ML15337A324

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Official Exhibit - NYS000576-00-BD01 - Pre-Filed Supplemental Testimony of Richard T. Lahey Re Contentions NYS-25, NYS-26B/RK-TC-1B & NYS-38/RK-TC-5
ML15337A324
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 09/23/2015
From: Lahey R
Rensselaer Polytechnic Institute
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 28315, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR
Download: ML15337A324 (9)


Text

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 1

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3


x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

September 23, 2015 9


x 10 PRE-FILED SUPPLEMENTAL TESTIMONY OF 11 DR. RICHARD T. LAHEY, JR.

12 REGARDING CONTENTIONS NYS-25, 13 NYS-26B/RK-TC-1B, AND NYS-38/RK-TC-5 14 On behalf of the State of New York (NYS or the State),

15 the Office of the Attorney General hereby submits the following 16 testimony by RICHARD T. LAHEY, JR., Ph.D. regarding Contention 17 NYS-25.

18 Q.

Please state your full name.

19 A.

Richard T. Lahey, Jr.

20 Q.

Dr. Lahey, you have previously summarized your 21 educational and professional qualifications and submitted 22 testimony in this proceeding, correct?

23 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:

Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:

Identified:

Admitted:

Withdrawn:

Rejected:

Stricken:

Other:

NYS000576-00-BD01 11/5/2015 11/5/2015 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 2

A.

Yes. I previously have submitted testimony and 1

reports in this proceeding. My education and professional 2

qualifications and experience are described in my Curricula 3

Vitae and that testimony.

4 Q.

I show you what has been marked as Exhibit NYS000574 5

and NYS000575. Do you recognize those documents?

6 A.

Yes. These are copies of documents that Entergy 7

disclosed to the parties in this proceeding. The first document 8

is a report published by the USNRC and is entitled NUREG/CR-9 7184, ANL-12/56, "Crack Growth Rate and Fracture Toughness Tests 10 on Irradiated Cast Stainless Steels," by Y. Chen, et al. The 11 second document is a report that is also published by the USNRC 12 entitled NUREG/CR-7185, ANL-14/10, entitled "Effects of Thermal 13 Aging and Neutron Irradiation on Crack Growth Rate and Fracture 14 Toughness of Cast Stainless Steels and Austenitic Stainless 15 Steel Welds, by O. K. Chopra, et al.

16 Q.

In those titles, do you know what ANL signifies?

17 A.

Yes. The abbreviation ANL stands for the Argonne 18 National Laboratories, and the designation ANL-14/10 and ANL-19 12/56 signifies, in my experience, that the documents were 20 developed by Argonne National Laboratories for the USNRC.

21 22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 3

Q.

Does NUREG/CR-7184, ANL-12/56 (NYS000574) indicate 1

what the USNRCs role was, if any, in developing the document?

2 A.

Yes. Among other things, the documents bibliographic 3

data sheet (frame 177) reports that the USNRCs Division of 4

Engineering was the sponsoring organization.

5 Q.

Does NUREG/CR-7185, ANL-14/10 (NYS000575) contain 6

similar information?

7 A.

Yes, the cover page states that the document was 8

prepared for the USNRCs Division of Engineering, Office of 9

Nuclear Regulatory Research, and that A.S. Rao was the USNRC 10 Technical Monitor and Project Manager.

11 Q.

Have you now had an opportunity to review NYS000574 12 and NYS000575?

13 A.

Yes.

14 Q.

Have these documents caused you to change the 15 testimony and opinions that you have previously submitted in 16 this proceeding in connection with Contention NYS-25 and 17 Contention NYS-26B/RK-TC-1B or Contention NYS-38/RK-TC-5?

18 A.

No. In fact, the documents support the concerns, 19 opinions, and testimony that I have presented in this 20 proceeding.

21 Q.

Please explain.

22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 4

A.

The document, "Effects of Thermal Aging and Neutron 1

Irradiation on Crack Growth Rate and Fracture Toughness of Cast 2

Stainless Steels and Austenitic Stainless Steel Welds, 3

[NUREG/CR-7185, ANL-14/10, NYS000575], contains analysis and 4

conclusions that are relevant to and supportive of the opinions 5

and testimony that I have presented. To briefly summarize, 6

among other things, the document reports that:

7 Both CASS and austenitic stainless steel welds (but not the 8

heat affected zones (HAZ)) have a duplex structure (i.e.,

9 they contain both ferritic & austenite phases), and both 10 may experience thermal embrittlement (TE). This 11 degradation mechanism applies to CASS structures, 12 components and fittings and the stainless steel welds for 13 reactor vessel internals (RVIs);

14 While thermal embrittlement (TE) may increase the hardness 15 and tensile strength of a material, it also decreases 16 ductility, fracture toughness (i.e., the resistance to 17 crack propagation), and, it decreases the impact strength 18 (i.e., due to significant shock loads) of CASS, its welds, 19 and the welds of austenitic stainless steel. In addition, 20 irradiation also causes embrittlement (IE) in these 21 components for fluences > 2.0 x 1020 n/cm2 (i.e., material 22 damage > 10 dpa), and irradiation makes CASS, its welds, 23 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 5

and the welds of austenitic stainless steel also more 1

susceptible to irradiation-assisted stress corrosion 2

cracking (IASCC);

3 Significantly, IASCC increases the crack growth rate of 4

cracks induced by stress corrosion cracking. However, the 5

document also reports that there is virtually no data above 6

10 dpa -- even though during the period of extended 7

operation some of the reactor vessel internals may 8

experience several hundred dpa; 9

Transgranular brittle cleavage was observed for embrittled 10 materials (and in particular for the CASS tests reported in 11 the other USNRC document, NUREG/CR-7184 [NYS000574];

12 Possible synergy was noted between thermal embrittlement 13 and irradiation embrittlement, although the report stresses 14 the need for more information to develop reliable J-R 15 failure curves. The other USNRC document, NUREG/CR-7184, 16 also notes this same type of synergism.

17 Q.

Do you believe that this report, NUREG/CR-7185, is 18 significant?

19 A.

Yes, it is. As mentioned, this USNRC report supports 20 my opinions and testimony presented in this proceeding. In 21 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 6

addition, this report, which was prepared by Argonne National 1

Laboratories and the USNRC Staff, contains information that 2

I have not seen in previous USNRC reports. In particular, the 3

susceptibility of stainless steel welds to TE and, for the first 4

time ever, the detrimental effect of this embrittlement on 5

impact strength (i.e., for withstanding significant shock loads) 6 and the potential for brittle fracture due to various impulsive 7

loads.

8 Q.

Can you summarize the other USNRC document, NUREG/CR-9 7184, Exhibit NYS000574?

10 A.

Yes. That document, "Crack Growth Rate and Fracture 11 Toughness Tests on Irradiated Cast Stainless Steels,"

12

[NYS000574], also contains analysis and conclusions that are 13 relevant to and supportive of the opinions and testimony that I 14 have presented. For example, as noted previously, the document 15 reports that for CASS materials, synergies exist between thermal 16 embrittlement (TE) and irradiation embrittlement (IE). Also, it 17 is significant that transgranular brittle cleavage was observed 18 for embrittled materials, as was ductile tearing (i.e.,

19 dimpling).

20 Q.

In your opinion, what is the significance of that 21 information?

22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 7

A.

The observation of both of these failure mechanisms 1

and the synergies between the various aging-related degradation 2

mechanisms is supportive of my previous opinions and testimony.

3 That is, realistic safety and fatigue analyses need to take into 4

account the age-related degradation of materials. For example, 5

the finding in NUREG/CR-7185 that CASS and austenitic stainless 6

steel welds are subject to thermal embrittlement (TE), and that 7

this reduces their impact strength, means that the welds 8

associated with the pressurizer spray nozzle, for example, are 9

particularly vulnerable to significant seismic and 10 thermal/pressure shock loads. Moreover, it appears that 11 vulnerability to early failure of the various RVI welds, which 12 are subject to TE, IE, IASCC, and shock loads, have not been 13 adequately analyzed.

14 Q.

I show you what previously was marked as NYS00488A-B 15 and ask you to compare it to NYS000575.

16 A.

NYS00488A-B is entitled Crack Growth Rate and 17 Fracture Toughness Tests on Irradiated Cast Stainless Steels, 18 NUREG/CR-7184, ANL-12/56 and it appears that this document is a 19 revised manuscript and it bears a manuscript date of December 20 2014. I referred to that earlier manuscript in my previous 21 testimony [e.g., NYS000482], and the State previously presented 22 the document as Exhibit 488. It appears that Argonne National 23 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 8

Laboratory and the USNRC have subsequently made some edits and 1

republished the document, which is now NYS000574.

2 Q.

It that the end of your supplementary testimony today?

3 A.

Yes it is. However, I reserve the right to supplement 4

my testimony if new information is disclosed or introduced.

5 6

NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 9

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3


x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

September 23, 2015 9


x 10 DECLARATION OF RICHARD T. LAHEY, JR.

11 I, Richard T. Lahey, Jr., do hereby declare under penalty 12 of perjury that my statements in the foregoing testimony and my 13 statement of professional qualifications are true and correct to 14 the best of my knowledge and belief.

15 Executed in Accord with 10 C.F.R. § 2.304(d) 16 17 18 Dr. Richard T. Lahey, Jr.

19 The Edward E. Hood Professor Emeritus of Engineering 20 Rensselaer Polytechnic Institute, Troy, NY 12180 21 (518) 495-3884, laheyr@rpi.edu 22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 1

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3


x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

September 23, 2015 9


x 10 PRE-FILED SUPPLEMENTAL TESTIMONY OF 11 DR. RICHARD T. LAHEY, JR.

12 REGARDING CONTENTIONS NYS-25, 13 NYS-26B/RK-TC-1B, AND NYS-38/RK-TC-5 14 On behalf of the State of New York (NYS or the State),

15 the Office of the Attorney General hereby submits the following 16 testimony by RICHARD T. LAHEY, JR., Ph.D. regarding Contention 17 NYS-25.

18 Q.

Please state your full name.

19 A.

Richard T. Lahey, Jr.

20 Q.

Dr. Lahey, you have previously summarized your 21 educational and professional qualifications and submitted 22 testimony in this proceeding, correct?

23 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:

Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 and 3)

ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:

Identified:

Admitted:

Withdrawn:

Rejected:

Stricken:

Other:

NYS000576-00-BD01 11/5/2015 11/5/2015 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 2

A.

Yes. I previously have submitted testimony and 1

reports in this proceeding. My education and professional 2

qualifications and experience are described in my Curricula 3

Vitae and that testimony.

4 Q.

I show you what has been marked as Exhibit NYS000574 5

and NYS000575. Do you recognize those documents?

6 A.

Yes. These are copies of documents that Entergy 7

disclosed to the parties in this proceeding. The first document 8

is a report published by the USNRC and is entitled NUREG/CR-9 7184, ANL-12/56, "Crack Growth Rate and Fracture Toughness Tests 10 on Irradiated Cast Stainless Steels," by Y. Chen, et al. The 11 second document is a report that is also published by the USNRC 12 entitled NUREG/CR-7185, ANL-14/10, entitled "Effects of Thermal 13 Aging and Neutron Irradiation on Crack Growth Rate and Fracture 14 Toughness of Cast Stainless Steels and Austenitic Stainless 15 Steel Welds, by O. K. Chopra, et al.

16 Q.

In those titles, do you know what ANL signifies?

17 A.

Yes. The abbreviation ANL stands for the Argonne 18 National Laboratories, and the designation ANL-14/10 and ANL-19 12/56 signifies, in my experience, that the documents were 20 developed by Argonne National Laboratories for the USNRC.

21 22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 3

Q.

Does NUREG/CR-7184, ANL-12/56 (NYS000574) indicate 1

what the USNRCs role was, if any, in developing the document?

2 A.

Yes. Among other things, the documents bibliographic 3

data sheet (frame 177) reports that the USNRCs Division of 4

Engineering was the sponsoring organization.

5 Q.

Does NUREG/CR-7185, ANL-14/10 (NYS000575) contain 6

similar information?

7 A.

Yes, the cover page states that the document was 8

prepared for the USNRCs Division of Engineering, Office of 9

Nuclear Regulatory Research, and that A.S. Rao was the USNRC 10 Technical Monitor and Project Manager.

11 Q.

Have you now had an opportunity to review NYS000574 12 and NYS000575?

13 A.

Yes.

14 Q.

Have these documents caused you to change the 15 testimony and opinions that you have previously submitted in 16 this proceeding in connection with Contention NYS-25 and 17 Contention NYS-26B/RK-TC-1B or Contention NYS-38/RK-TC-5?

18 A.

No. In fact, the documents support the concerns, 19 opinions, and testimony that I have presented in this 20 proceeding.

21 Q.

Please explain.

22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 4

A.

The document, "Effects of Thermal Aging and Neutron 1

Irradiation on Crack Growth Rate and Fracture Toughness of Cast 2

Stainless Steels and Austenitic Stainless Steel Welds, 3

[NUREG/CR-7185, ANL-14/10, NYS000575], contains analysis and 4

conclusions that are relevant to and supportive of the opinions 5

and testimony that I have presented. To briefly summarize, 6

among other things, the document reports that:

7 Both CASS and austenitic stainless steel welds (but not the 8

heat affected zones (HAZ)) have a duplex structure (i.e.,

9 they contain both ferritic & austenite phases), and both 10 may experience thermal embrittlement (TE). This 11 degradation mechanism applies to CASS structures, 12 components and fittings and the stainless steel welds for 13 reactor vessel internals (RVIs);

14 While thermal embrittlement (TE) may increase the hardness 15 and tensile strength of a material, it also decreases 16 ductility, fracture toughness (i.e., the resistance to 17 crack propagation), and, it decreases the impact strength 18 (i.e., due to significant shock loads) of CASS, its welds, 19 and the welds of austenitic stainless steel. In addition, 20 irradiation also causes embrittlement (IE) in these 21 components for fluences > 2.0 x 1020 n/cm2 (i.e., material 22 damage > 10 dpa), and irradiation makes CASS, its welds, 23 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 5

and the welds of austenitic stainless steel also more 1

susceptible to irradiation-assisted stress corrosion 2

cracking (IASCC);

3 Significantly, IASCC increases the crack growth rate of 4

cracks induced by stress corrosion cracking. However, the 5

document also reports that there is virtually no data above 6

10 dpa -- even though during the period of extended 7

operation some of the reactor vessel internals may 8

experience several hundred dpa; 9

Transgranular brittle cleavage was observed for embrittled 10 materials (and in particular for the CASS tests reported in 11 the other USNRC document, NUREG/CR-7184 [NYS000574];

12 Possible synergy was noted between thermal embrittlement 13 and irradiation embrittlement, although the report stresses 14 the need for more information to develop reliable J-R 15 failure curves. The other USNRC document, NUREG/CR-7184, 16 also notes this same type of synergism.

17 Q.

Do you believe that this report, NUREG/CR-7185, is 18 significant?

19 A.

Yes, it is. As mentioned, this USNRC report supports 20 my opinions and testimony presented in this proceeding. In 21 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 6

addition, this report, which was prepared by Argonne National 1

Laboratories and the USNRC Staff, contains information that 2

I have not seen in previous USNRC reports. In particular, the 3

susceptibility of stainless steel welds to TE and, for the first 4

time ever, the detrimental effect of this embrittlement on 5

impact strength (i.e., for withstanding significant shock loads) 6 and the potential for brittle fracture due to various impulsive 7

loads.

8 Q.

Can you summarize the other USNRC document, NUREG/CR-9 7184, Exhibit NYS000574?

10 A.

Yes. That document, "Crack Growth Rate and Fracture 11 Toughness Tests on Irradiated Cast Stainless Steels,"

12

[NYS000574], also contains analysis and conclusions that are 13 relevant to and supportive of the opinions and testimony that I 14 have presented. For example, as noted previously, the document 15 reports that for CASS materials, synergies exist between thermal 16 embrittlement (TE) and irradiation embrittlement (IE). Also, it 17 is significant that transgranular brittle cleavage was observed 18 for embrittled materials, as was ductile tearing (i.e.,

19 dimpling).

20 Q.

In your opinion, what is the significance of that 21 information?

22 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 7

A.

The observation of both of these failure mechanisms 1

and the synergies between the various aging-related degradation 2

mechanisms is supportive of my previous opinions and testimony.

3 That is, realistic safety and fatigue analyses need to take into 4

account the age-related degradation of materials. For example, 5

the finding in NUREG/CR-7185 that CASS and austenitic stainless 6

steel welds are subject to thermal embrittlement (TE), and that 7

this reduces their impact strength, means that the welds 8

associated with the pressurizer spray nozzle, for example, are 9

particularly vulnerable to significant seismic and 10 thermal/pressure shock loads. Moreover, it appears that 11 vulnerability to early failure of the various RVI welds, which 12 are subject to TE, IE, IASCC, and shock loads, have not been 13 adequately analyzed.

14 Q.

I show you what previously was marked as NYS00488A-B 15 and ask you to compare it to NYS000575.

16 A.

NYS00488A-B is entitled Crack Growth Rate and 17 Fracture Toughness Tests on Irradiated Cast Stainless Steels, 18 NUREG/CR-7184, ANL-12/56 and it appears that this document is a 19 revised manuscript and it bears a manuscript date of December 20 2014. I referred to that earlier manuscript in my previous 21 testimony [e.g., NYS000482], and the State previously presented 22 the document as Exhibit 488. It appears that Argonne National 23 NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 8

Laboratory and the USNRC have subsequently made some edits and 1

republished the document, which is now NYS000574.

2 Q.

It that the end of your supplementary testimony today?

3 A.

Yes it is. However, I reserve the right to supplement 4

my testimony if new information is disclosed or introduced.

5 6

NYS000576 Submitted: September 23, 2015

Pre-filed Supplemental Testimony of Richard T. Lahey, Jr.

Contentions NYS-25, NYS-26B/RK-TC-1B, NYS-38/RK-TC-5 9

UNITED STATES 1

NUCLEAR REGULATORY COMMISSION 2

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3


x 4

In re:

Docket Nos. 50-247-LR; 50-286-LR 5

License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6

Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7

Entergy Nuclear Indian Point 3, LLC, and 8

Entergy Nuclear Operations, Inc.

September 23, 2015 9


x 10 DECLARATION OF RICHARD T. LAHEY, JR.

11 I, Richard T. Lahey, Jr., do hereby declare under penalty 12 of perjury that my statements in the foregoing testimony and my 13 statement of professional qualifications are true and correct to 14 the best of my knowledge and belief.

15 Executed in Accord with 10 C.F.R. § 2.304(d) 16 17 18 Dr. Richard T. Lahey, Jr.

19 The Edward E. Hood Professor Emeritus of Engineering 20 Rensselaer Polytechnic Institute, Troy, NY 12180 21 (518) 495-3884, laheyr@rpi.edu 22 NYS000576 Submitted: September 23, 2015