ML19325D631

Affidavit in Support of NRC Staff Response to Licensee Motion for Summary Disposition.* Advises That Author Conducted Review of Facility Integrated Surveillance Program & Found Program Acceptable.W/Certificate of Svc

ML19325D631
Person / Time
Site:	Turkey Point
Issue date:	10/19/1989
From:	Elliot B Office of Nuclear Reactor Regulation, NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML19325D625	List: ML19325D624 ML19325D631
References
OLA-4, NUDOCS 8910250178
Download: ML19325D631 (18)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0fe!SS10N BEFGRE THE ATOMIC SAFETY AND LICENSING BOARD

)I In the Matter of Docket No. 50-250-OLA-4 FLORIDA POWER AND LIGHT h

50-250-OLA-4 i

COMPANY b

h P/T Limits.

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(Turkey Point Plant Units 3 and 4) h

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AFFIDAVIT IN SUPPORT OF NRC STAFF'S RESPONSE TO LICENSEE'S MOTION FOR

SUMMARY

DISPOSITION I, Barry J. Elliot, being duly sworn, state that the following P

statements are true and correct to the best of my knowledge and belief.

1.

My name is Barry J. Elliot.

I am employed by the U.S. Nuclear Regulatory Commission an a Senior Materials Engineer in the Materials and Chemical Engineering Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation.

I conducted the review of the Turkey i

Point Integrated Surveillance Program approved by the NRC in 1985.

I also reviewed the Licensee's report which documented the surveillance data from Turkey Point Unit 3-Capsule V.

In addition,'I assisted J. Tsao and G.E.

Edison in the preparation of the safety evaluation for Amendment Nos.134

}

and 128 to Facility Operating Licensee Nos. DPR-31 and DPR-41, respectively.

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l These amendments revise pressure / temperature limits at the Turkey Point plant to 20 effective full power years. A sumary of my professional qualifications and experience is attached hereto as Exhibit A and is incorporated herein by reference.

2.

The purpose of this affidavit is to respond to Contention 2 as i

admitted by the Atomic Safety and Licensing Board in its June 8, 1989, f

Memorandum and Order, and to support the Licensee's September 11, 1989, l

8910250178 091019 DR ADOCK 05 gO

p i,

Motion for sumary disposition. Only issues related to Contention 2 will be addressed in this affidavit because the Intervenors withdrew Contention 3 from this proceeding by their letter dated September 8,1989.

A.

Admitted Contention 2 3.

Admitted Contention 2 states:

i That the revised temperature / pressure limits that have been set for Turkey Point Unit 4 are non-conser-vative and will cause that reactor unit to exceed the requirements of General Design Criterion 31 of Appendix A to 10 C.F.R. Part 50, which requires that the reactor coolant pressure boundary be designed with a sufficient margin to insure that, when stressed under operating, maintenance,(testing, and postulated accident 1) the boundary behaves in a n conditions, manner and (2) the probability of a rapidly propagating fracture is minimized.

Petitioners contend that the new pressure /

temperature limits could cause the reactor vessel to j

exceed these requirements because the Licensee has based 4

its calculation of the predicted RTNDT for Unit 4 partly on surveillance capsule V test results from Turkey Point Unit 3 rather than predicting the RTNDT for Unit 4 based on Unit 4 capsule Y surveillance capsule data -- a practice which is not scientific, not valid, and could l

cause the Unit 4 reactor to behave in a brittle manner which would make the chances of a pressure vessel failure and resultant meltdown more likely.

Petitioners l

contend that predictions of RTNDT and pressure / temperature limits derived from the shift in i

nil-ductility temperature should be based only on plant-specific Unit 4 data, especially in light of the i

fact that the only tests ever performed on Unit 4 weld cpecimens demonstrated that the weld material in the Unit 4 vessel was 30% more brittle than that of Unit 3.

Because Unit 4's weld material is more embrittled, Petitioners contend that the FPL Integrated Surveillance program does not meet the Requirements of 10 C.F.R.

Appendix G Parts V.A and V.B. and 10 C.F.R. Appendix H, including Appendix H Parts IIC and IIIB.

Finally, Petitioners contend that the surveillance capsule V for Unit 4 should be tested to establish the new pressure / temperature limits and should the testing indicate that the RTNDT for Unit 4 has passed the i

300-degree Farenheit (sic) screening criterion set by the NRC, Unit 4 should be shut down until it is f

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.c demonstrated that the Unit 4 reactor pressure vessel can maintain its integrity beyond this limit.

MemorandumandOrder(RulingUponContentions),LBP-89-15,29NRC493,500-

[

501 (1989) (hereinafter Memorandum and Order); Petitioners' Amended Request for Hearing and Petition for Leave to Intervene, at 7-8.

4.

The Intervenors alleged that the revised pressure / temperature (P/T) 1 limits for Turkey Point Unit 4 are non-conservative because the Licensee 7

used deta from its integrated surveillance program to predict RTNDT, rather than relying on data obtained only from the Unit 4 surveillance capsule, The Licensee and the Staff understand Contention 2 to be limited in scope by j

the Board to two questions:

(1)whetherthe" Licensee'sconductofthe integrated surveillance program at Turkey Point fails to meet the requirements of the program itself " including the requirement of a contingency plan and (2) whether a " difference of less than five percent in the operating time between the two units is simply not significant."

Memorandum and Order at 503. The Staff agrees that the Licensee has conducted an acceptable integrated surveillance program. And the Staff agrees that a difference in operating time of this proportion does not invalidate the surveillance data.

l 5.

The Intervenors identified the bases for Contention 2 in their discovery responses:

(1) Turkey Point Units 3 and 4 have had different l

extendedoutages;(2)theLicenseeimplementeditsintegratedsurveillance program even though initial test results differed from those predicted; (3)

Unit 4 experienced an overpressurization event and Unit 3 did not; and (4) l during 1987 Unit 3 operated at 14 percent capacity factor and Unit 4 operated at 45 percent capacity factor. These issues are discussed below.

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B.

Pressure-Temperature (P/Ti t.imits and ART 6.

The regulatery requirements for calculating P/T limits are set forth in Appendix G of 10 C.F.R. Part 50. When the reactor core is not i

critical, pursuant to 10 C.F.R. Part 50. Appendix G.Section IV.A.2, the P/T limits for the reactor vessel must be at least as conservative as those obtained by using the analytical methods and the required margins of safety of Appendix G of the American Society of Mechanical Engineers (ASME) Code, supplemented by the requirenents of Section V of 10 C.F.R. Part 50, Appendix G.

The effects of neutron irradiation on adjusted reference temperature (ART) and upper shelf energy of reactor vessel beltline materials, including weld materials, are predicted from the results of studies of irradiation effects as well as the results of the surveillance program of Appendix H of Part 50 of the Commission's regulations.

10 C.F.R. Part 50, Appendix G, Section V.A.

7.

The Staff recommends that neutron irradiation damage to reactor vessel beltline materials be calculated in accordance with Revision 2 of Regulatory Guide 1.99. The ART is used to calculate P/T limits. Regulatory Guide 1.99, Rev. 2 defines the adjusted reference temperature as the sum of (1) the initial (unirradiated) RTNDT, (2) the increase in RTNDT due to neutron irradiation, and (3) a margin of safety to account for uncertainties in the test data. The initial RT is a baseline temperature value NDT calculated by testing unirradiated beltline material. The upper shelf l

energy is not required to calculate P/T limits and it has been found to be i

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outside the scope of this proceeding by the Board. Memorandum and Order at i

506.

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, l 8.

Regulatory Guide 1.99, Dev. 2 indicates that the increase in RTNDT resulting from neutron irradiation is calculated by multiplying a chemistry factor by a fluence factor. The fluence factor is dependent upon the accumulated neutron irradiation (neutron fluence) received by the reactor vessel.

In calculating the Turkey Point P/T limits, fluence factors were derived by using the neutron fluence at the inside surface of the reactor I9 n/cm (E MeV). The neutron r

vessel; the neutron fluence value is 2.022 x 10 fluence is the accumulated number of neutrons (n) with energies greater than 1.0 million electron volts (1MeV), irradiating a square centimeter (cmt) of material. When neutron irradiation causes an increase in ART, the P/T limits must be increased by the amount of increase in ART to ensure that the margins of safety in Appendix G of the ASME Code are maintained.

For this reason, the P/T limits for nuclear power plants must be revised periodically to account for the increase in ART which results from neutron irradiation.

I" 9.

The chemistry factor needed to calculate the increase in RTNDT weld metals may be calculated by one of two methods:

the first method uses Table 1 in Section 1.1 of Regulatory Guide 1.99, Rev. 2; the second method uses the least squares fit of the credible surveillance data described in l

j Section 2.1.

The chemistry factors in Table 1 are dependent upon the amounts of copper and nickel in the weld metal. The chemistry factors in l

Table I were derived through statistical analyses of reactor vessel surveillance data obtained from all comercially-operated nuclear power i

plants in the United States, including the Turkey Point surveillance data.

These chemistry factors are mean values for weld metals in all i

commercially-operated nuclear reactor vessels in the United States. Once a

i

. i mean value for the copper and nickel content is obtained it is used to calculate the ART for a particular reactor vessel.

10.

In the least squares fit method, which was used by the Licensee and is described in Section 2.1 of Regulatory Guide 1.99, Rev. 2, the chemistry factors are determined directly from the surveillance material from a particular plant, and the amount of copper and nickel in the weld do not enter into the calculation. When credible surveillance data from a particular plant are available, the Staff prefers that they be used to calculate the chemistry factor for that plant because such surveillance data are both weld and plant-specific. These plant-specific data are more reliable than values calculated by statistical analyses of surveillance weld materials for all commercially-operated nuclear power plants in the United States.

Therefore, the Staff recommends the use of these data whenever they are available.

11.

In the least squares fit method, the chemistry factor is determined by dividing the sum of the products of the increase in RTNDT i

resulting from testing the surveillance samples and the fluence function corresponding to the neutron fluence of the capsule by the sum of the

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fluence functions corresponding to the neutron fluences of the capsules.

This method fits the plant surveillance data in such a way as to minimize the sum of the squares of the errors.

The method set forth in Section 2.1 may be used only if the surveillance data are determined to be credible surveillance data. These data are obtained by placing surveillance material, which is representative of the reactor vessel beltline material, P

into capsules which are then placed into the reactor vessel.

_ _ _, _ _ _ _,,. _... _.. _ _ _ _ -. _ _.. ~ _

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12. The Turkey Point units approached ten effective full power years (EFPY) of operation in 1988. An EFPY is the amount of energy produced by operation of a nuclear reactor at full power continuously over a one year period. Because of outages and operation levels are usually below 100 percent, a reactor will produce less than one EFPY during a calendar year, j

In anticipation of reaching ten EFPY, the Licensee submitted its application to amend the P/T limits in the Technical Specifications for the Turkey Point Plant to make them applicable for operation up to 20 EFPY. Amendment Number 1M r; License Number DPR-31 for Turkey Point Unit 3 and Amendment Number 1?8 to License Number DPR-41 for Turkey Point Unit 4 approved the P/T limit curves for up to 20 EFPY. The Staff's Safety Evaluation indicates that for both Turkey Point units, the P/T limits meet the required margin of safety for 20 EFPY of operation.

C.

Integrated Surveillance Proaram

13. Surveillance materials are irradiated in capsules that are placed inside the reactor vessel. The capsules are withdrawn to comply with Appendix H of 10 C.F.R. Part 50. When a capsule is withdrawn from the reactor, the neutron fluence of the capsule is calculated; that is, the i

accumulated neutron irradiation of the capsule is determined. The materials J

in the capsule are then Charpy-impact tested to determine the increase in RT resulting from the neutron fluence of the capsule.

NDT

14. Embrittlement is detemined from the results of Charpy-energy tests which measure Charpy-energy at different temperatures. Surveillance specimens are broken over a range of different temperatures to provide a curve of Charpy-energy versus temperature. The Charpy-energy test is I

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conducted by subjecting the material in a surveillance capsule to hamer

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' strikes at a range of temperatures. The Charpy-energy test results have i

uncertainties associated with them. Therefore, the Staff, in Regulatory Guide 1.99 Rev. 2. recommends that embrittlement be determined from test-l data from two or more surveillance capsules.

In addition, an evaluation of the amount of embrittlement must include a margin for the uncertainties for the test method. The test results from one surveillance capsule (for i

example, Capsule T from Unit 4) do not, alone, demonstrate the precise amount of embrittlement of the Unit 4 beltline material, because more than one data point is necessary to obtain adequate test results.

15. Capsules T and V from Turkey Point Unit 3 and Capsule T from Turkey Point Unit 4 have been withdrawn and tested. Tests performed on the weld metal test specimens in each capsule permit the calculation of the increase in RTNDT, resulting from neutron irradiation of the capsule. These data points were evaluated, in accordance with the method described in i

Section 2.1 of Regulatory Guide 1.99, Rev. 2, to determine the chemistry factor for the Turkey Point critical weld metals. The chemistry factor obtained by the Section 2.1 method is detemir.ed directly from the results l

of testing the plant-specific surveillance samples; in the instant case.

Turkey Point surveillance samples.

16. Weld wire of heat number 71249 and flux lot 8445 was used to i

l l

fabricate the intermediate-shell-to-lower shell girth welds in Turkey Point Unit 3 and Turkey Point Unit 4 and the surveillance weld in Turkey Point Unit 3.

The surveillance weld samples in Turkey Point Unit 4 were fabricated using weld wire from heat number 71249, however, a different flux l

l lot, 8457, was used.

Since irradiation embrittlement is dependent upon the amount of copper and nickel in the weld and the accumulated neutron fluence, i

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the flux lot is not considered to be important in detemining the sensitivity of the weld to irradiation embrittlement.

17.

The Turkey Point surveillance material is credible because the

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surveillance weld samplet are fabricated from the same heat number of weld l

wire as was used in the critical beltline welds in the Turkey Point Units 3 and 4 reactor vessels. The source of the copper and nickel in the Turkey Point welds is the weld wire. Only minor variatione in the contents of the-t weld wire are expected. Therefore, both the surveillance weld samples and

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the beltline welds which are fabricated of the same weld wire, will have i

equivalent amounts of copper and nickel. When the amounts of copper and nickel are equivalent, the increase in RTNDT. for a given neutron fluence should be equivalent.

The increase in RT for the surveillance data NDT should be equivalent to that of the beltline weld and the data will be i

f credible. Since the surveillance data are credible the surveillance data i

I and the leasts squares method of evaluating it may be used to predict the increase in RTNDT' D.

The Use of Surveillance Data from Units 3 and 4 to Calculate ART l

for Unit 4 Was Proper

18. The Intervenors allege that the Licensee implemented its integrated surveillance program even though initial test results differed from predicted results. The test results from Capsule T of Unit 4 do not j

significantly exceed the projected mean value. The Licensee properly used surveillance data from capsules in both Turkey Point Units 3 and 4 to calculate the ART for Unit 4.

The weld specimens from Capsule T in Unit 4 were exposed to a neutron fluence (accumulated neutron irradiation) of 6.05

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y.,

p y-18 x 10 n/cmt (E IMeV). The increase in RT resulting from neutron NDT irradiation of the weld Capsule T metal test specimens is 225'F.

is obtained by

19. The projected (expected) mean increase in RTNDT calculating the product of the chemistry factor and the fluence factor by 6

the methods' set forth in Regulatory Guide 1.99, Rev. 2.

The Staff independently performed these calculations. The fluence factor which 18

/

corresponds to a neutron fluence level of 6.05 x 10 is 0.859. The least r

squares fit method was used to calculate the chemistry factor for the Turkey Point Plant P/T limits; the chemistry factor calculated is 200.2'F. The for the weld metal test expectM mean value for the increase in RTNDT specimensfromCapsuleTofUnit4is172*F.1/

20.

It is not proper to compare the expected mean increase in RTNDT and the measured value, as the intervenors did, because such a comparison is statistically meaningless.

In order to detemine whether the difference IS Of between the expected increase and the measured increase in RTNDT importance, it is necessary to examine the normal range in which RTNDT is 172*F with a values will fall. The expected mean increase in RTNDT ll standard deviation of 28'F.

Regulatory Guide 1.99, Rev. 2 provides that the for weld metal should fall within measured values for the increase of RTNDT I

two standard deviations of the expected mean value ( 56'F). The i

temperature range within two standard deviations of the mean expected I:

L increase in RT is 116'F to 228*F (172'F i 56'F). The measured increase NDT in RT

'is 225*F, which is less than the upper 95 percent confidence value NDT is calculated by taking the 1/

The expected mean valve for increase in RTNDT product of 0.859 and 200.2*F = 171.97'F.

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11 -

of 228'F; the measured value meets Regulatory Guide 1.99, Rev. 2.

While the Intervenors correctly state that the measured increase in RT is 225'F and NDT that it exceeds the mean expected value of 172*F this difference is within the range of scatter expected for the data. The weld metal test specimens from Capsule T of Unit 4 yielded test results which are within the range of scatter expected for the surveillance data. Therefore, the Unit 4 t

surveillance capsule data are credible according to Regulatory Guide 1.99, Rev. 2, and may be used in' conjunction with Unit 3 surveillance capsule data to calculate the ART for Unit 3 and Unit 4.

E.

Differences in Operating Times and Power Levels Are Accounted for in Licensee's Calculations

21. The Intervenors allege that differences in operating times and power levels at the Turkey Point Plant invalidate the surveillance data for the plant and, therefore, the integrated surveillance program as conducted at the Turkey Point Plant is unacceptable. As was discussed above, the L

increase in ART for irradiated samples from each capsule is calculated for the amount of accumulated neutron irradiation received by the capsule. When the capsules are irradiated for shorter time periods or at lower power L

levels, the accumulated neutron irradiation will be less.

Differences in l

operating times or power levels are accounted for in calculating the I

accumulated neutron irradiation of the capsules, therefore, these L

differences do not affect the determination of ART. The surveillance data provided by the Licensee take into account operating times and power levels L

at Turkey Point, therefore, the allegation that differences in operating i

times and power levels invalidate the data is unsupported by the facts.

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i et Moreover, the factual evidence supports the conclusion that the Licensee properly conducted the integrated surveillance program.

22. The Turkey Point Final Safety Analysis Report (FSAR) indicates that the core design, the reactor pressure vessel, and its internal equipment are very similar for Turkey Point Units 3 and 4.

See FSAR, il 3.2 and 4.2.

During each core loading for the Turkey Point units there may be small differences in core and operation details; however, over the life of the plant these small differences are accounted for in the neutron fluence calculations.

F.

Contingency Plan 23.

10 C.F.R. Part 50, Appendix H requires that plants have contingency plans incorporated into their integrated surveillance programs.

e Appendix H,Section II.C.3. of 10 C.F.R. Part 50, specifically requires that integrated surveillance programs include "a contingency plan to ensure that the surveillance program for each reactor will not be jeopardized by operation at reduced power level or by an extended outage of another reactor from which data are expected." Contingency plant are required by Appendix H because some plants which participate in the integrated surveillance system do not have surveillance capsules in their reactor vessels.

Plants without surveillance capsules rely on surveillance capsules irradiated in " host" plants to monitor irradiation damage. The purpose of the contingency plan is to ensure that if one host reactor in the integrated surveillance program has an extended shutdown or long period of low power operation, surveillance test data will be available from another host reactor in the program.

24. The integrated surveillance program at the Turkey Point plant does not rely on data obtained from surveillance capsules irradiated in host plants; surveillance capsules are in the reactor vessels of Units 3 and 4 at

L Turkey Point. Therefore, if either unit were to undergo an extended outage i

or long period of low power operation, the capsules in the operating unit would be available for surveillance.

In addition, the capsules in the inoperable unit could be moved into the operating unit. The less than five percent difference in operating time between the two units does not require implementation of the Turkey Point plant contingency plan.

G.

Other Issues Raised by the Intervenors

25. The Intervenors allege the Unit 3 surveillance data should not be used to calculate the ART for Unit 4 because in 1981, Unit 4 experienced two overpressurization events and Unit 3 did not. On November 28, 1981, and on November 29, 1981 Unit 4 experienced overpressurization events. The peak pressures during the events were about 1115 pounds per square inch gauge (psig) and 740 psig, respectively, and the temperature of the reactor vessel was approximately 110*F. These pressure and temperature levels exceeded the P/T limits for the plant. However, the levels were substantially below the vessel's design pressure of 2485 psig and the normal operating pressure of 2235 psig, as well as, the operating temperature of 546.2'F of the reactor coolant inlet.

The P/T limits ensure that pressure and temperature

(

transients do not result in brittle fracture of the reactor vessel during heatup and cooldown periods. The 1981 transients were minor events and did not result in brittle fracture of the vessels. Moreover, these events did not increase embrittlement or the ART of either the surveillance material or the vessel material. The events do not invalidate the surveillance data.

Therefore, Unit 3 surveillance data were properly used to calculate the ART l

for Unit 4.

l:

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26. The Intervenors contend that operation of Unit 3 at 14 percent capacity and Unit 4 at 45 percent capacity during 1987 calls into question the continued use of the Turkey Point P/T limits calculated for 20 EFPY, For the reasons discussed in Section E, differences in capacity factors of this magnitude are unimportant. Differences in operating times and power levels, and thus capacity factors, are accounted for in calculating the accumulated neutron irradiation of surveillance capsules or the reactor vessels. Therefore, the total neutron fluence received is of significance.

The Licensee has indicated that the differences in total neutron fluence between Unit 3 and Unit 4 is small, less than 3 percent for the period in question. Affidavit of Stephen A. Collard on Contentions 2 and 3 at 62, Table 5.

A difference of this magnitude in total neutron fluence for the Turkey Point Units is insignificant. The reactor vessels for Turkey Point Units 3 and 4 have continued to operate since 1985 within their design limits. Therefore, the ART and P/T limits based upon surveillance capsule l

data from 1995 or earlier are still valid and reliable and there is no basis l

l for adjusting the calculated ART of 20 EFPY or the P/T limits.

1-1 H.

Licensee's Calculation of Hypothetical P/T Limits for Unit 4 l

27.

I reviewed the Licensee's statements regarding the calculation of l

1

- hypothetical P/T limits for Unit 4 based on the methodology set forth in i

Regulatory Guide 1.99, Rev. 2.

Affidavit of Stephen A. Collard on 1-Contentions 2 and 3, at 11 71-74.

I performed independent calculations and my results indicate the Licensee's hypothetical P/T limits are within the proper range.

28. The Licensee calculated the P/T limits for Turkey Point Units 3 and 4 according to the methods set forth in Regulatory Guide 1.99, Rev. 2.

P In addition, the P/T limits meet the required margin of safety for 20 EFPY of operation. Turkey Point Plant's implementation of the integrated surveillance program i.eets the requirements of the program itself. The Turkey Point surveillance data are credible. Differences in operating times and power levels are accounted for in measurements of the neutron irradiation of the Turkey Point capsules and do not affect the determir.ation of' ART. The integrated surveillance program did not produce results which differ in any significant way from predicted results. The 3

overpressurization events in 1981, did not increase embrittlement or the ART of either the Turkey Point surveillance material or the vessel material.

The events did not invalidate the surveillance data. The Licensee properly used the surveillance data from both Unit 3 and Unit 4 to calculate the P/T limits at Turkey Point,

&~x OAW 'Barry K F.lliot Subscri ,and sworn before me this day of October, 1989. l /- 7 Nota N3hemlulenEx$esa41.leso l-l 1

j n w j L* EXHIBIT A BARRY J. ELLIOT U.S. NUCLEAR REGULATORY COMMISSION-MATERIALS AND CHEMICAL ENGINEERING BRANCH DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY OFFICE OF NUCLEAR REACTOR REGULATJON STATEMENT OF PROFESSIONAL QUALIFICATIONS I am currently employed by the U.S. Nuclear Regulatory Connission as a Senior Materials Engineer in the Materials and Chemical Engineering Branch, j Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation. I am responsible for the review and the evaluation of safety analysis reports which are related to the materials engineering aspects of components in nuclear power plant systems. I also provide technical assistance to the Offices of Nuclear Reactor Regulation and Nuclear Regulatory Research on related reactor safety matters. I have been employed at the Nuclear Regulatory Connis; ion since March 31, 1989. I graduated from Rensselaer Polytechnical Institute in 1968 with a Bachelor of Science degree in Materials Engineering. I attended evening classes at Fairleigh Dickinson University, where in 1971, I received a Masters of Science degree in Business Administration. I was employed by Curtiss Wright Corporation' from 1968 to 1980. From 1968 to 1971 I worked in the Materials Development Laboratory of the Aero-nautical Division where I performed failure analyses on reciprocating and gas-turbine engines, and developed test apparatus to evaluate material reliability. From 1971 to 1980 I worked in the Nuclear Division where I was responsible for developing and implementing non-destructive examination r test procedures and fusion weld prucedures to be used in the fabrication and inspection of U.S. Department of the Navy nuclear pressure vessels. __._ _ ~,. _ _ _.. _... ... ~ -. ... ~

[, ' M, ' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION '89 OCT 20 P3 :16 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD bosb g,ir,-' In the Matter of Docket Nos. 50-250 OLA-4 1 50-251 OLA-4 ) FLORIDA POWER AND LIGHT COMPANY (Turkey Point Plant, Units 3 and 4) (P/TLimits) CERTIFICATE OF SERVICE I hereby certify that copies of " RESPONSE OF NRC STAFF IN SUPPORT OF LICENSEE'S MOTION FOR

SUMMARY

DISPOSITION" and " AFFIDAVIT IN SUPPORT OF NRC STAFF'S RESPONSE TO LICENSEE'S MOTION FOR

SUMMARY

DISPOSITION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by a double asterisk by use of express mail tervice, this 19th day l of October,1989: B. Paul Cotter, Jr., Chairman

• Richard J. Goddard, Esq.*

Administrative Judge Regional Counsel Atomic Safety and Licensing Board USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., N.W., Suite 2900 Washington, D.C. 20555 Atlanta, GA 30303 Glenn 0. Bright

• Atomic Safety and Licensing Board Administrative Judge Panel (1)

Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i Washington, D.C. 20555 Atomic Safety and Licensing l' Jerry Harbour

• Appeal Panel (5)*

Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory tomission Washington, D.C. 20555 Office of the Secretary

• U.S. Nuclear Regulatory Comission Steven P. Frantz, Esq.

Washington, DC 20555 l L Harold F. Reis. Esq. Attn: Docketing and Service Section i Newman & Holtzinger, P.C. l 1615 L. Street, N.W., Suite 1000 Joette Lorion** i Washington, D.C. 20036 7269 SW 54th Avenue Miami, FL 33143 l l L l L 1-.. 1

[1 I f. t ...Q,y .i - 2.- John T.' Butler, Esq. i Steel. Hector & Davis Center for Nuclear Responsibility ** 4000 Southeast Financial Center 7210 Red Road #217 Miami, FL..' 33131-2398 Miami, FL 33141 Adjudicatory File (2)* Atomic' Safety'and Licensing Board ' U.S. Nuclear Regulatory Connission Washington, D.C. 20555 I k(k 'M Patticia Jehle Counsel for NRC Staff l } i t l. t l.. l L t l' + l t u .j + i f g l 1 lI r .s 1; i u l ^. .-}}