ML20206C484

Licensee Supplemental Response to Intervenor First Set of Interrogatories to Licensee.* Ej Weinkam & SE Turner Resumes & Certificate & Svc Encl.Related Correspondence

ML20206C484
Person / Time
Site:	Saint Lucie
Issue date:	11/09/1988
From:	Demastry J FLORIDA POWER & LIGHT CO.
To:	RICH, C.
Shared Package
ML20206C459	List: ML20206C456 ML20206C484
References
88-560-01-OLA, 88-560-1-OLA, OLA, NUDOCS 8811160298
Download: ML20206C484 (19)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

,: r r BEFORE THE ATOMIC SAFETT AND LICENSING BOARD E

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In the Matter of ) Docket No. 50-335 OLA

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FLORIDA POWER AND LIGHT COMPANY )

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(St. Lucie Plant, Unit No. 1) ) (ASLBP No. 88-560-01 OLA)

)

LICENSEE'S SUPPLEMENTAL RESPONSE TO INTERVENOR'S FIRST SET OF INTERROGATORIES TO LICENSEE Florida Power & Light Company ("Licensee") hereby r,upplements its response to Intervenor's First Set of Interroga-tories to Licensee in the above captioned proceeding.

Licensee's Supplemental Response to Intervenors General Interrogatories l General Interrogatory I.A The Licensee expects to call the following three ,

expert witnesses to testify in regard to the remaining issues in contenticn in this proceeding (portions of Contentions 3 and 7, and Contention 6 in its entirety):

Mr. Weinkam will testify <

1) Mr. Edward J. Weinkam in regard to contentions Florida Power & Light Co.

700 Universe Blvd. 3, 6 and 7. Mr. Weinkam's Juno Beach, FL 33408 qualifications are enclosed ,

as Attachment A.

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2) Dr. Krishna P. Singh Dr. Singh will testify Holtec International in regard to Contentions ,

139A Gaither crjve 3 and 6. Dr. Singh's Mount Laurel, NJ 08084 goalifications are enclosed {

as Attachment B.

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3) Dr. Stanley E. Turner Dr. Turner will testify Holtec International in regard to Contentions 3, 230 Normandy Circle, E. 6 and 7. Dr. Turner's Palm Harbor, FL 34683 qualifications are enclosed as Attachment C.

General Interrogatory I.B Contentions 3 and 6 ,

Mr. Edward J. Weinkam will offer testimony primarily

concerning the Boraflex in-service surveillance program for the St. Lucie 1 spent fuel storage rarks. Mr. Weinkam's testimony will describe the surveillance procedure and the testing to be performed on Boraflex specimens that have been placed in the spent fuel pool.

Dr. Krishna P. Singh will offer testimony primarily concerning the design and fabrication of the spent fuel storage racks for St. Lucie 1. The testimony will considers (1) the extensive experience of the Joseph Oat Corporation in the manufacture of spent fuel storage racks utilizing Boraflex;

" (2) the design of the St. Lucie 1 spent fuel storage racks as it employs an established technology and permits the shrinkage of Boraflex without affecting its performance; and (3) the results of testing programs demonstrating that Boraflex is suitable for use as a neutron absorber material in spent

fuel pool environments.

Dr. Stanley E. Turner will offer testimony primarily concerning the performance of Boraflex under test and operational conditions, and the reactivity effects of gap formation, l

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" should it occur in the Boraflex panels.

z Dr. Turner's testimony will also consider the a'dequacy of the surveillance program at.~St. Lucie 1 for detecting any unexpected degradation of Boraf1'ex should it occur. Based upon this testimony,LDr.

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. Turner will conclude that there is amp 1e and credible defense-in-depth against any adverse consequences of Boraflex degradation that may occur in the St. Lucie I storage racks.

V Contention 7 Mr. Edward J. Weinkam will offer testimony primarily concerning the adminictrative controls in place for the spent fuel storage racks at St. Lucie 1 to prevent the accidental misplacement of a fuel assembly in the' racks.

Dr. Stanley E. Turner will offer testimony denonstrating that the design of the sporet fuel storage racks at St. Lucia 1 complies with regulatory requirements, and demonstrating

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the impossibility of a criticality accident with St. Lucie

! I fuel in the absence of a moderator.

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-UNITED STATES OF AMERICA )

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DISTRICT!OF COLUMBIA )

r DeMastry b.fing first duly sworn, deposes and says:

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That he is Manager Nuclear Licensing, of Florida Power and Company, the Licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that the is authorized to execute the document on behalf of said Licensee.

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f.A.DeMastry 7 Subscribed and sworn to before me this day of k( p* k V', ,

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} 7 o NOTARY PUBLIC.' for the District of Columbia My Corm.ission expires 'fl9' e l .' / / (j /

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i ATTACRMENT A' EDWARD J. WEINKAM III

-Work Experiences 1986 - Present Florida Power & Ligh',lompany (FPL)

Principal Engineer - Nuclear Licensing - Serves as primary FPL contact with the NRC Office of NucleTr Reactor Regulation for the St. Lucie Plan- coordinates license amendments, technical, safety anc cava.cnmental reviews to satisfy regulatory requirements arrt improve plant operational flexibility. Represents 9L on Combustion Engineering Nuclear Steam Supply Owner. Group Licensing Subcommittee.

1981 - 1986 U.) Nuclear Regulatory Commission-(NRC)

Technical Assistant - Served as technical specialist to the Assistant Director for Licensing and. subsequently to the Division Director, Westinghouse Reactors. Advised the Director and Assistant Director on technical safety matters related to the design, construction and operation of nuclear power plants.

Licensing Proj">:t Manager - Managed and coordinated environmental and safety review of application for nuclear power plant operating license, assuring compliance with rules and regulations. Served as principal staff liaison and point of contact between the NRC staff and applicants, the public, Congress, other government agencies and the media.

• Senior Reactor Engineer - Participated in the development of technica) specifications for boiling and pressurized water reactor plants.

1980 - 1981 TRACOR, Inc.

Engineer Scientist - Served as Lead Engineer for nuclear Provided support to submarine maintenance support.

Naval Sea Sys. ems command for the planning, execution and analysis of nuclear submarine extended operating cycle (SEOC).

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Edward J. Weinkam III Page Two

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1979 - 1980 University of Maryland Assistant Instructor, Mechanical Engineering Department -

Taught undergraduate engineering course.

1974 - 1979 U.S. Navy Served on nuclear attack submarine. Qualified as Engineering officer of the Watch, officer of the Deck and Command Duty officer. Served in various operations, weapons and engineering billets. Directly supervised 30 submarine sailors in shipyard and operational environments.

Memberships: Associate Member - American Society ,.

of Mechanical Engineers Associate Member - American Nuclear Society Education: 1984, M.S. Mechanical Engineering, University of Maryland l' 1974, B.S. Mechanical Engineering,  ;

University of Netre Dame .

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ATTACHMENT B RESUME KRISHNA P. SINGH, Ph.D., P.E.

CURRENT POSITION: President-HOLTEC INTERNATIONAL

• Mount Laurel, New Jersey EDUCATION: University of Pennsylvania Ph.D. in Mechanical Engineering (1972)

University of Pennsylvania M.S. in Mechanical Engineering (1969)

B.I.T. Sindri 3.S. in Mechanical Engineering (1967)

PROFESSIONAL EXPERIENCE:

1986 - present President, Holtec International Mount Laurel, New Jersey

, 1979 - 1986 Vice President of Engineering Joseph Oat Corporation Cateden, New Jersey 1974 - 1979 Chief Engineer Joseph Oat Corporation Camden. New Jersey 1971 - 1974 Principal Engineer .

Joseph Oat Corporation Camden, New Jersey 1967 - 1968 Assistant Professor of Applied Mechanics

? R.I.T. Allahabad REGISTRATIONS: Registered Professional Engineer, Pennsylvania (1974 - present)

Registered Professional Engineer, Michigan (1980 - present)

PROPESSIONAL MEMBERSHIPS : Fellow of the ASME: Member AICE, Member a

ANSI Chairman, TEMA Vibration Com.mittee (1979 - IS86): Chairman, PVP Committee of ASME, Nuclear Engineering Division.

PATENTS: "Heat Exchanger for Withstanding Cycle Changes in Temperature" (with M. Holtz and A.I. Soler), U.S. Tatent No.

4,207,944 (1980).

PATENTS (continued): "Radioactive Fuel Cell Storage Rack" (with M. Holtz), U.S. Patent No.

4,382,060 (May 1983).

t BOOKS AND ARCHIVAL VOLUMES (Luthored or edited):

1. "Mechanical Design of Heat Exchangers and Pressure Vessel Components", (with A.I. Soler), Arcturus Publishers, Cherry Hill, New Jersey, 1100 pages, hardbound (1984).

2. "Theory and Practice of Ifeat Exchanger Design", Hemisphere Publishers (c. 1987).

3. Feedwater Heater Workshop Proceedings", (with Tom Libs), EPRI-

'78-123 (1979).

4. "Feedwater Heater Technology: State-of-the-Art", EPRI-CS-4155 (1985).

5. "Planning Study for Analytical Correlations of Fluid Drag of Fuel Drag of Fuel Assemblies in Fuel Rack Storage Locations",

EPRI Project RP-2124.

6. "Thermal / Mechanical Heat Exchanger Design", ASME PVP Committee, Vol. 118 (1980).

EXPERIENCE IN SPENT FUEL RACK TECHNOLOGY:

e Developed mechanical design, participated in the seismic analysis, and led licensing of high density racks for the following plants:

Year Utility Plant Licensed Detroit Edison Company Enrico Fermi III 1980 Commonwealth Edison Company Quad Cities 1982 Sacramento Muncipal Rancho Seco 1983 Utilities District South Carolina Electric & V.C. Summer 1984 Gas Company General Public Utilitiep Oyster Creek 1984 Boston Edison Company Pilgrim 1985 Pacific Gas & Electric Diablo Canyon 1986 Commonwealth Edison Company Byron Units I & II ongoing Commonwealth Edison Company Braidwood I & II 1987 Florida Power & Light St. Lucie 1 1988 Northeast Utilities Millstone I ongoing Georgia Power Company Vogtle ongoing e One U.S. Patent on a honey comb-style high density reck.

t e Author of four technical papers in the permanent literature 7 on Spent Fuel Pool Technology.

e Provided expert witness support to the following NRC Atomic Safety Licensing Board hearings: ,

-- Dresden Unit III, Commonwealth Edison Company (1952)

-- Diablo Canyon Units 1 & 2, PG&E (1987)

PUBLICATIONS:

"A Method for Solving Ill-Posed Integral . Equations of the 1.

First Kind", (with B. Paul), Computer Methcds in Applied i Mechanics and Engineering 2, 339-348 (1973).

2. "Numerical Solutions of Non-Hertzian Elastic Contact Problems", (with B. Paul), Journal of Applied Mechanics, Vol. '

41, No. 2, 484-490 (June 1974).

3. "On the Inadequacy of Hertzian Solutions of Two-Dimensional Line Contact Problems", Journal of the Franklin Institute, Vol. 298, No. 2, 139-141 (1974).

4. "How to Locate Impingement Plates in Tubular Heat '

Exchangers", Hydrocarbon Processing, Vol. 10, 147-149 (1974).

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5. "Stress Concentration in Crowned Rollers", (with B. Paul), ,

j Journal of Engineering for Industry, Trans. ASME, Vol. 97, Series B, No. 3, 990-994 (1975).

6. "Applicatien of Spiral Wovnd Gaskets for Leak Tight Joints",97, Journal of Prersure Vessel Technology, Trans. ASME, Vol. ,

Series J, No. 1, 91-93 (1975!

7. "Contact Stresses for Multiply-connected Regions -- The case of Pitted Spheres", (with B. Paul and W.S. Woodward),

Proceedings of the IUTAM Symposium on Contact Stresses, August 1974, Holland, Delft University Press, 264-281 (1976).

8. "Design of Skirt-Mounted Supports", Hydrocarbon Processing, Vol. , 199-203 (April 1976).

9. "Predicting Plow-Induced Vibration in U-Bend Regions of Heat Exchangers -- An Engineering Solution", Journal 195-205 of the1976).

(August Franklin Institute, Vol. 302, No. 2,

10. "A Method to Design Shell-Side Pressure Drop Constrained Tubular Heat Exchangers", (with M. Holtz), Journal of Engineering for Pover, Trans. ASME, Vol. 99, No. 3, 441-448 (July 1977).

t PUBLICATIONS (continued):

11. "An Efficient Design Method for Obround Pressure Vessels and Their End Closures", International Journal of Pressure Vessel and Piping, Vol. 5, 309-320 (1977).

12. "Analysis of Vertically Mounted Through-Tube Heat Exchangers",

Journal of Engineering for Power, Trans. ASME, Vol. 100, No. 2, 380-390 (April 1978).

13. "Study of Bolted Joint Integrity and Inter-Tube-Pass Leakage Part I -- Analysis", Journal of in U-Tube Heat Exchangers: 1, 9-15 Engineering for Power, Trans. ASME, Vol 101, No.

(1979).

14. "Study of Bolted Joint Integrity and Inter-Tube-Pess Leakage in U-Tube Heat Exchangers, Part II -- Applications", Journal of Engineering for Power, Trans. ASME, Vol. 101, No. 1, 16-22 (1979).

15. "On Thermal Expansion-Induced Stresses in U-Bends Holtz), Trans.

of Shell-ASME, and-Tube Heat Exchangers", (with M. 4, 634-639 Journal of Engineering for Power, Vol. 101, No.

(October 1979).

16. "Heat Transfer Characteristics of a Generalized Divided Plow Eeat Exchanger", Proceedings of the Conference on Industrial 88-97 Energy Conserva*. ion Technology, Houston, Texas, (1979).

17. "An Approximate Analysis of Foundation Stresses in Horizontal Pressure Vessels", (with V. Luk), Paper No. 79-NE-1, Trans.

ASME, Journal of Engineering for Power, Vol. 102, No. 3, 555-557 (July 1980).

16. "Generalization of the Split Flow Heat Exchanger Geometry for Enhanced Heat Transfer", (with it. Holtz), A!Chc.

Symposium Series 189, Vol. 75, 219-226 (1979).

19. "Analysis of Temperature-Induced Stresses in the Body Bolts of Three Element Joints", ASME Winter Annual Mueting, vaper No. 79-QA/NE-7.

20. "Optimization of Two-Stage Evaporators for Minimizing Rad-waste Entrainment", (with M. Holtz), Journal of Mechanical Design, Trans. A3ME, Vol. 102, No. 4, 804-806 (1980).

21. "A Comparison of Thermal Performance of Two and Four Tube Pass Designs for Split Flow Shells", (with M. Holtz), Journal of Heat Transfer, Trans. ASME, Vol. 103, No. 1, 169-172 (February 1981).

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PUBLICATIONS (continued):

22. "A Method fer Maximizing Support Leg Stress in a Pressure Vessel l'ounted on Four Legs Subject to Moment and Lateral Loadings", International Journal of Pressure Vessels and Piping, Vol. 9, No. 1, 11-25 (1981).

23. "Design, Stress Analysis and Operating Experience in Feedwater Heaters", '(with T. Libs), Proceedings of the Conference on Industrial Energy Conservation Technology, Houston, Texas, 113-118 (1980).

24. "On the Necessary Criteria for Stream Symmetric Tubular Heat Exchanger Geometries", Heat Transfer Engineering, Vol.

3, No. 1, (1981).

25. "Some Fundamental Relationships for Tubular Heat Exchanger Thermal' Performance", Trans. ASME, Journal of Heat Trt.nsfer, Vol. 103, 573-578 (1981).

26. "Transient Swelling of Liquid Level During Pool Boiling in an Emergency Condenser", (with J.P. Gupta), Letters in Heat and Mass Transfer, Vol. 8, No. 1, 25-33, (January / February 1981).

27. "An Approximate Method for Evaluating the Temperature Field in Tubesheet Ligaments Under Steady-State Conditions", (with M. Holtz), Journal of Engineering for Power, Trans. ASME, Vol. 104, 895-900 (1982).

28. "Feasibility Study of a Multi-Purpose Computer Program to Optimize Power Cycles for Operative Plants", (with Y.

Menuchin and N. Hirota), Proceedings of the Conference on

?.ndustrial Energy Conservation Technology, Houston, Texas (1981).

29. "Design Parameters Affecting Bolt Load in Ring Type Gasketed Joints", (with A.I. Soler), Trans. ASME, Journal of Pressure vessel Technology, Vol. 105, 11-13 (1983).

30. "A Design Concept for Minimizing Tubesheet Stress and Tubejoint Load in Fixed Tubesheet Exchangers", (with A.

I. Soler), Trans. ASME (c. 1982).

31. "Dynamic Coupling in a closely-Spaced Two-Body System Vibrating in Liquid Medium: The Case of Fuel Racks", (with A.I. Soler), Proceedings of the Third International Conference on "Vibration in Nuclear Plants", Keswick, England, 815-834 (May 1982).

32. "Effect of Nonuniform Inlet Air Flow on Air-Cooled Heat Exchanger Performance", (with A.I. Soler and Lee Ng),

Proceedings of the Joint ASME-JSME Heat Transfer Conference, 537-542 (1983).

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PUBLICATIONS (continued):

33. "Seismic Response of Free-Standing Fuel Rack Constructions to 3-D Motions", (with A.I. Soler), Nuclear Engineering and Design, Vol. 80, 315-329 (1984).

34. "A Method for Computing Maximum Water Terperature in.a Fuel Pool Containing Spent Nuclear Fuel", Nuclear Technology, American Nuclear Society (c. 1984).

"On Minimization of Radwaste Carry-Over in a N-Stage 35.

Evaporator", (with M. Holtz and V. Luk), Heat Transfer Engineering, Vol. 5, No. 1-1, 68-73 (1984).

36. "Feedwater Heater Procurement Guidelines -- Some New Performance Criteria", Symposium on State-of-the-Art Feedwater Heater Technology, EPRI (c. 1984).

37. "Method for Quantifying Heat Duty Derating due to Inter-Pass Leakage in Bolted Flat Cover Heat Exchangers", Heat Transfer Engineering, Vol. 4, No. 3-4, 19-23 (1963).

38. "On Some Performance Parameters for Closed Feedwater Heaters, Proceedings of PVP Conference, ASME (c. 1985).

39. "A Design Procedure for Evaluating the Tube Axial Load Due to Thermal Effects in Multi-Pass Fixed Tubesheet Heat Exchangers", (vith A.I. Soler), Journal of Pressure Vessel Technology, Trans. ASME (c. 1986).

40. "An Elastic-Plastic Analysis of the Integral Tubesheet in O-Tube Heat Exchangers -- Towards an ASME Code-Oriented Approach", Proceedings of PVP Conference, ASME fe. 1985).

, 41. "Feedwater Heaters", invited paper, Proceef.ings of the Joint NSF-ASI Conference, Poona, India (c. 1986).

42. "Surface condensers", invited paper, Proceedings of the Joint NSF-ASI Conference, Poona, India (c. 1986).

43. "Flow-Induced Vibration", invited paper, Proceedings of the Joint NSF-ASI Conference, Poona, India (c. 1966).

44, "Mechanical Design of Heat Exchangers", invited paper, Proceedings of the Joint NSF-ASI Conference, Poona, India i

(c. 1986).

45. "A Rational Method for Analyzing Expansion Joints",

(with A.I. Soler), ASME, Journal of Pressure Vessel Technology (c. 1988).

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PUBLICATIONS (continued):

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.46. An Analysis of the '.mprovement in the Thermal Performance L of Surface Condenser Equipped with Tweener Supports", ASME  ;

Joint Power Genera'; ion Conf ertAce, Miami, Florida  ;

(October 1987).

47. " A Generalized S'>cnt Fuel Pool Model", (with V. Maciunas),

Heat Transfer Ergineering (c. 1988).

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ATTACHf!ENT C BASjig STANLEY _.EdUR_ti.fL_PB D.

CURRENT POSITION:

Chief Scientist Holtec International Mount Laurel, New Jersey B.S. In Chemistry EDUCATION: University of South Carolina, 1945 Ph.D. in Nuclear Chemi,stry University of Texas, 2.951 PROFESSIONAL Holtec International EXPERIENCE: Chief Scientist, 1987 - Pr_esent Dr. Turner is respons!.ble for all scientific projects, !.ncluding the criticality safety analysis of new and spent fuel storage racks, preparation and evaluation of Bornflex surveillance coupons, planning and evaluation of experimental Boraflex irradiation programs, shielding eniculations, radiological impact assessments and other projects of a scientific nature.

' Seuthern Science Office of Black &

Veatch, Engineers - Architects E12 ject Ma n a ce r / Cons ul_t a n t (1977-19971 Dr. Turner was responsible for a wide range of scientific projects, including radiological monitoring systems, assessment of alternate nuclear fuel cycles, combustible gas generation and control, reactor physics analyses, and safety evaluations.

Professional Experienced Continued:

Dr. Turner was involved in the design, evaluation and licensing of high density spent fuel storage racks, including both criticality analyses and assessment of Additionally, radiological consequences. '

he evaluated the core physics performance and isotope production rates of research, test, training, production, and power reactors. As Project Manager for several U.S. Arms Control and Disarmament Agency programs, Dr. Turner investigated possible modifications to reactors for improved fuel utilization and evaluated advance Ph*R reactor concepts, involving extended fuel burnup, increased core regionalization and alternate methods of reactivity control.

NUS Corporation Senior Consultant (1973-19771 Dr. Turner was Project Manager on numerous assignments. Among them were the assessment of post-LOCA hydrogen generation, and methods of control and developnent of specialized radiological 1

monitoring systems: a servey of European l nuclear fuel cycle plans and capabi-lities; generic review of public issues in the natien's nuclear power program; investigation of Halon-1301 for fire control and ir.hlbition of hydrogen ,

burnir.;; a study of radiolytic decomposition of Halon; and a survey of U.S. nuclear plant practice for foreign clients. His other work dealt with such activities as analytical physics support, evaluation of catalyst performance, and fission gas release and inventory calculations.

Professional Experience Continued:

Southern Nuclear Engineering, Inc.

y_i_c_e President. Phyiles (1964-19711 During his association with this company, Dr. Turner managed and participated in a number of projects which involved assessing tritium production and control methods; performing calculations of heavy isotope productions reviewing licensing documents; preparing operating procedures performing safety assessment of large, special purpose reactors; evaluating consequences of industrial 1 sabotage in nuclear power plants; assessing reactors for maritime application; and evaluating fuel cycle economics.

General Nuclear Engineering SardnLJJta ctor Phys i ci_s t (1957-1964)

Dr. Turner performed or directed most of the fuel cycle cort evaluations, heavy isotope analysis, and fuel managementHe work performed by this company.

planned and ccordinated various experinents and testing programs, and managed research and development activities relatedIntoaddition, advancedhenuclear fuel elements.

participated in plant licensing actions and safety reviews, and served as a member of the Safety Committee for an operating nuclear power plant.

Mobil Hesearch Laboratory Seconyist Ehysic (1957--19571 Dr. Turner performed research in radiological methods for oil exploration, including radiation measurements and field tests. l i

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3 Professional Experienced Continued:

U.S. Navy Radiological Defense Laboratory Physicist (1951-19521 Dr. Turner performed research in the consequences and r.ethods of defending against nuclear bomb detonations, including field tests and radiological measurements.

BONORARY SOCIETIES: Sigma Pi Sigma, Phi Lambda Epsilon, Blue Key, Sigma Xi PPOTESSIONAL ATTILIATIONS: Dr. Turner is a member of the ANS Standards Committee 8.17 on Nuclear Criticality Safety, and Chairman of ANS 5.3 and 5.4 Working Groups on Tission Product Release. He was formerly a member of the ANS 5 Co ..ittee on Decay Heat and contributed to the formulation of the standard on fission product decay heat.

Registered Professional Nuclear Engineer Florida, No. 22862 i

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!:X hEiiT UWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '88 NOV 14 P3 :00 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD gg.y ,

00CKlii iG '. ':( ~ViCl b R M t. -

)

In the Matter of )

Docket No. 50-335 OLA I

FLORIDA POWER AND LIGHT COMPANY )

)

(St. Lucie Plant, Unit No. 1) ) ASL"5 No. 88-560-01-LA

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of Licensee's Supplemental Response to Intervenor's First Set of Interrogatories to Licensee, dated November 9: 1988, were served on the following by deposit '

in the United States mail, first class, postage prepaid and properly addressed, on the date shown below: ,

?

B. Paul Cotter, Jr., Chairman '

Atomic Safety and Licensing Board Panel ,

U.S. Nuclear Regulatory Commission  ;

Washington, D.C. 20555 l Glenn O. Bright ,

Atomic Safety and Licensing Board Panel i U.S. Nuclear Regulatory Commission t

' Washington, D.C. 20555  !

Dr. Richard F. Cole '

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission r Washington, J.C. 20555 1

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E Adjudicatory File .

Atomic Safety and Licensing Board Panel i U.S. Nuclear Regulatory Commission  !

Washington, D.C. 20555 l (Two copies) l t

Secretary U.S. Nuclear-Regulatory Commission .

Washington, D.C. 20555  !

Attention: Chief, Docteting and Service Section f (Original pies two copies) f Benjamin H. Vogler, Esq. k Office of General Counsel U.S. Nuclear Regulatory Commission  ;

Washington, D.C. 20555 f

Campbell Rich

• 4f26 S.E. Pilot Avenue Stuart, Florida 34997 Dated this 10th day of November, 1988.

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-- - -g hae A. Bauser Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, D.C. 20036 Telephone (202) 955-6669 Counsel for Florida Power & Light Company

• Also served by Fedexal Express.

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