ML20245J602
| ML20245J602 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/21/1989 |
| From: | Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| References | |
| CON-#389-8822 OLA-4, NUDOCS 8907030105 | |
| Download: ML20245J602 (10) | |
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UNITED STATES OF-AMERICA 19 JUN 26 P4 :08 2
NU',.4AR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
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In the Matter of
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Docket Nos. 50-250 OLA - 4 FLORIDA POWER & LIGHT COMPANY
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'50-251 OLA - 4'
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i (Turkey Point Plant,
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(P/T Limits)
Units 3 and 4)
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I LICENSEE'S FIRST SET OF DISCOVERY REQUESTS TO THE CENTER FOR NUCLEAR RESPONSIBILITY AND JOETTE LORION i
Florida Power & Light Company (" Licensee" or "FPL")
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l hereby serves its First Set of Discovery Requests to the Center for Nuclear Responsibility and Joette Lorion (" Interveners")
I pursuant to 10 C.F.R. S 2.740b and S 2.741.
i Each interrogatory herein is to be answered fully, in writing, and under oath or affirmation within 14' days.after
-l service.
Each answer should clearly indicate the interrogatory j
to which it is intended to be responsive.
If Interveners after exercising due dilicence,-cannot answer any portion of any of the i
interrogatories i, full, Interveners shall so state, shall answer i
the interrogatories to the extent possible, shall explain in-detail the inability of the Interveners to answer the remainder-j i
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8907030105 890621 PDR ADOCK 05000250 G
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of the interrogatories, and shall state when Interveners expect I
l to be able to answer any unanswered portions.
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The discovery requests are divided into two sections.
l Section I consists of general interrogatories which should be answered for each and every contention admitted by the Board in this proceeding.
Section II consists of interrogatories and document requests that are specific to a particular contention.
j l
I.
GENERAL INTERROGATORIES (to be answered for each and every admitted contention):
A.
State whether Interveners intend to call any person or persons as witnesses, including expert witnesses, in this proceeding in support of each contention and, if so, identify any and all such persons giving the name, address and professional qualifications of each.
B.
Provide summaries of the views, positions, or proposed testimony on each contention of all p0rsons identified in response to interrogatory I.A.
that Interveners intend to present during this proceeding.
C.
Identify all documents, books, reports, papers, studies, analyses and calculations that Interveners intend to employ or rely upon in presenting their direct case on each I
contention.
D.
Identify all documents, books, reports, papers, studies, analyses and calculations that Interveners intend to employ or rely upon in conducting cross examination of the NRC l
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l Staff and/or Licensee witnesses testifying in connection with l
each contention.
1 E.
Identify any and all documents, books, reports, papers, J
studies, analyses, calculations, or expert opinions which i
Interveners claim provide support for each contention.
F.
Identify the relevant documents, books, reports, papers, studies, analyses or calculations prepared by the Licensee or NRC Staff which Interveners contend are deficient, and identify any particular portions thereof Interveners regard as deficient; explain the manner in which they are deficient; and identify all documents, books, reports, papers, studies, analyses, calculations or expert opinions relied upon by Interveners that provide support for Interveners' claim that a deficiency exists.
II.
SPECIFIC INTERROGATORIES AND DOCUMENT REQUESTS:
A.
Admitted Contention 2:
1.
Identify the basis for Interveners' assertion (as interpreted by the Licensing Board, Memorandum and Order (June 8, 1989), p. 17) that the Licensee's conduct of the integrated surveillance test program at Turkey Point fails to meet the requirements of the program itself.
2.
Identify the specific portions of 10 CFR Part 50 Appendices G and H which support Interveners' claim that the Licensee's conduct of the integrated surveillance test program is improper.
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3.
Identify the basis.for Intervenor's assertion (as:
interpreted by the Licensing Board,fMemorandum and Order (June 8, 1989), pp. 17-18) that.the operating history of Turkey Point Units'3 and 4 are significantly different'for purposes of the integrated surveillance test program.
4.
Identify the basis for Interveners' assertion (as interpreted by the Licensing Board Memorandum and Order-(June 8, 1989), pp. 17-18) that the Unit 3 capsule material has been; irradiated for a significantly shorter pe-od of time than the capsule material in Unit 4-.
5.
Do you agree that the design and operating features of the Turkey Point Units 3 and 4 reactors are, and have been, similar?
If not, please provide the basis for your answer.
6.
Are you contending that Turkey Point Unit 3 and/or Turkey Point Unit 4 have experienced periods of operation at reduced power levels and/or extended outages.of sufficient-extent since April 22, 1985, to affect the. validity of.the integrated surveillance test program for these units.
If yes, please specifically identify each such period (by unit, dates, and cause of outage or reduced power operation) and the bases for your contention that an outage or reduced power operation of either unit affected the validity of the integrated surveillance test program.
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l 7.
Identify the basis for the statement in the Bases
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for Contention 2 that FPL " chose only to use capsule V test data" from Turkey Point Unit 3 in predicting RTNDT and s
revising the heat-up and cooldown limits.
Do you agree that FPL used test data from both Turkey Point Unit 3 and Unit 4 i
1 in predicting RTNDT and revising these curves?
If not, l
l identify the basis for your disagreement.
8.
Identify the basis for your statement (Transcript
)
pages 64-65) that FPL "must, according to their own regulations, use the most limiting RTNDT."
Identify specifically the " regulations" to which you referred.
9.
Identify the basis for the statement in l
I contention 2 that using surveillance capsules from Turkey
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for Unit 4 "is not Point Unit 3 to help predict the RTNDT scientific, not valid."
Furthermore, identify all
)
documents, books, reports, papers, studies, analyses, 1
calculations, or other scientific data which Interveners intend to rely on in support of this assertion.
10.
Identify the basis for the statement in Contention 2 that the Turkey Point integrated surveillance program does not meet the criteria in 10 CFR Part 50 Appendices G and H.
11.
Please provide a copy of the Southwest Research Institute report on the Reactor VessS1 Material Surveillance.
I
1
.q 4 1 Program for Turkey Point Units 3 and 4, dated May 1979, referenced in the bases for Contention 2.
12.
Please provide copies of the following documents referenced by Interveners at the March 21, 1989,. pre-hearing conference in connection with Contention 2.
(a)
Southwest Research Institute Report, August 1986.
(Transcript, page-30)
(b)
" Analysis of Capsule T from FPL Turkey Point
]
Number 3 Reactor Vessel Surveillance Program,' December, 1985," Westinghouse Electric Corp.
(Transcript, pages
)
69-70) 1 (c)
" Reactor Vessel Material Surveillance Program-1 for Turkey Point Unit Number 4, Analysis of Capsule T, l
June 14, 1976" by Southwest Research Institute.
(Transcript, page 70)
B.
Admitted Contention 3:
1.
Identify the basis for the statement in Contention 3 that the copper content used in predicting the RTNDT in the weld materials for the Turkey-Point reactor
.]
u vessels was " unrealistically low."
2.
Identify the ba 1; for the' statement in l
l Contention 3 contention that P/T limits are required by.10 CFR Part 50 Appendices G and H to be " based on the most l
l limiting value of RTNDT."
Identify the' specific subsections.
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of Appendices G and H'which allegedly 'contain such a
-J requirement.-
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3.
What value of copper content do. Interveners cot. tend should have been used in calculating the RTNDT f0f Turkey Point Units 3 and 47 Please provide the basis for j
i your answer.
l 4.
Do you agree that.0.26%' represents the mean value:
j i
of the copper content of the weld material for'the Turkey Point reactor vessels?
If not, please provide:the basis for your answer.
5.
Identify the basis for the statement in-Contention 3 that FPL's specification of the copper content--
of the reactor vessel welds is "non-conservative."
Furthermore, identify the relevant sections of any document
]
which supports this assertion.
6.
Please provide copies of the following' documents I
referenced by Interveners at the March 21, 1989 pre-hearing conference in connection with Contention 3'.
(a)
Babcock and Wilcox document! discussing the pressure vessels.
(Transcript,-page 72)
(b)
Babcock and.Wilcox 1556.
(Transcript, page'
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84)
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. (c)
Babcock and Wilcox 10144-A.
(Transcript, pages 84-85).
Respectfully submitted,
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Harold F.
Reis
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Steven P.
Frantz Kenneth C. Manne Newman & Holtzinger, P. C,.
1615 L Street, N.W.
Suite 1000 l
Washington, D.C.
20036 (202) 955-6600 Co-Counsel for Florida Power &
l Light Company Co-Counsel John T. Butler Steel, Hector & Davis l
4000 Southeast Financial Center l
Miami, Florida 33131 l
(305) 577-2800 June 21, 1989 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '89 JUN 26 P4 :08 OF r.73 In the Matter of
)
OGCni?a u,.4 y.
)
BNt.Ncw FLORIDA POWER & LIGHT
)
Docket Nos. 50-250 OLA - 4 COMPANY
)
50-251 OLA - 4
)
(Turkey Point Plant,
)
(P/T Limits)
Units 3 and 4)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Discovery Requests to the Center for Nuclear Responsibility and Joette Lorion" and letter dated June 21,-1989, from Steven P.
Frantz to the Licensing Board Members were served on the following by deposit in the United States mail, first class, properly stamped and addressed, on the date shown below.
B. Paul Cotter, Chairman 3
Atomic Safety and Licensing Board Panel
{
U.S. Nuclear Regulatory Commission j
Washington, D.C.
20555
{
i Glenn O. Bright i
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jerry Harbour Atomic Safety and Licensing Board Panel I
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Doard Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. 'Juclear Regulatory Commission l
Washington, D.C.
20555 l
Office of Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Attention:
Chief, Docketing and Service Section
'l (Original plus two copies)
Joette Lorion, Director l
l l
L_n_ _ _ _ _ _. __
2 ' Center for Nuclear Responsibility 7210 Red Road #217' Miami, Florida 33143
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Janice Moore-Offic'e of General Counse'l U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- 4 Richard Goddard l
i U.S. Nuclear. Regulatory ~ Commission
~
101 Marietta St., N.W.
- 2900
' Atlanta, GA. 30323 i
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John T. Butler Steel, Hector & Davis
. j 4000 Southeast' Financial Center'
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Miami,--Florida 33131 Dated this 21st day of June 1989.
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W)I V ff Q
Kenneth C.
Manne i
Newman & Holtzinger, P.C-l 1615 L Street,..N.W.
l Suite 1000 Washington, D.C.-
20036 i
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