ML20262G967
| ML20262G967 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| 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) | |
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 NEXTERA ENERGY SEABROOK, LLC (Seabrook Station, Unit 1)
Docket No. 50-443-LA-2 ASLBP No. 17-953-LA-BD01 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).
2 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 Ronald M. Spritzer, Chairman ADMINISTRATIVE JUDGE Rockville, Maryland September 17, 2020
/RA/
NRC Staff Question 1 Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
Q) You forwarded this message on 09/24/2019 12:56 PM.
I f-) Rep~
Reply All Forward Tue 09/24/2019 10:59 AM Expires 09/22/2026 Is an in-depth understanding of the specifics of ASR necessary to determine whether NextEra's Method provides reasonable assurance?
NRC Staff Question 2 RE: Proposed Question I ~ Repill Reply A_"~-- Forward 7 Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Tue 09/24/2019 11 :28 AM 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?
NRC Staff Question 3 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:52 PM.
Expires 09/22/2026 Dr. Sauoma compares this situation to Gentilly-2. Is this an appropriate comparison?
I ~ Rep_lY_~<~
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Forw~ * ** I Tue 09/24/2019 11 :56 AM
NRC Staff Question 4 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:52 PM.
Is CCI a reliable measurement of ASR expansion?
Expires 09/22/2026
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Forwa~
Tue 09/24/2019 12:08 PM
NRC Staff Question 5 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:53 PM.
I ~ Repill Reply A_"_~- Forward Tue 09/24/2019 3:07 PM Expires 09/22/2026 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)?
NRC Staff Question 6 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:53 PM.
Expires 09/22/2026 Will the 6-month inspection interval catch all possible expansions before they hit the limits?
I ~ Repill Reply ~
Forward Tue 09/24/2019 3:22 PM
NRC Staff Question 7 RE: Proposed Question Wachutka,Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:53 PM.
~ Repill Reply~ Forw~ 9 Tue 09/24/ 2019 4:43 PM Expires 09/22/2026 Are the monitoring, acceptance criteria, and inspection intervals of the ASR expansion monitoring program and the structure deformation monitoring program the same or different?
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:
How many concrete specimens were tested within 60 days of casting?
How many concrete specimens were tested after two years? Or if you dont know, what was the percentage of the original samples?
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 Question 8 Question 9 Question 10 C-10 Questions 8-14
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:
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 experimental measurement of the elastic modulus in a laboratory?
In casting the Seabrook concrete, there is a great variability in the compressive 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?
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 Question 11 Question 12 Question 13 Question 14
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 Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
Q) You forwarded this message on 08/31/2020 3:58 PM.
I f-) Rep~
Reply A_n_~- Forward
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Wed 09/25/2019 10:04 AM Expires 09/23/2026 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?
NRC Staff Question 16 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:58 PM.
Action Items Expires 09/23/2026 I ~ Rep~
Reply+/-
Forwa~
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+ 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?
NRC Staff Question 17 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 3:59 PM.
Action Items I ~ Reill Reply All Forwa~ D Wed 09/25/2019 10: 11 AM Expires 09/23/2026
+ Get more add-ins What evidence does Dr. Saouma have that the surface of the Seabrook walls is less than 80% relative humidity?
NRC Staff Question 18 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:00 PM.
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Forward Wed 09/25/2019 10:25 AM Expires 09/23/2026 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 To O Mattison, Molly Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/ 31/2020 4:01 PM.
Action Items I ~ Reill Reply A_II_~- Forward 7 Wed 09/25/2019 10:49 AM Expires 09/23/2026
+ 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 from CCI?
NRC Staff Question 20 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:01 PM.
I ~ Rep_lY_~<~
_ Reply All Forwa~ D Wed 09/25/2019 12:23 PM Expires 09/23/2026 Dr. Saouma advocates for "Direct tension tests" - does he present this in his original testimony or is this a new argument?
NRC Staff Question 21 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:01 PM.
I f-:) Reply
<~ Reply ;-r Forwa~ D Wed 09/ 25/20191:41 PM Expires 09/ 23/ 2026 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)?
NRC Staff Question 22 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian; 0 Scro, Jennifer Retention Policy 7 Years (7 years)
(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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Forwa~ D Wed 09/25/2019 2:21 PM Expires 09/23/2026 r
NRC Staff Question 23 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:04 PM.
I ~ Rep_lY_~<~
_ Reply All Forwa~ E Wed 09/25/2019 2:38 PM Expires 09/23/2026 Dr. Saouma discusses additional stresses from ASR. Aren't these accounted for by the structure deformation monitoring program?
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:
How many concrete samples (cylinders) did NextEra take during construction?
What is the mean value of the compressive strength from these samples?
What is the corresponding standard deviation?
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 24 Question 25 Question 26 C-10 Questions 24-28
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.
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 Question 27 Question 28
NRC Staff Question 29 Wachutka,Jeremy To O Mattison, Molly Cc O Curry, Ian;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:04 PM.
Action Items Expires 09/24/2026 I ) KeP_IY_..__"_~) Kep1y An I ~ t orwara J L.:_" :J Thu 09/26/2019 12: 13 PM
+ 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 Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:05 PM.
~ Repill Reply~ Forw~ 7 Thu 09/26/2019 2: 10 PM Expires 09/24/2026 Isn't the purpose of conducting the LSTP so that the finite element analysis does not have to use degraded material properties?
NRC Staff Question 31 RE: Proposed Question Wachutka, Jeremy To O Mattison, Molly Cc O Curry, Ian;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:05 PM.
Action Items Expires 09/24/2026 2
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+ 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?
NRC Staff Question 32 RE: Proposed Question
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Scro, Jennifer
'Ye To O Mattison, Molly; 0 Mayhall, Taylor Cc O Curry, Ian;
- Wachutka, Jeremy Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:05 PM.
Expires 09/24/2026
~ Repill Reply All Forward 3 Thu 09/26/2019 2:45 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 Wachutka, Jeremy To O Mattison, Molly Cc O Mayhall, Taylor;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:06 PM.
I ~ Rep~
Reply +/-
Forwa~ D Thu 09/26/2019 3:09 PM Expires 09/24/2026 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 To O Mattison, Molly Cc O Mayhall, Taylor;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:06 PM.
Expires 09/24/2026 I ~ Rep_lY_~<~
Reply+/- Forw~ 3 Thu 09/26/2019 3:13 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 Wachutka, Jeremy To O Mattison, Molly Cc O Mayhall, Taylor;
- Scro, Jennifer Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/31/2020 4:07 PM.
I f-) Repill Reply A_II~-- Forward Fri 09/27/2019 9:51 AM Expires 09/25/2026 Dr. Saouma, look at the line on the graph of LSTP data of micro-cracked test specimens, isn't it linear?
NRC Staff Question 36 From: Wachutka, Jeremy Sent: Friday, September 27, 2019 9 :51 AM To: Mattison, Molly <Molly.Mattison@nrc.gov>
Cc: Mayhall, Taylor <Taylor.Mayhall@nrc.gov>; Scro, Jennifer <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?
NRC Staff Question 37 RE: Proposed Question
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Scro, Jennifer
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To O Mattison, Molly; 0 Mayhall, Taylor Cc
- Wachutka, Jeremy Retention Policy 7 Years (7 years)
(D You forwarded this message on 08/ 31/ 2020 4:08 PM.
Action Items I ~ Repill Reply ~
Forwa~ E Fri 09/27/2019 10:34 AN Expires 09/ 25/2026
+ 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?
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.
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 38 1.
Please explain how the NRC initially licenses nuclear power plants, what general NRC Staff Questions 38-72
2.
Please explain the concept of reasonable assurance of adequate protection of public health and safety.
3.
Which general design criteria are relevant to this proceeding?
4.
What licensing basis documents are at issue in this proceeding?
5.
What are consensus codes and standards? How are they developed? How are they used in NRC licensing?
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?
licensing? How is the reasonable assurance standard relevant to these changes?
8.
Is a licensee required to change its licensing basis documents just because they are old?
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?
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 Question 39 Question 40 Question 41 Question 42 Question 43 Question 44 7.
What methods are available to change a plants licensing basis after initial Question 45 Question 46 Question 47
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.
1.
Please explain how the monitoring for ASR expansion is based on the LSTP.
2.
Please explain how the acceptance criteria for ASR expansion are based on the LSTP.
LSTP.
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?
5.
Are any data from the LSTP used as direct inputs for the structure deformation monitoring program?
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.
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 Question 48 Question 49 Question 50 3.
Please explain how the inspection intervals for ASR expansion are based on the Question 51 Question 52 Question 53 Question 54
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?
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.
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?
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?
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 Question 55 2.
Even if it was not required, did the Staff obtain independent reviews of NextEras Question 56 Question 57 Question 58 3.
Dr. Saouma argues that a delamination crack at Seabrook similar to the cracks
light most favorable to C-10, challenge NextEras Method. These proposed questions explore whether such challenges affect the Staffs reasonable assurance determination.
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?
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?
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?
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?
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 59 Question 60 Question 61 Question 62 Question 63 5.
Dr. Saouma argues that there are relative humidity and temperature gradients in
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?
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?
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?
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?
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.
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 64 Question 65 Question 66 8.
Dr. Saouma argues that the edge-effect crack that developed during the LSTP Question 67 Question 68 Question 69
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.
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?
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 Question 70 Question 71 Question 72
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
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:
NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1)
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Docket No. 50-443-LA-2 September 19, 2019 NEXTERAS PROPOSED QUESTIONS FOR THE BOARD TO PROPOUND TO DR. SAOUMA Steven Hamrick, Esq.
NextEra Energy Seabrook, LLC 801 Pennsylvania Ave., NW Suite 220 Washington, D.C. 20004 Phone: (202) 349-3496 Fax: (202) 347-7076 E-mail: steven.hamrick@fpl.com Paul M. Bessette, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5796 Fax: (202) 739-3001 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 NextEra Questions73-142
Confidential Pending Release by the Licensing Board Per 10 C.F.R. § 2.1207(a)(3)(iii)
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:
NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1)
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Docket No. 50-443-LA-2 September 19, 2019 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.
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 2 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.
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?
[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.
- 3.
Proposed Line of Questioning Question 73 Question 74
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 3
[If Dr. Saouma discusses the use of unreduced elastic modulus or other material properties from the original design calculations rather than the LSTP]:
o Those values are specified in Seabrooks existing license and do not come from the LSTP, correct?
o Are you aware that the LSTP is not the sole basis for using the strength and stiffness values in Seabrooks existing license?
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?
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.
Question 75 Question 76 Question 77 Question 78
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 4 3.
Proposed Line of Questioning
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?
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).
Question 79 Question 80
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 5 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.
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?
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.
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?
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?
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).
- 3.
Proposed Line of Questioning Question 81 Question 82 Question 83 Question 84 Question 85
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 6
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?
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?
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?
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?
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?
You performed no independent structural calculations or finite element modeling for Seabrook structures to support your Testimony, is that correct?
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?
o
[If yes to either of these]: In which exhibits are those results presented?
Question 86 Question 87 Question 88 Question 89 Question 90 Question 91 Question 92 Question 93
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 7 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
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.
Question 94
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 8 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?
o Are you aware that NRC guidance is entitled to special weight?
o Are you aware that ASCE/SEI 4-16 also explicitly approves the use of this methodology?
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?
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?
o Which exhibits supposedly support this challenge?
You criticized Revision 0 of the structural evaluation for the Containment 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?
o Are you aware that SRP § 3.7.2 says the same?
o Are you aware that Seabrooks UFSAR explains that the site has a shear wave velocity between 8,000-10,000 ft/s?
o Do you still maintain that NextEras seismic analyses must include SSI analyses?
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?
o But your written Testimony articulates no technical basis for such a challenge, does it?
Question 95 Question 96 Question 97 Question 98 Question 99 Question 100 Question 101 Question 102 Question 103 Question 104 Question 105
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 9 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
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 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?
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).
Question 106 Question 107 Question 108
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 10 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 Seabrook since the time of its construction?
o Thus, a probabilistic or constitutive model could not be used at Seabrook, right?
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?
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?
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?
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?
No nuclear power plants within the U.S. or around the world employ the Saouma method in managing ASR, correct?
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?
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?
MPRs testimony cites a 2017 technical paper from Esposito and Hendricks (NER037) that concludes constitutive (also known as chemo-Question 109 Question 110 Question 111 Question 112 Question 113 Question 114 Question 115 Question 116 Question 117 Question 118
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 11 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?
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
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 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).
Question 119 Question 120 Question 121
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 12
In your research for the NRC, you used additives to accelerate expansion, correct?
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
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?
Are you arguing that Seabrooks license should authorize nonlinear structural behavior?
o
[If yes]: But your written Testimony provides no technical basis to show that such an approach is conservative, does it?
o
[If no]: Then there is no need for NextEra to analyze 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).
Question 122 Question 123 Question 124 Question 125 Question 126
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 13 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
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?
o
[If yes]: What exhibits provide the technical basis for your disagreement?
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).
Question 127 Question 128 Question 129
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 14 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
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?
o Are you aware that all of Seabrooks seismic Category I structures are reinforced?
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.
Question 130 Question 131 Question 132
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Which exhibits provide the technical basis for your conclusion that NextEras analyses must pretend that all structures are unreinforced?
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).
Question 133 Question 134
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 16 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
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?
Given that NextEra has chosen to use a presumption that all structures are affected by ASR, additional petrography would be redundant, would it not?
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?
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.
Question 135 Question 136 Question 137 Question 138
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 17 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 To demonstrate that NextEras Motion in Limine to strike portions of the Rebuttal Testimony should be granted.
3.
Proposed Line of Questioning
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 (Section / Page)
Portion of NextEra or NRC Testimony C-10 Purports to Rebut Analogous Discussion in the LAR or SE That C-10 Could Have But Did Not Challenge in Its Initial Testimony Alleged Lack of Industry Standards (Section B.3)
Use of ACI 318-71 (Section B.4)
NRC Testimony reference to the LARs use of code acceptance criteria.
NextEras Testimony regarding the LARs use of ACI 318-71.
See, e.g., Original LAR, Encl. 1 at 3 (NextEra is currently evaluating all seismic Category I structures at Seabrook with indications of ASR to verify that structures continue to satisfy the ACI 318-71 and ASME Code acceptance criteria, as appropriate, with the additional demand from ASR concrete expansion.)
Question 139 Question 140
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 18 Interim Assessment (Section D.1.1)
MPR Testimony at A81-A86 regarding the interim assessment of ASR and the slow rate of ASR progression.
See, e.g., Original LAR, Encl. 1 at 3-4 (describing the interim assessment);
MPR-4288 at 1-2 (describing the slow rate of ASR progression).
Probabilistic Features in LAR (Section D.1.2)
SGH Testimony at A59 regarding the use of probabilistic features to calculate ASR load factors.
See, e.g., Original LAR, Encl. 1 at 22 (explaining the crack index measurements are fit to probabilistic distributions for calculating ASR load factors).
Load Testing (Section D.3.2)
NRC Staff Testimony at A40 asserting the LSTP was a full-scale load test which showed that for heavily loaded members (i.e.,
members with flexural cracking, the flexural stiffness increased as ASR expansion increased.
See, e.g., SE at 8 (noting the FSEL involved Load testing full-scale specimens with similar reinforcement to Seabrook structures); id. at 20 (noting that, for heavily loaded structures (i.e.,
members with flexural cracking), the flexural stiffness increased as ASR expansion increased).
Seismic Response and Flexural Stiffness (Section D.4.2)
NRC Staff Testimony at A29 asserting [t]he natural frequency of a structure is proportional to the square root of the stiffness to mass ratio..
See, e.g., SE at 19 (noting that
[c]hanges in stiffness change the natural frequency by a square root relationship).
Validation of Strain with Field Measurements (Section D.8.2)
SGH Testimony at A83 explaining that strains are monitored and corroborated against field measurements.
See, e.g., Original LAR, Encl. 1 at 19 (explaining that inspections are performed to measure structural strains, and models are calibrated against field measurements).
Corroboration Study and Empirical Correlation (Section D.9.1 and Supplemental Rebuttal (INT030))
MPR Testimony at A95 and A176 describing the corroboration study and empirical correlation.
See, e.g., MPR-4273 app. C (INT019-R)(NP), (INT021)(P) (describing the corroboration study and empirical correlation).
ASR Load Inputs (Section D.9.2)
SGH Testimony at A76 describing the ASR load inputs.
See, e.g., SEM Document (INT022) § 4.4.3 (describing the ASR load inputs).
Design Basis Concrete Properties (Section D.9.3)
SGH Testimony at A75 explaining that the FEM uses concrete properties as specified in the UFSAR and original construction See, e.g., Original LAR, Encl. 1 at 5 (explaining that analyses of ASR-affected concrete use the structural properties and code equations from the original design analyses when ASR
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 19 documents so long as expansion remains below SMP limits.
expansion levels are below the limits defined in Section 3.8.4.7 [i.e., SMP limits].
Seismic Uncertainty (Section D.9.4)
NRC Staff Testimony at A29 discussing the LARs method of accounting for uncertainties in material properties in seismic analyses via the use of 10% peak broadening of the response spectra.
See, e.g., SE at 19 (noting uncertainties in material properties are factored into the Seabrook original seismic design by broadening the peaks of the calculated in-structure response by at least 10 percent.)
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
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?
Question 141
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 20
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?
Question 142
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii) 21 Executed in Accord with 10 C.F.R. § 2.304(d)
Respectfully submitted, Executed in Accord with 10 C.F.R. § 2.304(d)
Steven Hamrick, Esq.
NextEra Energy Seabrook, LLC 801 Pennsylvania Ave., NW Suite 220 Washington, D.C. 20004 Phone: (202) 349-3496 Fax: (202) 347-7076 E-mail: steven.hamrick@fpl.com Paul M. Bessette, Esq.
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W.
Washington, D.C. 20004 Phone: (202) 739-5796 Fax: (202) 739-3001 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
Confidential Pending Release by the Licensing Board Per 10 C.F.R. 2.1207(a)(3)(iii)
DB1/ 106447597 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
NEXTERA ENERGY SEABROOK, LLC (Seabrook Station Unit 1)
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Docket No. 50-443-LA-2 September 19, 2019 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
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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NEXTERA ENERGY SEABROOK, LLC
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Docket No. 50-443-LA-2 (Seabrook Station, Unit 1)
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(License Amendment)
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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 Office of Commission Appellate Adjudication Mail Stop: O-16B33 Washington, DC 20555-0001 ocaamail.resource@nrc.gov 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 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 U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop: O-16B33 Washington, DC 20555-0001 Hearing Docket hearingdocket@nrc.gov U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: O-14A44 Washington, DC 20555-0001 Anita Ghosh, Esq.
anita.ghosh@nrc.gov Jeremy Wachutka, Esq.
jeremy.wachutka@nrc.gov David E. Roth, Esq.
david.roth@nrc.gov OGC Mail Center: Members of this office have received a copy of this filing by EIE service.
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) 2 NextEra Energy Seabrook, LLC 801 Pennsylvania Avenue, N.W., #220 Washington, DC 20004 Steven C. Hamrick, Esq.
steven.hamrick@fpl.com NextEra Energy Seabrook, LLC Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue NW Washington, DC 20004 Paul M. Bessette, Esq.
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 C-10 Research & Education Foundation 44 Merrimac Street Newburyport, Mass. 01950 Natalie Hildt Treat natalie@c-10.org Harmon, Curran, Spielberg, & Eisenberg, LLP 1725 DeSales Street, NW, Suite 500 Washington, DC 20036 Diane Curran, Esq.
dcurran@harmoncurran.com Office of the Secretary of the Commission Dated at Rockville, Maryland, this 17th day of September 2020.
Clara I. Sola Digitally signed by Clara I.
Sola Date: 2020.09.17 12:15:54
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