ML20245F789
| ML20245F789 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/07/1989 |
| From: | Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| To: | FLORIDA POWER & LIGHT CO. |
| References | |
| CON-#389-9026 OLA-4, NUDOCS 8908150072 | |
| Download: ML20245F789 (7) | |
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~89 Al]G 10 P4 :20-UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMM2SSION iF.k.C.
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v BEFORE THE ATOMIC SAFETY AND LICENSING FOARD In-the Matter of
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Docket nos. 50-250 OLt 4 Florida. Power'& Light Company
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50-251 OL4-4
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Turkey Point Plant, Units 3 & 4
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( P/T LIMITS)
' INTERVENERS' FIRST SET OF DISCOVERY REQUESTS TO LICENSEE L
Interveners, the Cer.ter for Nuclear Responsibility.and Joette Lorion, hereby serve their First Set of Discovery Requests to Licensee Florida Power & Light Company, pursuant to 10 C.F.R.
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2.740 (b) and 2.741.
Each interrogatory hezein is to be answered fully, in writing,'and under oath or affirmation within 14 days after service.
Each answer should clearly indicate the interrogatory to which it is intended to be responsive.
If Licensee after exercising due dilligence, cannot answer any portion of the inter'rogatories in full, Licensee shall answer the interrogatories to the extent possible, shall explain in detail the inability of Licensee to answer the remainder of the interrogatories and shall state when Licensee expects to be able to answer any unanswered portions.
PDR 3
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A.
INTERROGATORIES AND DOCUMENTS SPECIFIC TO CONTENTION 3 :
- 1. Identify the facts and documents that Licensee relies upon alleging that.26 is the proper and conservative percentage of copper to use in calculating the RTNDT for use in revising the P/T limits for Turkey Point units 3 and 4.
2.
Provide copies of any and all historical or other documents that prove that the copper content of the limiting welds is 0.26%.
3.
State whether the 0.26% copper content is the mean value and explain whether or not Li.censee factored in a standard I
deviation when calculating the percentage of copper.
4.
If the answer to interrogatory no. 3 is no, provide the reason and/or justification for not applying a standard deviation.
5.
Provide the reasons and! or justifications for the Licensee's use of 0.31% of copper in calulating RTNDT and setting the P/T limits for the first 10 years of operation and explain how Licensee can justify the use of 0.26% copper in setting the P/T limits for 20 years rather than the 0.31% copper content.
6.
State whether Licensee agrees that the use of 0.31% copper rather than 0.26% copper in calculating RTNDT and revising P/T limits for units 3 and 4 would result in the P/T limits l
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(3) being more conservative and/or restrictive.
If Licensee dis.grees state the basis for your disagreement.
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State whether Licensee or the NRC Staff attempted to calculate RTNDT and revise the P/T limits using a 0.28 or above copper content.
If any such calculations were performed, please provide copies of documents containing such calculations.
8.
State whether Licensee agrees that a reduction in the percentage of copper content could result in an increase of EFPY.
- 9. Copies of any and all calculation of RTNDT for Turkey Point Units 3 and 4 for revision of the P/T limits as set out by Regulatory Guide 1.99, Revision 2.
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B. INTERROGATORIES AND DOCUMENTS SPECIFIC TO CONTENTION 2:
- 1. Documents that provide information concerning the respective design, fluence, and operating histories for Turkey Point Units 3 and 4, including but not limited to documents that provide information on the following:
a) weld wire heat number and flux lot for the welds and surveillance test capsules; b) operating procedures; c) EFPY; d) loading history; e) accumulated neutron spectra, flux a.nd fluence; f) cycle lengths; g) capacity factor; h) fuel management.
- 2. Copies of any and all documents that Licensee has supplied to the NRC since 1985 as required by 10 CFR Appendix H,Section II C, Parts 1-6.
- 3. State whther Licensee has a contingency plan as required by 1
Appendix H to assure that the surveillance program for each j
reactor will not be jeopardized by operation at a reduced power level or by an extended outage of another reactor from which data are expected.
If yes, provide a copy of the plan and/or any documents provided to the NRC as a result of such
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( 5) i outage.
If the answer is no, state why no such plan exists.
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4.
State whether Licensee believes that the Charpy weld metal j
test results for capsule T of Unit 4 agreed with the original embrittlement predictions for that reactor unit.
- 5. State whether TP Units 3 and 4 have had equivalent core loadings since 1985 and provide documents that support your response.
6.
State whether the neutron spectra profiles for Turkey Point Units 3 and 4 are and have beenequivalent and provide documents that support your response.
7.
Provide documents that show the prediction of radiation damage as a function of power output for both Turkey Point Units 3 a"nd 4,
- 8. State whether Licensee conducts in cavity dosimetry testing for units 3 and 4 in order to reduce uncertainties in projected neutron fluence.
If the answer is yes, provide the results of tests for TP 3 and 4.
If the answer is no, explain why no such tests are conducted.
9.
State whether in cavity dosimetry testing was ever incorporated into the integrated surveillance program for Units 3 and 4.
10.
State whether Licensee agrees with the NRC Staff statement on page o of the Safety Evaluation for the P/T amendments
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(6) that flux lot number is only of minor importance in determining the sensitivity of irradiation embrittlement.
State the basis ar.d or justification for Licensee's agreement or disagreement.
- 11. Provide Licensee's basis and justification for their assertion that the operating features of Turkey Point Units 3 and.
4 are sufficiently similar to predict accurate comparisons of the predicted amount of radiation damage as a function of total power output.
Name the documents that support this position.
- 12. Provide copies of any and all documents in which a 30 ft-lb charpy energy level rather than a 42 ft-lb level were used to calculate RTNDT based on Unit 4 casula T surveillance data.
Respectfully submitted, I
GDUSL & O.N %
Joette Lorion Director, Center for Nuclear
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Responsibility Dated: August 7, 1989
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UNITED STATES OF AMERICA.
NUCLEAR REGULATORY COMMISSION
'89 AUG 10 P4 :20 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OF8 t.
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In the Matter of
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P P t.ht" Docket Nos. 50-250 OLA FLORIDA POWER & LIGHT CO.
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50-251 OLA
' Turkey Point Plant
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Units 3 and 4
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(Pressure / Temperature Amendments)
CERTIFICATE OF SERVICE Interveners hereby certify that copies of " Interveners' First Set of Discovery Requests to Licensee"were served on the following parties by deposit in the U.S. mail, first class, postage prepaid on August 7, 1989:
Dr. Paul Cotter John T.
Butler Atcmin Safety & Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washingten, D.C.
20555 Miami, Florida 33131 Glenn O. Bright Steven P.
Frantz Atcmic Safety & Licensing Board Newman & Holt:inger P.C.
U.S. Nuclear Regulatory Commission 1615 L.
Street NW Washington, D.C.
20555 Suite 1000 Washington, DC 20036 Jerry Harbour Atcmic Safety & Licensing Board U.S. Nuclear Regulatory Commission WashiN con, D.C.
20555 Office of Secretary U.S. Nucleer Regulatory Commission Washington, D.C.
20555 Janice Moore g
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Office of General Counsel Joette Lorion U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Director, Center for Nuclear Responsibility 7210 Red Road #217 Miami, Florida 33143 (305) 661-2165
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