maintain that NextEras seismic analyses must include SSI analyses?

Question 104 o [If yes]: What is the basis for your conclusionare you purporting to challenge the value of Seabrooks shear wave velocity, or the conclusions in ASCE/SEI 4-16 and NUREG-0800?

Question 105 o But your written Testimony articulates no technical basis for such a challenge, does it?

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E. Abandonment of Code-Based Analysis Is Unnecessary and Impractical

1. Brief Description of the Issue In his testimony, Dr. Saouma asserts that Seabrook should be investigated through th[e]

angle [of probabilistic risk evaluation] and not through a 1971 design code.16 Indeed, Dr.

Saouma devotes a large portion of his testimony to discussing alternative methods for analyzing ASR. But as NextEras experts explain, these methods are more appropriate for academic study than practical application at an operating nuclear power plant; and given NextEras approach of monitoring (rather than simply predicting), they are unnecessary. More importantly, the NRC Staff reviews the application as submitted by the applicant, not other methods by which the same thing might be accomplished.

2. Objective of the Examination To demonstrate that abandonment of code-based analysis is unnecessary and impractical, and that Dr. Saoumas testimony on this topic identifies no deficiency in the LAR.
3. Proposed Line of Questioning Question 106 In your testimony, you recommend not using the code-based approach in favor of other methods including probabilistic and constititutive models.

But there is no operating experience from the U.S. nuclear industry using the methods you recommend, correct?

Is it a true statement that no nuclear plant operator has ever tied a Question 107 nonlinear, probabilistic, constitutive-based finite element model for ASR back to the remainder of its licensing basis with acceptable standards of performance and structural reliability?

Question 108 The field observations at Seabrook structures typically show ASR pattern cracking and formation of gel at a few locations on a wall, while the rest of the same wall shows no ASR or much lower ASR intensity, even though both portions are subjected to the same or similar temperature and 16 Saouma Testimony at 30 (INT001-R).

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) humidity. But a probabilistic or constitutive model could not simulate this observed variation without detailed historical data (e.g., humidity), right?

o Are you aware that no such information has been collected at Question 109 Seabrook since the time of its construction?

Question 110 o Thus, a probabilistic or constitutive model could not be used at Seabrook, right?

Question 111 o [If Dr. Saouma disagrees]: Are you aware that the Gentilly-2 example you cited was heavily instrumented (for example, with 139 extensometerssee NER038 at 11) at the time of construction in order to collect the data necessary for a constitutive model?

Question 112 In your testimony you criticize NextEras methodology as insufficient to predict the ultimate ASR strains in the structure. Do you acknowledge that the fundamental approach in the Seabrook LAR is not to predict the ultimate ASR strains but rather to put in place a comprehensive monitoring program that assures the strains do not exceed acceptable limits?

Question 113 Many engineering programs for managing material degradation in the nuclear industry and other industries rely on monitoring a component or structure against established acceptance criteria without predicting the ultimate condition. Are you familiar with such programs?

Question 114 o If actions are taken if/when the acceptance criteria are reached, could not such an approach be used for ASR-affected reinforced concrete structures?

Question 115 No nuclear power plants within the U.S. or around the world employ the Saouma method in managing ASR, correct?

Question 116 Your position on representativeness appears to be driven by a goal of predicting the progress of ASR and its expansion potential. Do you acknowledge that level of representativeness necessary for a predictive model is fundamentally different than the level necessary for NextEras approach, which does not rely on predictions of future ASR expansion?

Question 117 In your testimony, you discuss the need to predict residual reactivity and expansion potential to support application of a predictive model. But information regarding residual reactivity is irrelevant to a program that does not seek to predict ASR expansion, isnt it?

Question 118 MPRs testimony cites a 2017 technical paper from Esposito and Hendricks (NER037) that concludes constitutive (also known as chemo-10

Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) mechanical) models are largely theoretical and would require additional development work before they could ever be applied to actual structures.

This tends to contradict your opinion that such models are the only valid approach for addressing ASR-affected structures at a currently operating nuclear power plant, doesnt it?

Question 119 None of the constitutive models cited in your Testimony have industry-consensus acceptance criteria, do they?

F. The Use of Identical Concrete Mix Is Unnecessary and Impractical

1. Brief Description of the Issue In his testimony, Dr. Saouma criticizes the LSTP for not using the identical aggregate and sand from the same quarry as Seabrook to construct the test specimens.17 NextEras experts explain that the use of identical aggregate was neither possible nor practical for the LSTP.18 But if, as Dr. Saouma suggests, concrete is so sensitive to variables to the point that identical representativeness is indispensable, then much of the industry research on concrete would be invalid.
2. Objective of the Examination To demonstrate that Dr. Saoumas criticism of the LSTP for not using identical aggregate is unrealistic and identifies no deficiency in the LAR.
3. Proposed Line of Questioning Question 120 In your testimony, you criticize the LSTP for not using the identical aggregate and sand from the same quarry as Seabrook to construct the test specimens. But the international community of specialists who develop the codes for use of structural concrete continue to rely on a range of test programs with a wide variety of constituents, dont they?

o Thus, the consensus of structural concrete experts is that Question 121 concrete is not so sensitive to variables to the point that identical representativeness is indispensable, right?

17 Saouma Testimony at 10 (INT001-R).

18 MPR Testimony at A115-A122, A198 (NER001).

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In your research for the NRC, you used additives to accelerate expansion, correct?

Question 122 o Are the results of your research then of limited usefulness for evaluating actual ASR-affected structures because they have been mixed with substances not present in the original aggregate mix?

G. Nonlinear Analysis Is Unnecessary Because Seabrooks Structures Are Required to Remain Within Linear-Elastic Limits

1. Brief Description of the Issue In his testimony, Dr. Saouma criticizes the LAR methodology for not using nonlinear analysis.19 However, Seabrooks UFSAR requires structures to remain in the linear-elastic performance range.20 Thus, nonlinear analysis is not relevant to Seabrooks structures.
2. Objective of the Examination To demonstrate that Dr. Saoumas recommendation of nonlinear analysis is unsupported, unnecessary, and identifies no deficiency in the LAR.
3. Proposed Line of Questioning Question 123 In your testimony, you criticize the LAR methodology for not using nonlinear analyses. Are you aware that Seabrooks UFSAR requires structures to remain in the linear-elastic range?

Question 124 Are you arguing that Seabrooks license should authorize nonlinear structural behavior?

o [If yes]: But your written Testimony provides no technical Question 125 basis to show that such an approach is conservative, does it?

o [If no]: Then there is no need for NextEra to analyze Question 126 something that is not authorized by its license, is there?

19 Saouma Testimony at 7, 24 (item 1), 28 (item 16), and 28-29 (item 18) (INT001-R).

20 SGH Testimony at A96 (NER004).

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H. Dr. Saoumas Assertion that ASR Expansion Is Not a Load Is Incorrect and Contradicts Consensus Codes

1. Brief Description of the Issue In his testimony, Dr. Saouma claims that The assumption that ASR can be considered a load is fundamentally wrong.21 But as NextEras experts explain, if ASR only changed material properties and not load (as asserted by Dr. Saouma) then there would be no displacements or deformations associated with ASR. Yet field observations at Seabrook demonstrate there are, in fact, displacements and deformations.
2. Objective of the Examination To demonstrate that Dr. Saoumas understanding of loads is unsupported.
3. Proposed Line of Questioning Question 127 In your testimony, you state that The assumption that ASR can be considered a load is fundamentally wrong. But the definition of load in widely-accepted industry codes such as ASCE/SEI 7-16 § 1.2.1 defines load as forces or other actions that result from . . . environmental effects, differential movement, and restrained dimensional changes. Do you disagree with this definition of loads?

Question 128 o [If yes]: What exhibits provide the technical basis for your disagreement?

Question 129 o [If no]: Are you aware that Seabrooks structures have actually deformed due to ASRin other words, that ASR forces have caused the building to change?

I. ASR Expansion Behavior Is Different in Confined vs. Unconfined Concrete

1. Brief Description of the Issue NextEras witnesses explain that the chemical prestressing effect in reinforced concrete has an apparent benefit to the structural performance of concretei.e., does not degrade stiffness 21 Saouma Testimony § C.2.4.2 (INT001-R).

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) or structural capacity, and in some cases increases structural capacityuntil the concrete reaches a certain level of ASR-related expansion.22 In other words, the chemical prestressing effect causes the structural performance of ASR-affected reinforced concrete to depart from what one might expect if merely using the material properties of ASR-affected unreinforced concrete in calculations prescribed in existing consensus codes and standards.23 Dr. Saouma acknowledges this aspect of the prestressing effect,24 which is well established in existing literature.

However, he claims that the LAR is invalid because it did not use the material properties of unreinforced concrete in the structural evaluations/FEMs.

2. Objective of the Examination To demonstrate that the use of unreinforced concrete properties in structural evaluations/FEMs, as Dr. Saouma recommends, is unnecessary and would be unrepresentative of reinforced concrete, such as that at Seabrook.
3. Proposed Line of Questioning Question 130 In your testimony, you acknowledge that, due to the prestressing effect, structural performance of ASR-affected reinforced concrete departs from the performance one might expect if only considering the material properties of that concrete. However, you claim that this information should not be accounted for in NextEras FEM. Do you agree that the use of unreinforced material properties in an FEM would result in a conclusion regarding structural performance substantially different from the real-world performance of a reinforced structure?

Question 131 o Are you aware that all of Seabrooks seismic Category I structures are reinforced?

Question 132 o Is your assertion that NextEra should have treated all reinforced structural members as if they were unreinforced?

22 MPR Testimony at A68 (NER001).

23 Id.

24 Saouma Testimony at 17.

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Question 133 o Which exhibits provide the technical basis for your conclusion that NextEras analyses must pretend that all structures are unreinforced? Question 134 You stated in your testimony that reduced material properties should be used in NextEras FEM. But Chapter 4 of your book (which you cited in the References section of your testimony) recommends the use of reduction factors for Youngs Modulus and Tensile strength of 1.0 (i.e. no reduction) for ASR-affected structures with internal reinforcement. Why does your testimony recommend that NextEra use a reduction factor for reinforced concrete structures when you recommend otherwise in your book?

J. Many of Dr. Saoumas Recommendations Are Unnecessary in the Context of the LAR

1. Brief Description of the Issue Dr. Saoumas testimony makes multiple recommendations for additional areas of monitoring or study that he believes should have been undertaken by NextErasuch as petrography, humidity monitoring, and calculation of residual reactivity and ultimate expansion potential. However, while these features may be useful in certain other contexts, such as a predictive model like Dr. Saoumas, they are unnecessary in the type of ASR monitoring program outlined in the LAR. For example, Dr. Saouma claims that CCI should be used in conjunction with continuous/additional petrographic studies and points to a flowchart from the Federal Highway Administration (FHWA) Guideline to support his claim.25 But the FHWA Guideline mentions petrography in the diagnosis phase. Whereas the LAR methodology uses the conservative assumption that all concrete expansion at Seabrook is caused entirely by ASR.26 Thus, nothing more is needed to diagnose the presence of ASR.

25 Saouma Testimony § C.3.2.1 (INT001-R).

26 SGH Testimony at A71 (NER004).

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2. Objective of the Examination To demonstrate that, in the context of the LAR, additional petrography, humidity monitoring, and calculation of residual reactivity and ultimate expansion potential are unnecessary.
3. Proposed Line of Questioning Question 135 In your testimony, you state that CCI should be used in conjunction with continuous/additional petrographic studies and you point to a flowchart in the FHWA Guideline. The flowchart shows petrography in the diagnosis phase. But the FHWA Guideline articulates no role for petrography after ASR has been diagnosed and assumed to be present, correct?

Question 136 Given that NextEra has chosen to use a presumption that all structures are affected by ASR, additional petrography would be redundant, would it not?

Question 137 In section C.2.1 of your Testimony (INT001-R), you suggest that NextEra should have conducted residual expansion testing to measure the remaining expansion potential in the concrete. But given that the LAR methodology is not designed to predict expansion behavior, but rather monitors expansion and establishes limits to ensure it remains within acceptable levels, such testing would serve no purpose, would it?

Question 138 In section C.3.2 of your Testimony (INT001-R), you suggest that NextEra should measure internal relative humidity in Seabrooks concrete to confirm whether it is humid enough for ASR expansion to occur, and to predict the level of expansion. But given that the LAR methodology monitors expansion, and can measure the level of expansion, relative humidity monitoring would be irrelevant, correct?

K. Most of Dr. Saoumas Rebuttal Testimony Seeks to Comment on Aspects of the LAR That Were Available Before His Initial Testimony Was Filed

1. Brief Description of the Issue Rebuttal testimony may not include arguments that reasonably should have been, but were not, raised in the partys case-in-chief.27 Nevertheless, Dr. Saoumas Rebuttal Testimony 27 See, e.g., Levy, LBP-09-22, 70 NRC at 655.

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) presents nearly a dozen new criticisms that C-10 clearly could have raised in its initial testimony.

More specifically, the Rebuttal Testimony purports to rebut various statements in NextEras and the NRC Staffs Testimony. But these statements by NextEra and NRC Staff do not proffer any new arguments or information that was unavailable at the time C-10s initial testimony was filed.

Rather, they repeatsometimes verbatiminformation in the LAR or the NRC Staffs Safety Evaluation (SE), which have been available to C-10 for many months or years. Indeed, C-10 submitted both of these documents with its initial testimony.

2. Objective of the Examination Question 139 To demonstrate that NextEras Motion in Limine to strike portions of the Rebuttal Testimony should be granted.
3. Proposed Line of Questioning Question 140 In your rebuttal testimony, you discuss many features of the LAR or conclusions by the NRC Staff that were presented in the LAR documentation or the Staffs SER. For each of the following items, the information you claim was first presented in NextEras or NRC Staffs testimony (such that you could not have challenged the information at the time you filed your initial testimony) was actually provided in documents to which C-10 has had access for years or months, right?

Topic Portion of NextEra or NRC Analogous Discussion in the LAR or (Section / Page) Testimony C-10 Purports to SE That C-10 Could Have But Did Rebut Not Challenge in Its Initial Testimony Alleged Lack of NRC Testimony reference to See, e.g., Original LAR, Encl. 1 at 3 Industry Standards the LARs use of code (NextEra is currently evaluating all (Section B.3) acceptance criteria. seismic Category I structures at Seabrook with indications of ASR to verify that structures continue to satisfy Use of ACI 318-71 NextEras Testimony the ACI 318-71 and ASME Code (Section B.4) regarding the LARs use of acceptance criteria, as appropriate, with ACI 318-71. the additional demand from ASR concrete expansion.)

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Interim MPR Testimony at A81-A86 See, e.g., Original LAR, Encl. 1 at 3-4 Assessment regarding the interim (describing the interim assessment);

(Section D.1.1) assessment of ASR and the MPR-4288 at 1-2 (describing the slow slow rate of ASR rate of ASR progression).

progression.

Probabilistic SGH Testimony at A59 See, e.g., Original LAR, Encl. 1 at 22 Features in LAR regarding the use of (explaining the crack index (Section D.1.2) probabilistic features to measurements are fit to probabilistic calculate ASR load factors. distributions for calculating ASR load factors).

Load Testing NRC Staff Testimony at A40 See, e.g., SE at 8 (noting the FSEL (Section D.3.2) asserting the LSTP was a involved Load testing full-scale full-scale load test which specimens with similar reinforcement to showed that for heavily Seabrook structures); id. at 20 (noting loaded members (i.e., that, for heavily loaded structures (i.e.,

members with flexural members with flexural cracking), the cracking, the flexural stiffness flexural stiffness increased as ASR increased as ASR expansion expansion increased).

increased.

Seismic Response NRC Staff Testimony at A29 See, e.g., SE at 19 (noting that and Flexural asserting [t]he natural [c]hanges in stiffness change the Stiffness frequency of a structure is natural frequency by a square root (Section D.4.2) proportional to the square root relationship).

of the stiffness to mass ratio . .

Validation of SGH Testimony at A83 See, e.g., Original LAR, Encl. 1 at 19 Strain with Field explaining that strains are (explaining that inspections are Measurements monitored and corroborated performed to measure structural (Section D.8.2) against field measurements. strains, and models are calibrated against field measurements).

Corroboration MPR Testimony at A95 and See, e.g., MPR-4273 app. C (INT019-Study and A176 describing the R)(NP), (INT021)(P) (describing the Empirical corroboration study and corroboration study and empirical Correlation empirical correlation. correlation).

(Section D.9.1 and Supplemental Rebuttal (INT030))

ASR Load Inputs SGH Testimony at A76 See, e.g., SEM Document (INT022) § (Section D.9.2) describing the ASR load 4.4.3 (describing the ASR load inputs).

inputs.

Design Basis SGH Testimony at A75 See, e.g., Original LAR, Encl. 1 at 5 Concrete explaining that the FEM uses (explaining that analyses of ASR-Properties concrete properties as affected concrete use the structural (Section D.9.3) specified in the UFSAR and properties and code equations from the original construction original design analyses when ASR 18

Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) documents so long as expansion levels are below the limits expansion remains below defined in Section 3.8.4.7 [i.e., SMP SMP limits. limits].

Seismic NRC Staff Testimony at A29 See, e.g., SE at 19 (noting uncertainties Uncertainty discussing the LARs method in material properties are factored into (Section D.9.4) of accounting for uncertainties the Seabrook original seismic design by in material properties in broadening the peaks of the calculated seismic analyses via the use of in-structure response by at least 10 10% peak broadening of the percent.)

response spectra.

L. Dr. Saouma Lacks Experience in Practical Structural Engineering

1. Brief Description of the Issue Dr. Saoumas professional background indicates significant academic work, but acknowledges that he is not a licensed professional engineer. In essence, Dr. Saouma is more of a theoretician than a practitioner of structural engineering. Nevertheless, he claims to be an expert in certain areas of structural engineering. But he has not established an appropriate professional pedigree for such claims. And in other areas of structural engineering, he admits that he is unqualified. But for those areas, he does not explain how he purported to address those areas in the Saouma Model.
2. Objective of the Examination To demonstrate that, while Dr. Saouma may be well-versed in structural engineering theory, he lacks the appropriate professional experience to be regarded as an expert in practical application of structural engineering to real-world structures.
3. Proposed Line of Questioning Question 141 In Section 6 of your report for the Emergency Petition (INT007), you indicate that you are not qualified to comment on the reinforcement anchorage tests. Thus, you likewise were not qualified to address reinforcement anchorage in the Saouma Model, were you?

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii)

Question 142 Unlike reinforcement anchorage, you do provide testimony on shear.

But while the description of your qualifications shows a diversity of experience, it does not identify participation in any design code or technical committees related to shear. Thus, you also are not qualified to provide commentary on shear, are you?

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Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii)

Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d) Executed in Accord with 10 C.F.R. § 2.304(d)

Steven Hamrick, Esq. Paul M. Bessette, Esq.

NextEra Energy Seabrook, LLC Morgan, Lewis & Bockius LLP 801 Pennsylvania Ave., NW Suite 220 1111 Pennsylvania Avenue, N.W.

Washington, D.C. 20004 Washington, D.C. 20004 Phone: (202) 349-3496 Phone: (202) 739-5796 Fax: (202) 347-7076 Fax: (202) 739-3001 E-mail: steven.hamrick@fpl.com E-mail: paul.bessette@morganlewis.com 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 Dated in Washington, DC this 19th day of September 2019 21

Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of: )

) Docket No. 50-443-LA-2 NEXTERA ENERGY SEABROOK, LLC )

) September 19, 2019 (Seabrook Station Unit 1) )

)

CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I certify that, on this date, the foregoing NEXTERAS PROPOSED QUESTIONS FOR THE BOARD TO PROPOUND TO DR. SAOUMA was served IN-CAMERA on the Electronic Information Exchange (the NRCs E-Filing System), in the above-captioned proceeding, to the following recipients:

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop: T-3F23 Washington, DC 20555-0001 Ronald M. Spritzer, Chair Administrative Judge ronald.spritzer@nrc.gov Nicholas G. Trikouros Administrative Judge nicholas.trikouros@nrc.gov Dr. Sekazi K. Mtingwa Administrative Judge sekazi.mtingwa@nrc.gov 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/ 106447597

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

NEXTERA ENERGY SEABROOK, LLC ) Docket No. 50-443-LA-2 (Seabrook Station, Unit 1) )

)

(License Amendment) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing MEMORANDUM AND ORDER (Providing Parties Proposed Questions for the Official Record) have been served upon the following persons by Electronic Information Exchange.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Office of Commission Appellate Adjudication Office of the Secretary of the Commission Mail Stop: O-16B33 Mail Stop: O-16B33 Washington, DC 20555-0001 Washington, DC 20555-0001 ocaamail.resource@nrc.gov Hearing Docket hearingdocket@nrc.gov U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Office of the General Counsel Washington, DC 20555-0001 Mail Stop: O-14A44 Washington, DC 20555-0001 Ronald M. Spritzer, Chair Administrative Judge Anita Ghosh, Esq.

ronald.spritzer@nrc.gov anita.ghosh@nrc.gov Jeremy Wachutka, Esq.

Nicholas G. Trikouros jeremy.wachutka@nrc.gov Administrative Judge David E. Roth, Esq.

nicholas.trikouros@nrc.gov david.roth@nrc.gov Dr. Sekazi K. Mtingwa Administrative Judge sekazi.mtingwa@nrc.gov OGC Mail Center: Members of this office have received a copy of this filing by EIE service.

Taylor Mayhall, Law Clerk Taylor.Mayhall@nrc.gov Molly Mattison, Law Clerk Molly.Mattison@nrc.gov Ian R. Curry, Law Clerk Ian.curry@nrc.gov Stephanie Fishman, Law Clerk stephanie.fishman@nrc.gov

NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1) - Docket No. 50-443-LA-2 MEMORANDUM AND ORDER (Providing Parties Proposed Questions for the Official Record)

NextEra Energy Seabrook, LLC C-10 Research & Education Foundation 801 Pennsylvania Avenue, N.W., #220 44 Merrimac Street Washington, DC 20004 Newburyport, Mass. 01950 Steven C. Hamrick, Esq. Natalie Hildt Treat steven.hamrick@fpl.com natalie@c-10.org NextEra Energy Seabrook, LLC Harmon, Curran, Spielberg, & Eisenberg, LLP Morgan, Lewis & Bockius LLP 1725 DeSales Street, NW, Suite 500 1111 Pennsylvania Avenue NW Washington, DC 20036 Washington, DC 20004 Diane Curran, Esq.

Paul M. Bessette, Esq. dcurran@harmoncurran.com paul.bessette@morganlewis.com Scott David Clausen, Esq.

Scott.Clausen@morganlewis.com Ryan K. Lighty, Esq.

ryan.lighty@morganlewis.com Grant Eskelsen, Esq.

grant.eskelsen@morganlewis.com Digitally signed by Clara I.

Clara I. Sola Sola Date: 2020.09.17 12:15:54

-04'00' Office of the Secretary of the Commission Dated at Rockville, Maryland, this 17th day of September 2020.

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