ML20091C925

Interrogatories on Contentions B & D.Certificate of Svc Encl.Related Correspondence

ML20091C925
Person / Time
Site:	Turkey Point
Issue date:	05/29/1984
From:	Bauser M FLORIDA POWER & LIGHT CO., STEEL, HECTOR & DAVIS
To:	AFFILIATION NOT ASSIGNED, CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
References
84-496-03-LA, 84-496-3-LA, OLA, NUDOCS 8405300687
Download: ML20091C925 (8)

Text

_

QTED CORRESPONDENCE COL *ETED

g. U'mnC UNITED STATES OF AMERICA '84 MY 30 N0:44 NUCLEAR REGULATORY COMMISSION

• nm- r- .. ,

BEFORETHEATOMICSAFETYANDLICENSINGBbkkDNOd,t '

)

In the Matter of ) Docket Nos. 50-250-OLA

) 50-251-OLA FLORIDA POWER AND LIGHT COMPANY )

) ASLBP No. 84-496-03 LA

)

(Turkey Point Nuclear Generating )

Units 3 & 4) )

)

LICENSEE INTERROGATORIES TO INTERVENORS CENTER FOR NUCLEAR RESPONSIBILITY AND JOETTE LORION Licensee Florida Power & Light Company hereby requests that the Center for Nuclear Responsibility and Joette Lorion (Intervenors), pursuant to 10 C.F.R. $ 2.740(b) and the Licensing Board's Prehearing Conference Order of May 16, 1984, answer each of the following interrogatories fully in writing, under oath or affirmation, within 14 days after service.

For each response to the interrogatories listed below, identify the person or persons who prepared, or substantially contributed to the preparation of, the responce. Further, the interrogatories are to be considered the Intervenors' continuing obligation. Accordingly, if -- after answering purOmgh are

0 '

these interrogatories -- additional information comes to Intervenorr' attention with respect to one or mora of the answers, the answers should be amended in a timely manner to provide such additional information.

contention b

, b-1 State whether you intend to call any person or persons as witnesses, including expert witnesses, in this proceeding in support of Contention b and, if so, provide the names, addresses, educational backgrounds, and professional qualifications on any such person or persons.

b-2 Provide summaries of the views, positions, or proposed testimony on Contention b of all persons named in

]

! response to Interrogatory No. b-1 that you intend to present during this proceeding.

] b-3 Identify by au-hor, title, date of publication and j 1

publisher, all books, reports and papers that you intend 4 to employ or rely upon in presenting your direct case i

on Contention b.

b-4 Identify by author, title, date of publication and publisher, all books, reports and papers that you intend to employ or rely upon in conducting your cross-examination of prospective Licensee witnesses testi-fying in connection with contention b.

I

eo .

l

. b-5 If the representations made in Contention b are based '

in whole or in part on any documents prepared by the t

Licensee or the NRC Staff which you contend are deficient, specify which documents and the particular portions thereof you regard as deficient and explain in what way they are deficient.

b-6 Identify by name and publication number the " entirely new computer model" referred to in Contention b.

b-7 Do Intervanors contend that the Emergency Core Cooling  !

System (ECCS) evaluation model employing the new computer model identified in response to Interrogatory No. b-6 has not been accepted by the Nuclear Regulatory Commission for performing ECCS analyses pursuant to the ,

requirements of 10 C.F.R. S 50.467 f

b-8 Identify by author, title, date of publication and publisher all books, reports and papers relied upon >

in support of the statement in Contention b that "Re-flood rates are critical if below 1 or 2 inches per minute."

b-9 Do Intervenors contend that use of "the entirely new computer model" results in failure to meet the ECCS acceptance criteria of 10 C.F.R. $ 50.46 or any other regulatory requirements at Turkey Point?

L

_4-6 b-10 If the answer to Interrogatory No. b-9 is "Yes,"

identify the particular criterion, criteria or other l regulatory requirements which Intervenors contend will l

i not be satisfied at Turkey Point.

i contention d d-1 State whether you intend to call any person or persons as witnesses, including expert witnesses, in this proceeding in support of Contention d and, if so, provide the names, addresses, educational backgrounds, and professional qualifications on any such person or 1 persons.

d-2 Provide nummaries of the views, positions, or proposed

! testimony on Contention d of all persons named in response to Interrogatory No. d-1 that you intend to j present during this proceeding.

d-3 Identify by author, title, date of publication and publisher, all books, reports and papers that you intend to employ or rely upon in presenting your direct case on Contention d.

d-4 Identify by author, title, date of publication and l

publisher, all books, reports and papers that you intend

( to employ or rely upon in conducting your cross-l examination of prospective Licensee witnesses testifying l

in connection with contention d. ,

l l

l >

c 4

d-5 If the representations made in Contention d are based l

in whole or in part on any documents prepared by the l

Licensee or the NRC Staff which you contend are  !

l deficient, specify which documents and the particular  ;

portions thereof you regard as deficient and explain in what way they are deficient.

l d-6 Identify by author, title, date of publication and

publisher, all books, reporto and papers relied upon in support of the statement in Contention d that, "If the minimum allowable DNBR is reduced from 1.3 to 1.7 (sic] as proposed, this would authorize opera-tion of the fuel much closer to the upper boundary of of the nucleate boiling regime."

d-7 Do Intervenors contend that the " proposed decrease in the departure in the nucleate boiling ratio" results in failure to meet the ECCS acceptance criteria of 10 C.F.R. S 50.46 or any other regulatory requirements I

at Turkey Point?

l l

l r

r o

O d-8 If the answer to Interrogatory d-8 is "Yes," identify the particular criterion, criteria or other regulatory requirements which Intervenors contend will not be satisfied at Turkey Point..

Respectfully submitted, AL99L Nirold F.'Reis Michael A. Bauser Steven P. Frantz Of Counsel:

Newman & Holtzinger, P.C.

Norman A. Coll 1025 Connecticut Avenue, N.W.

Steel, Hector & Davis Washington, D.C. 20036 1400 Southeast Bank Building (202) 862-8400 Miami, FL 33131 (305) 577-2800 Dated: May 29, 1984 l

DOCKETED UNITED STATES OF AMERICA #

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 30 NO M4 (inn Cf 5.e 00CMLTikG 4 Stus BRANCH

)

In the Matter of ) Docket Nos. 50-250 OLA

) 50-251 OLA FLORIDA POWER AND LIGHT COMPANY )

) ASLBP No. 84-496-03 LA (Turkey Point Nuclear Generating )

Units 3 & 4) )

)

. CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee Interogatories to Intervenors Center for Nuclear Responsibility and Joette Lorion," dated May 29, 1984, were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below.

Dr. Robert M. Lazo, Chairman Atomic Safety and Licensing Board Panel

, U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Emmeth A. Leubke j Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission l

Washington, D.C. 20555 Attention: Chief, Docketing and Service Section (original plus two copies)

4 o

. O t

Colleen P. Woodhead, Esq.

U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, D.C. 20555 Mitzi A. Young, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

+ Norman A. Coll, ESq.

I' Steel, Hector & Davis 1400 Southeast Bank Building 100 S. Biscayne Boulevard Miami, FL 33131 4

Martin H. Hodder 1131 N.E. 86th Street Miami, FL 33138 6

Dated this 29th day of May 1984.

M Michael A. Bauser 1

Newman & Holtzinger, P.C.

s 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 Telephone (202) 862-8476 I

l i