ML20090C296

Response to Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20090C296
Person / Time
Site:	Turkey Point
Issue date:	07/10/1984
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:	FLORIDA POWER & LIGHT CO.
References
OLA, NUDOCS 8407130238
Download: ML20090C296 (8)

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UNITED STATES OF AMERICA 5 ~-

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-250 OLA Florida Power & Light Co. ) 50-251 OLA Turkey Point Units 3 and 4 )

INTERVENORS' RESPONSE TO INTERROGATORIES PROPOUNDED BY FLORIDA POWER & LIGHT COMPANY Pursuant to 10 C.F.R. S 2.740 (b), and the Licensing Board's Prehearing Conference Order of May 16, 1984, Intervenors present the following responses to the interrogatories propounded by the Florida Power & Light Company.

Responses were prepared by Joette Lorion under the supervision of her' attorney,. Martin.H. Hodder.' Intervenors understand that the interrogatories are a continuing obligation and will provide additional information when it comes to Intervenors' attention.

Contention b b-1 Witness selection hasn't been presently determined. Pursuant to rule 10 C.F.R. S 2.740 (b) , Intervenors will keep the Board and parties posted.

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b-2 Not applicable, b-3 The reports and papers that Intervenors intend to rely upon in presenting the case on contention b are as follows:

" Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors," 10 C.F.R. 50.46 and Appendix K of 10 C.F.R. 50.46, FR Volume 39, Number 2, January 4, 1974.

Demastry (FPL) to Eisenhutt (NRC) ," Additional Analyses (LOCA with Ungridded BART Model) For F H/ BART Technical Specification Amendment," September 20, 1983.

D. Mcdonald (NRC) letter to Chrig (FPL), " Technical Specification Amendments to Support the Integrated Program for Vessel Flux Reduction and Operation with the New Steam Generators,"

December 23, 1983.

WCAP-9561,"BART-Al : A Computer Code for Best Estimate Analysis of Reflood Transients." Accepted by letter dated December 21, 1983, C.O. Thomas (NRC) to E.P. Rahe (Westinghouse).

WCAP-9561;"BART-Al : A Computer Code for Best Estimate Analysis of Reflood Transients," January, 1980.

Uhrig (FPL) letter to Eisenhut (NRC), " Proposed License Amendment Optimized Fuel Assembly and Wet Annular Burnable Absorber Rods," June 3, 1983.

s 48 Federal Register, 45862, October 7, 1984.

NRC Report on Pressurized Thermal Shock, Nov. 1982.

b-4 The above would also be employed in cross examination, b-5 Documents prepared by the NRC and Licensee that we contend are' deficient are:

Mcdonald (NRC) letter to Uhrig (FPL), " Technical Specification Amendments to Support Program for Vessel Flux Reduction,"

December 23, 1983.

Thomas (NRC) letter to Rahe (west), " Application for Referencing of Licensing Topical Report WCAP-9561, BART A.1: A Computer Code for Best Estimate Analysis of Reflood Transients,"Dec.

21, 1983.

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TMey are deficiest in that the approved refilod rate is not in conformance with safe power reactor operation.

b-6 "The entirely new computer model referred to in contention b is the BART-Al Model, WCAP-9561.

l b-7 Yes, current acceptance of the ECCS Evaluation model

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5 employing the new computer code is only conditional.

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in 5 b-8 The statement that reflood rates are critical if helow

a em 1 or two inches per minute was composed by the Center's then 9.]

technical advisor, Robert B. . Pollard.of the Union of Concerned y s Scientists, Washington, DsC , who was giVen the technical fj-hjh documents listed in B-3. Other documents used are unknown.

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b-9 Yes, Intervenors contend that the use of "the entirely new M

11 computer model" results in failure to meet the ECCS

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..2 acceptance criteria of 10 C.F.R. S 50.46.

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b-10 The criteria which will not be satisfied at Turkey Point Nh

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are: 10 C.F.R. 50.46 (c) and (d), and 10 C.F.R. Appendix ~ $-- A, Part 35, and 10 C.F:R. Appendix K, D.3 and D.5. g(_"", fi2 f: = Contention d M5 pz:.n:: ms: Pursuant d-l Witness selection hasn't been presently determined. ?E!h

15. Intervenors will keep the Board

~ E3                                to rule 10 C.F.R. S 2.740 (b)

@ss NFEI and parties posted. p._ 4:r25 d-2 Not applicable. g.Eg d-3 The reports and papers that intervenors intend to employ or 3$$ ' SH5 rely upon in presenting their case on contention d are:

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Mcdonald (NRC) letter to Uhrig (FPL), " Technical Specification Amendments to Support Program for Vessel Flux Reduction and Operation with New Steam Generators, Dec. 23, 1983. Uhrig (FPL) letter L-83-344 to Eisenhut (NRC), " Turkey Point Units 3 and 4, Docket nos. 50-250, 50-251, Proposed License Amendment F H/ Fg , Sept. 9, 1983. Uhrig (FPL) letter L-83-507 to Eisenhut (NRC) , " Clarification to F H/ Fg Technical Specification Changes," October 4, 1983.

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Thomas (NRC) letter to Rahe (West), " Application for Referencing of licensing Topical Report WCAP-9561, "BART A1: A Computer Code for Best Estimate Analysis of Reflood Transients, Dec. 21, 1983. Mcdonald (NRC) letter to Uhrig (FPL), " Amendments No. 98 and No. 92 to Facility Operating License for Turkey Point Units 3 and 4, December 9, 1983. ,

           " Acceptance Criteria for Emergency Cooling Systems for Light Water Cooled Nuclear Power Reactors," 10 C.F.R. 50.46 and Appendix K or 10 C.F.R. 50.46, Federal Register, Volume 39, No. 2, January 4, 1974.

Uhrig (FPL) letter to Eisenhut (NRC) , " Optimized Fuel Assembly and Wet Annular Burnable Absorber Rods," June 3, 1983. NRC Staff Report on Pressurized Thermal Shock, Nov. 1982. d-4 The above documents would also apply to Intervenors cross  ; examination. i n

d-5 Documents prepared by the NRC and Licensee that we contend are deficient are: Mcdonald (NRC) letter to Uhrig (FPL), " Technical Specification Amendments to Support Program for Vessel Flux Reduction," December 23, 1983. Th6 mas (NRC) letter to Rahe (West.), "Applicationfor Referencing of Licensing Topical Report WCAP-9561, BART A.1: A Computer Code for Best Estimate Analysis of Reflood Transients," Dec. 21, 1983. They are deficient in that the approved DNBR is not in conformance with safe power reactor operation. d-6 The statement that "If the minimum allowable DNDR is reduced from 1.3 to 1.7 as proposed, this would authorize operation of the fuel much closer to the uoper boundary of the nucleate boiling regime," was composed by the Center's then technical expert, Robert B. Pollard of the Union of Concerned Scientists in Washington D.C. Robert Pollard utilized the technical documents described in d-3. Any other documents that may have been utilized are presently unkown. d-7 Yes, Petitioners contend that the " proposed decrease in the departure in the nucleate boiling rati6" would result in failure to meet the ECCS acceptance criteria of 10 C.F.R. 50.46.

d-8 The crieria that Intervenors contend will not be met at Turkey Point are 10 C.F.R 50.46 (b) (1) and Appendix K (c) (4). These interrogatories were prepared and signed by Joette Lorion in the absence of her attorney, Martin Hodder, becanse of mailing constraints. Respectfully Submitted, h Joette Lorion Director CNR 7210 Red Rd. #208 Miami, F1. 33143 Ph: (305) 661-2165 Dated: July 10, 1984

State Of Florida ) County of Dade ) I, JOETTE LORION, being first duly sworn, do depose and say that the following is true and correct to the best of my knowledge, information and belief.

                                                 "t> L b                    oW Joette Lorion Sworn and subscribed before me this               fb      day of July 1984.

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NotaryPublp State of Florida patsev eurtre suit Cr rtestos av :0**!ss104 trP. est is.! m f3TED FNH! Cf t!R8L 143. 043. My Commission Expires:

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION U, $Vr> BEFORE THE ATOMIC SAFETY AND LICENSING BOARD d'AC ' In the Matter of ) DocketNos.50-2hhQ4h7 Florida Power & Light Company ) 50-251.0U4 00 Turkey Point Units #3 and #4 ) UG::TlM[. E .Qg ,.,Y; CERTIFICATE OF SERVICE I hereby certify that copies of the "Intervenors' Response to Interrogatories Propounded By Florida Power & Light Company" have been served on the following parties by deposit in the United States Mail, first class, this l0 th day of July, 1984. Dr. Robert M. Lazo, Chairman Norman A. Coll, Esq. Atomic Safety & Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 100 S. Biscayne Blvd. Washington, D.C. 20555 Miami, F1. 33131 Dr. Emmeth A. Luebke Harold F. Reis, Esq. Atomic Safety & Licensing Board Lowenstein, Newman, Reis & U.S. Nuclear Regulatory Commission Axelrod Washington, D.C._20555 1025 Connecticut Ave NW Washington, D.C. 20036 Dr. Richard F. Cole Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Colleen P. Woodhead, Esq. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 $ gl ' 6*s-Dccketing and Service Section Martin H. Hodder Office of the Secretary Attorney for Center for U.S. Nuclear Regulatory Commission Nuclear Responsibility Washington, D.C. 20555 and Joette Lorion l & Vbco6 cia N00

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