ML19325E013

Intervenors Statement of Matl Facts as to Which Genuine Issue to Be Heard W/Respect to Intervenors Contention 2.*

ML19325E013
Person / Time
Site:	Turkey Point
Issue date:	10/19/1989
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:
Shared Package
ML19325E014	List: ML19325E013 ML19325E015
References
CON-#489-9352 OLA-4, NUDOCS 8910310196
Download: ML19325E013 (4)

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e. .- i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 DM 23 Pt '33

! BEFORE-THE ATOMIC SAFETY AND LICENSING BOAPD

,. In the Matter of )

) Dockets Nos. 50-250 OLA-4 FLORIDA POWER & LIGHT COMPANY ) 50-251 OLA-4 l

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(Turkey Point Plant, ) (Pressure / Temperature Limits)

Units 3 and 4) )

) l INTERVENORS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEA.RD WITH RESPECT TO INTERVENORS' CONTENTION 2. I L Intervenors contend there is a genuine 1ssue to be heard with respect to the following material facts:

1. Whether Turkey Point Unit 4 has more Effective Full Power .

Operating Years (EFPY) and/or Effective Full Power Hours (EFPH) than ,

Turkey Point Unit 3 and 'a f so whether or not the difference in operating time on a yearly basis is significant.

2. Whether Turkey Point Unit 4 has accumulated more neutron fluence than Turkey Point Unit 3, and if so whether or not the difference is significant.

3. Whether the Licensee has underestimated the fluence accumulated by Turkey Point Unit 4.

4. Whether the NRC Staff acted improperly by granting the Licensee an amendment for an integrated surveillance program in light of the fact that; a) the Staff was aware that the units fuel core loadings and design were dissimilar at the time the 1985 amendments were granted; b) the reasons given to the Staff by the 8910310196 891019 PDR ADOCK 05000250 o G PDR fp h

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Licensee to justify the program did not meet the " substantial advantage to be gained" criteria; c) the Staff was aware at the time they issued the amendments that the capsule T test results for Unit  :

4 had not agreed with predictions in that they showed far greater embrittlement'than either the Staff or FPL had expected.

5. Whether the Licensee meets the requirements of an Integrated Surveillance Program under 10 C.F.R. Appendix H in that; a) the Tureky Point units have had widely divergent capacity factors in 1984, 1986, and 1987; b) the Licensee has no written contingency plan to ensure that the test data won't be compromised by a lengthy outage of either of the Turkey Point units; c) since 1984, Turkey Point units 3 and 4 have been operating with different mixed fuel' Cores.

6. Whether Turkey Point Unit 4 capsule V 1f tested would show a significantly greater sh1ft in RTNDT and higher accumulated fluence than the Unit 3 capsule V that was tested in 1985.

7. Whether the use of Turkey Point Unit 4 plant specific data would cause the pressure / temperature limits to be more conservative than those that have been calculated using a combination of Unit 3 l

and Unit 4 data.

8. Whether flux lot has any affect on embr1ttlement of pressure l

vessel weld material and weld samples.

9. Whether the use of Unit 3 data to predict P/T operational limits for Unit 4 1s unscientific and non-conservative.

10. Whether change in strain rate can significantly affect the 1

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f fracture toughness- RTNDT.

11. Whether additional factors such as strain rate 'and load-history dependent damage uccumulation should be considered in  ;

predicting the'P/T limits for unit 4

12. Whether material degradation caused by neutron irradiation ,

s being accumulat.ive is a time history and rate dependent process.

13. Whether the rates or duration of accumulation are important

'i n considering the effects of neutron irradiation.

14. Whether damage accumulation predictions based on the linear sum are conservat1ve.

1 15. Whether Turkey Point Unit 3 experienced a slow down period.

16. Whether Turkey Point Units 3 and 4 differ in their loac history.

17. Whether the non-conservative P/T limits set for Unit 4 could cause Turkey Point Unit 4 to exceed the requirements of General Design Criterion 31 of Appendix A to 10 C.F.R. Part 50 a

. because the vessel would be more susceptible to a brittle fracture.

l 18. Whether the Licensee violated the provisions of 10 CFR Part 50 Appendix G,Section V which requires that the effects of neutron L irradiation on the reference temperature of a reactor vessel are to l

L be' predicted based upon "the results of pertinent radiation effect studies..." by using Unit 3 data to calculate the ART and revise the l P/T limits for Turkey Point Unit 4.

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Dated:this 19th' day of- +

October 1989, in Miami, Florida,  ;

Respectfully submitted, ,

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'Joette'Lorion, Director Center for Nuclear F.esponsibiltiy ,

, 7210 Red Road #217 Miami, Florida ~33143 (305) 661-2165 t

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