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Intervenors Responses to Licensee First Set of Discovery Requests to Ctr for Nuclear Responsibility & J Lorion.* Certificate of Svc Encl.Related Correspondence
	ML20245F811
Person / Time
Site:	Turkey Point
Issue date:	08/08/1989
From:	Lorion J; CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:	; FLORIDA POWER & LIGHT CO.
References
	CON-#389-9027 OLA-4, NUDOCS 8908150083
	Download: ML20245F811 (9)
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t UUnc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket Nos. 50-250 OLA-4 50-251 OM-4 Florida Power & Light Company

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Turkey Point Plant Units 3 & 4

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(Pressure / Temperature Limits)

INTERVENERS' RESPONSES TO LICENSEE'S FIRST SET OF DISCOVERY REQUESTS TO THE CENTER FOR NUCLEAR RESPONSIBILITY AND JOETTE LORION Interveners, the Center for Nuclear Responsibility and Joette Lorion, hereby provide their responses to Licensee's First Set of Discovery Requests:

Resoonse to I.A:

At this time, Interveners have not retained an expert witness.

Interveners will supplement this response if such a witness is retained.

Response to I.B:

N/A. See I.A.

Response to I.C:

N/A. See I.A.

Respon.se to I.D:

See Attatchment A.

Response to I.E:

See Attatchment A.

Attatchment A will be amended should Interveners discover additional documents that could be used for cross examination.

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1 Response to I.F:

At this time, the documents Interveners believe are deficient are the Licensee's Amendment Request and the NRC Staff's Safety Evaluation regarding the Amendment Request.

Interveners believe that any and all portions of there documents that rely on a.26 copper content to calculate RTHCT and revise the P/T limits are deficient.

Interveners also believe that any portions of there documents that allow Unit 3 data to be used to calculate RTNDT and revise the P/?

limits for Unit 4 are incorrect and deficient.

At this time, Interveners have not retained an expert witness to support their views.

Interveners intend to use the documents listed in attatchment A to provide support for their claim that these documents are deficient.

Restense t; II A.

1:

Interveners base their assertion on the fact taa: :ne Turxey point Units 3 &- 4 have different operating his:Ories, which includes a difference in extended outages, and the fact that Licensee entered into the Integrated Program despite the fact that initial test results for Unit 4 did not agree with predictions for that Unit, in that Unit 4's Capsule T showed a greater fegree Of embrittlement than the mean embrittlement that was pr:fected.

Restense t: ::. A ::

10 C.F.R. Part 50, Appendi:c H,Section II I.

, Append n H,Section II 3.,

Appendix G,Section V.3.,

Appendix G, Secti0n II F.

Res=ense t:

.A. 3:

The units have different operational his:Ortes.

For example, Unit 4 suffered from an overpressurization even while Uni: 3 did not.

Also, in 1987, Unit 3 operated a: 14; caract:7, whi' e Uni: 4 operated at 45% capacity fac Or.

Restense ti ::.A. 4:

5ee response to no. II.A.

3.

t Restonse t II. A. 5: Interveners agree that the design features of corn units appear to be similar at this time.

Interveners de net agree that the units have similar operational features.

The basis fer this belief is stated in response to nos. II.A. 1 and II.

A.

3.

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Response to II. A.

6:

Yes.. One example of an. extended. outage L

that could have affecred the validity of the Integrated Surveillance program is the. great difference in capacity factors between the units in 1987 as identified in response to II. A. 3.

Response to II.A. 7:

At the time Interveners prepared their Petition for Leave to Intervene, they did not have the NRC Staff's SER and they were under the impression that only Unit 3 data.had been used to set the revised, pressure / temperature limits.

Interveners agree that both the Licensee and Staff contend that both Unit 3 and Unit 4 test data have been combined to set the new limits.

Resoonse to II.

A.

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The basis of this statement is the NRC Staff's Safety Evaluation and the parts of.10 C.F.R. Appendix G

- and H identified in response to II. A.

2.

Sea also, Appendix G paragraphs V.A. and V.B,, Licensee's Response to Petitioners' Request for Hearing, page 2, License Amendment Nos. 134 and 128 dated January 10, 19 89, page B.3.1-2 (a), the NRC Staff's Safety Evaluation of Amendments 134 and 128, pages 2 and 3.

See also Response II.A.8.

Resconse to II.B. 3:

See response to II.B.l. Interveners believe 0.31% copper should be used.

Restonse to II.B. 4:

Interveners do not have sufficient information a:

nis time to eitner confirm or deny this statement.

Res=onse to II.3. 5:

See response to II.B.l.

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tesconse to II.B.6:

Interveners do not have a copy of the transcript.

Interveners believe that the document mentioned is f

correctly titled BABCOCK and WILCOX 177-FA REACTOR VESSEL BELTLINE WELD METAL CHEMISTRY STUDY, BAW 1799, July 19t,3.

Should Licensee be unable to locate this document, Interveners will provide a copy on request.

Respectfully submitted, IM O' N Jeette Lorion Director, Center for Nuclear Responsibility (305) 661-2165 Dated: August 8, 1989 STATE OF FLORIDA COUNTY OF DADE Before me the undersigned authority, personally appeared, JCETTE LORION, who after being duly sworn deposes and says that the foregoing RESPONSES TO LICENSEE'S FIRST SET OF DISCOVERY REQUESTS TO THE CENTER FOR NUCLEAR RESPONSIBILITY AND JOETTE LORION prpopounded on the

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day of g u.-cc.T

, 1989, are true and correct to the best of her knowledge"and ability, and that she has read the RESPONSES and knows the content thereof.

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' NOTARY PUBLIC', S tate '

of Florida at Large MY COMMMISSION EXPIRES:

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ATTATCHMENT A I

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1. Document entitled tressure-Temperature Limitations for the i

Turkey Point Unit 's

6. 4 and Power Plants, bouthwest Research j

Institute June 30, 1976.

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2. Document entitled Analysis of Capsule T from the FPL Turkey Point Reactor Vessel Radiation Surveillance Program, Westinghouse Electric Corporation, December 1975.

3. Reactor Vessel Material Surveillance Program for Turkey Point Unit No. 4 Analysis of Capsule T, Southwest Research Institute, June 14, 49/0.

4.

Document entitled Reactor Vessel Material Surveillance Program Capsule S for-Units 3 and 4, May 1979.

Southwest Research Institute,

5. Document entitled Unit 4 Reactor Vessel Radiation Surveillance Program, WCAP 766U, MAy 1971.

6. PNL Technical Review of Pressurized Thermal Shock Issues, NUREG/ CR RRRZd3/, PNL 434/, July 196Z and bupplement 1,

May 1963.

7. NRC Staff Evaluation of Pressurized Thermal Shock SECY-82-465 dated November 23, 1982.

8. Letter to NRC from W.F.

Conway, FPL, re: Proposed License Amendments for P/T Limits with attachments dated September 21, 1988.

9. Letter to W.F. Conway, FPL from Gordon Edison, NRC, Re: License Amendment nos. 134 and 124 and attatched Safety Evaluation dated January 10, 1989.

10. Revision 2 to Regulatory Guide 1.99.

~~ 11. Letter to C.O. Woody, FPL from Daniel Mcdonald, NRC, Re:

Projected Values of Fracture Toughness Requirements for Protection Against PTS Events-Turkey Point Plants Units 3 an'd 4 with attatched Safety Evaluation dated March 11, 1987.

12. Letter to C.O. Woody, FPL, from Dan Mcdonald, NRC, Re: Reactor Vessel Surveillance Program Analysis of Capsule V dated October 30, 1987.

11. Letter to W.F.

Conway, FPL, from Gordon Edison, NRC, re:

Turkey Point Units 3 and 4 Reactor Vessel Toughness, dated May 31, 1988.

14. Letter to W.F.

Conway, FPL, from Gordon Edison, NRC,re:

Reactor Vessel Surveillance Program Analysis of Capsule V Dated May 25, 1968.

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L 14.ELetter from Steve Franz, FPL,.to the ASLB, with attacched Declaration of Pryor:N. Randall dated December 2, 1985.

15. Letter to Rules and Procedures Branch, NRC, from L..

L Butterfield, Westinghouse Owner's Group, RE: Comments on Draft' Regulatory Guide 1.99, Revision 2 dated

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September ~16, 1986.

16. Letter.from L.D.

Butterfield, Westinghouse Owner's Group, to Rules &LProcedures Branch, NRC, re: Co'nme n t on Regulatory Guide 1.99, Revision 2 dated May 15, 1986.

17. Letter to'J.W. Williams, FPL, from Steven Varga, NRC, re:

Near Term Flux Reduction Program dated February 27, 1985, with enclosures.

18. Letter to J.W. Williams, FPL, from Daniel G. Mcdonald, NRC, re: Amendment nos. 102 and 106 with Safety Evaluation, dated

' April 22, 1985.

19. Letter from J.W. Williams, FPL, to Darrell G. Eisenhut, re:

Request to Change Capsule Schedule, dated February 8, 1985.

20. Letter from Dr.-George Sih, Director of Fracture Mechanics Lehigh Unive,rsity, Re: Expert Opinion Turkey Point Nuclear Power ~ Plant Unit 4 Embrittlement, dated October 10, 1985.

21. Letter to NRC Commissioners from Demetrios Basdekas, NRC Engineer, r'e: Final PTS Rules and Related Unresolved Safety Issues, dated March 6, 1985.

21. Letter to J.W. Williams, FPL, from Steven A. Varga, NRC, re: Evaluation of Reactor 7essel Materials Data from TP Units 3 and 4 Reactor Vessels and attacched Safety Evaluation dated April 26, 1984.

22. Letter to Robert Uhrig, FPL, from Steven Varga, NRC, re:

re: FTS and Flux Reduction, dated February 1, 1983.

23. Letter to Darrel Eisenhut, NRC, from Robert Uhrig, FPL, re: Pressure Vessel Material Fracture Toughness, dated February 3,~1983.

24. Letter to Darrel Eisenhut, NRC, from Robert Uhrig, FPL, re: Turkey Point Unit 4 150 day Response to PTS, dated January 21, 1982.

25. Letter to Commissioners Gilinsky and Ahearne$2-465, from Demetrios Basdekas, NRC, re: Staff Report on PTS SECY November 23, 1982.

26. Memo to NRC Chairman Palladino, from William Dirks, Director of Operations. NRC, re: Differing Professional Opinion of Basdekas on Pressurized Thermal Shock, dated October 8, 1981.

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( 3T l27. Letter to Morris K. Udall, House of Representatives, from Demetrios Basdekas,-NRC, dated April 10, 1981, re: Pressurized Thermal Shock.

28. Westinghouse Summary Report on Reactor Vessel Integrity,

.WCAP 10019 by T.A. Meyer, dated December 1981.

29.. Letter toiDarrel Eisenhut, NRC, from Robert E. Ulirig, FPL, L

re: Attatchment-correction, dated October-23, 1981.

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30. Letter from, Robert E.

Uhrig, FPL, to Darrel Eisenhut

NRC, re:'FPL Response to Eisenhut. letter under 10 C.F.R. $0.54, dated October 23, 1981.

31. Letter to Robert Uhrig, FPL, from Darrel Eisenhut,.NRC, re: 10.54 3etter on Pressurized Thermal Shock to Reactor

. Vessels, dated August. 21, 1981.

32. Letter to-George Lear, NRC, from Robert Uhrig, FPL,-re:

Reactor Vessel Materia 1'Information, dated October 21, 1977.

33. Letter to Edson Case, NRC, from Robert Uhrig, FPL, re:

-Reactor Vessel Surveillance Capsules, dated September 14,.1977.

34. Letter to George Lear, NRC, from Robert Uhrig, FPL, re:

Fracture Toughness Requirements and attachments, dated April-11, 1977.

35. Babcock and Wilcox 177-FA Reactor Vessel Beltline Weld Chemistry Study, BAW 1799, July 1983.

36. Technical Specifications for Pressure / Temperature Limits for the first 10 years of operation at Turkey Point, including but not limited to 3/4 4-32 through 3/4 4-38.

37. American Society of Mechanical Engineers, " Standard Practice for Conducting Surveillance Tests f6r Light-Water Cooled Nuclear Power Reactor Vessels, " ASTM E 185-82, July 1982.

38. Westinghouse Electric Corporation Report entitled " Reactor Vessel Heatup and Cooldown Limit Curves for Normal Operation" dated May 1988.

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UNITED STATES OF AMERICA Nr NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA'aB ME 10 P4 :20 In the Matter of

)

,. g g, Docket Nos. 50J2$fdLO "

FLORIDA POWER & LIGHT CO.

50-251 6LA

)

Turkey Point Plant

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(Pressure / Temperature Amendments)

Units 3 and 4

)

CERTIFICATE OF SERVICE.

I hereby certify that copies of " Interveners' Responses to Licensee's First Set of Discovery Requests to the Cer.ter for Nuclear Responsibility and Joette Lorion" have been served on the following parties by deposit in the U.S. mail, first class, postage prepaid on the date shown below:

Dr. Paul Cotter John T. Butler Atomic Safety & Licensing Board Steel, Hector & Davis U.S. Nuclear Regulatory Commission 4000 SE Financial Center Washington, D.C.

20555 Miami, Florida 33131 Glenn O.

Bright Steven P.

Erant:

Atomic Safety & Licensing Board Newman & Holtzinger P.C.

U.S. Nuclear Regulatory Commission 1615 L.

Street NW Washington, D.C.

20555

. Suite 1000 Washington, DC 20036 Jerry Harbour Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Office of Secretary j

U.S. Nuclear Regulatory Commission Washington, D.C.

20555

g [

g Janice Moore Office of General Counsel l

Joette Lorion U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Director, Center for Nuclear Responsibility 7210 Red Road #217 i

Miami, Florida 33143 Date: August 8, 1989 (305) 661-2165

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ML20245F811

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