ML17227A538

OEDO-17-00529- Letter from Research & Education Foundation 10 CFR 2.204 Demand for Information (DFI)

ML17227A538
Person / Time
Site:	Seabrook
Issue date:	05/12/2017
From:	Hildt-Treat N, Lang-Skibbee P C-10 Research & Education Foundation
To:	Mccree V NRC/EDO
Shared Package
ML17227A527	List: ML17227A538
References
2.206, LAR 16-03, OEDO-17-00529
Download: ML17227A538 (3)

Text

May 12, 2017 Via electronic submission: OPA.resource@NRC.gov

Subject:

10 CFR 2.204 Demand For Information (DFI)

Mr. Victor McCree Execu ve Director for Opera ons United States Nuclear Regulatory Commission Washington, D.C. 205550001

Dear Mr. McCree:

On behalf of the C10 Research and Educa on Founda on (hereina er C10), 44 Merrimac Street, Newburyport, Massachuses, 01950, I submit this pe on pursuant to Ch. 2.206, Title 10, of the Code of Federal Regula ons (herea er 10 CFR).

Demand for Information requested C10 pe ons the NRC to issue demands for informa on pursuant to 10 CFR 2.204, and to then issue an order under 10 CFR 2.202 to licensee NextEra, owner of Seabrook Sta on who is the en ty seeking approval of its LAR 1603 License Amendment Request (Seabrook Sta on License Amendment Request 1603; Revise Current Licensing Basis to Adopt a Methodology for the Analysis of Seismic Category 1 Structures with Concrete Aected by AlkaliSilica Reac on, August 1, 2016, 10 CFR 50.90, Docket No. 5443, SBKL16071.). This DFI applies to the August 1, 2016, LAR 1603 and any and all amendments, aachments and revisions.

Justification for Enforcement Action Requested In its response to C10s "led conten ons to this LAR, NextEra (Docket No. 50443LA2, May 5, 2017, before the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission), Next Era makes a number of statements that purport to demonstrate that the LAR 1603 should be approved by the NRC and that the conten ons submied by C10 should be rejected. A signi"cant number of their statements in support of those posi ons refer to the technical data submied in LAR 1603.

However, because virtually all of the sta s cs in the technical data are redacted, it is impossible for C10 to assess the validity of NextEras statements.

Therefore, C10 herewith requests the NRC to approve via this Demand For Informa on that the LAR 1603 documents be released to C10 with no por ons redacted.

C10 Founda on 44 Merrimac Street, Newburyport Mass. 01950 www.c10.org (978) 4656646

C10 Founda on 10 CFR 2.204 DFI, 5/12/2017 page 2 C10 understands that at least some of this informa on it is seeking is proprietary, and C10 is willing to sign a con"den ality agreement. C10 maintains regular, secure oce space in which these documents would be keep in a locked "ling closet and would be available only to C10s sta and members of the Board of Directors, to be accessed and used only on the premises.

Examples of sections of NextEras response to C10s contentions that cannot be adequately assessed due to the extensive redaction in LAR 1603

1. para. 1, page 4: ASRinduced expansion in reinforced concrete has an eect, similar in some ways to prestressing, that mi gates the loss of structural capacity that would be assumed based on the change in material proper es, up to a point. Without the redacted data to support this asser on, it is not possible for C10 to assess its validity.

2. para. 2, page 7: The overall conclusion from analyses of structural limit states is that limit state capacity is not degraded when small amounts of ASR expansion are present in structures. Presently, the ASR expansion levels in Seabrook structures are below the levels at which limit state capaci es are reduced. (LAR evalua on Sec on 3.2.1.)

Without having access to what small amounts numbers are and the levels at which limit state capaci es are reduced, C10 cannot assess the validity of the claims of LAR 1603.

3. para. 2, page 16: The LAR explicitly calls for core sample tes ng as an integral part of its ASR monitoring methodology, and the results of the "rst campaign of tests are included in a technical document submied as part of the LAR. The sta s cal results of the tes ng are redacted; therefore, again, C10 is prevented from being able to actually review and assess the results.

4. para. 2, page 17: As explained throughout the technical documents underlying the LAR, the mechanical eect of ASR does not necessarily result in an adverse impact to structural capacity, at least up to the point of expansion that was observed in the program. Because the sta s cal data is redacted, C10 cannot review or asses it; therefore, C10 cannot know up to what point expansion due to ASR was tested. Since the point of LAR 1603 is to establish a valid tes ng methodology for the eect of ASR on the structures at Seabrook Sta on, having these sta s cs is vital for adequate review of the LAR.

5. para. 2, page 22: MPR4153 even provides the results of those tests. These results, which state the outcome of tests on the material proper es of concrete tested in the University of Texas FSEL by the company MPR are redacted.

(MPR4153 Sec on 4.1; Id. At Appx D (Throughthickness expansion ToDate for the First Campaign of Extensometers).

6. para. 1, page 36: The "rst campaign to examine outofplane expansion has been completed and involved tes ng of cores. The results of those tests are available in the LAR. The results are redacted.

7. para 1, page 43: This tes ng examines the current elas c modulus of the concrete, which in turn requires compressive strength tes ng. The "rst campaign to examine outofplane expansion involved tes ng of cores. The results of those tests are available in the LAR. Pe oner neither references nor challenges the tests conducted to date. The Pe oner (C10) cannot reference nor challenge the test results, because they are redacted. This is a classical circular argument advanced by Seabrook Sta ons owner NextEra.

C10 Founda on 44 Merrimac Street, Newburyport Mass. 01950 www.c10.org (978) 4656646

C10 Founda on 10 CFR 2.204 DFI, 5/12/2017 page 3 Petition Logistics C10 is willing to sign and commit fully to a con"den ality agreement. C10 requests via this DFI that such an agreement be prepared and communicated to C10 and that following its execu on LAR 1603 with all its amendments, aachments and revisions be released to C10 for review and assessment.

Sincerely, Patricia Lang Skibbee President of the Board of Directors C10 Research & Educa on Founda on 44 Merrimac Street Newburyport, MA 01950 Ph: 978 465 6646 Email: Patricia.skibbee@verizon.net Natalie Hildt Treat Execu ve Director C10 Research & Educa on Founda on 44 Merrimac Street, Newburyport, MA 01950 Ph: (978) 4656646 Email: natalie@c10.org C10 Founda on 44 Merrimac Street, Newburyport Mass. 01950 www.c10.org (978) 4656646