ML20246J275
| ML20246J275 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/28/1989 |
| From: | Demastry J, Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER |
| To: | CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| References | |
| CON-#389-9109 OLA-4, NUDOCS 8909050101 | |
| Download: ML20246J275 (24) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAsp AUG 30 20:05 f
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'In the Matter.of
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Docket Nos. 50-250 OLA-4' FLORIDA POWER & LIGHT COMPANY )
50-251 OLA-4 i
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(Turkey Point' Plant,
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Units 3 and 4)
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(P/T Limits)
)
LICENSEE'S RESPONSE TO INTERVENERS' FIRST SET OF DISCOVERY REOUE
'd TO LICENSEE Florida Power & Light Company (FPL or Licensee) hereby filei its response to the interrogatories and the document requests contained in " Interveners' First Set of Discovery Requests to Licensee" (August 7, 1989).
The requested documents will'be made available to the Interveners for inspection and copying beginning September 5, 1989, during normal business hours at Steel, Hector & Davis, 4000 Southeast Financial Center, Miami, Florida.
Interveners are requested to provide John Butler, co-counsel for
' Licensees, with notice (at least two business days) prior to seeking such inspection.
Interrogatory A.1 -
l Identify the facts and documents that Licensee relies upon in alleging that.26 is the proper and conservative percentage of copper to use in calculating the RT, for use in revising the P/T limits for Turkey Point units 3 and 4.
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.; Licensee's Response -
FPL did'not utilize any percentage of copper in calculating the RT,oy used in revising the P/T limits for Turkey Point Unit 3 and 4 in 1988.
Instead, in accordance with the provisions of Revision 2 to Regulatory Guide 1.99, FPL calculated the RT,7 using surveillance capsule data.
If FPL had calculated the RT,oy using a percentage of copper, 0.26% would have been the appropriate value to utilira.
Revision 2 to Regulatory Guide 1.99 states that, 1/ hen using a copper percentage to calculate RT the "best Ottimate" of ef,
the copper percentage should be utilized.
As stated in FPL letter L-84-31 to the NRC dated February 10, 1984, and the NRC's Safety Evaluation for Turkey Point dated April 26, 1984, the mean value of the copper content in the Turkey Point reactor vessel welds is 0.26%.
This mean value is the best estimate of the copper content of the welds.
Document Recruest A.2 Provide copies of any and all historical or other documents that prove that the copper content of the limiting welds is 0.26%.
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Licensee's Res>onse -
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1 The following documents are responsive to.this request:
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~ FPL Letter.L-84-31 to the NRC dated February 10, 1984 l
1) 2)
NRC's Safety Evaluation for Turkey Point dated April 26, 1984 Additionally, the following documents provide information which was used to calculate a copper percent of 0.26%.
'3)
Supplement to FPL Letter L-77-113 to the NRC dated June l
27, 1977 4)
W.A.
. Van der
- Sluys, et al.,
An Investigation.of f
Mechanical Properties and Chemistry Within a Thide Mn-
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Mo-Ni Submerged Arc Weldment, EPkI NP-373, Electric Power l
Research Institute, Palo Alto, California, February 1977 5)
B&W 177-FA Deactor Vessel Beltline Weld Chemistry Study, BAW-1799, Babcock and Wilcox, Lynchburg, Virginia, July 1983-6)
FPL Letter L-77-113 to the NRC, dated April 11, 1977 l
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S.E.
Yanichco, FP&L Co. Turkey Point Unit 3 Reactor l
Vessel Radiation Surveillance
- Program, WCAP
- 7656, Westinghouse Electric Corp., Pittsburgh, PA, May 1971 8)
S.E.
Yanichco, FP&L Co. Turkey. Point Unit 4 Reactor Vessel Radiation Surveillance
- Program, WCAP
- 7660, Westinghouse Electric Corp., Pittsburgh, PA, May 1971 l
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Point Beach Unit 1 Reactor Vessel Radiation Surveillance l'
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- Program, WCAP
- 8743, Westinghouse Electric
. Corp.,
Pittsburgh, PA FPL believes that documents 1,2,3,5,6,7,8, and 9 are.in the NRC's Public Document Room (PDR).
If Interveners are unable to locate these documents in the PDR, FPL will make these documents -(together with document 4) available for inspection by Interveners and, upon request, will provide copies to the Interveners at a cost of $.10 per page.
Interrogatory A.3 -
State whether the 0.26% copper content is the mean value and explain whether or not Licensee factored in a standard deviation when calculating the percentage of copper.
Licensee's ResDonse -
The value of 0.26% is the mean value of the copper content of the Turkey Point reactor vessel welds.
This value does not include a standard deviation.
Interrogatory A.4 -
If the answer to interrogatory no. 3 is no, provide the reason i
and/or justification for not applying a standard deviation.
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Licensee 8s Response -
Both Revision 2 to Regulatory Guide 1.99 and 10 CFR 50.61 call for the use of a "best estimate" of the copper percentage.
Inclusion of a standard deviation would be inconsistent with the concept of a "best estimate."
Interrogatory A.5 -
Provide the reasons and/or justifications for the Licensee's use of 0.31% of copper in calculating RT, 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.
Licensee's Response -
As stated in Licensee's Response to Interrogatory A.1, FPL l
did not utilize a value of 0.26% in calculating the P/T limits in 1988.
FPL previously utilized a value of 0.31%
in calculating the P/T limits for 10 EFPY because that was the best estimate of the copper percentage based upon the limited data then available.
. Interrogatory A.6 -
State whether Licensee agrees that the use of 0.31% copper rather than 0.26% copper in calculating RT,,7 and revising P/T limits for units 3 and 4 would result in the P/T limits being more conservative and/or restrictive.
If Licensee disagrees, state the basis for your disagreement.
Licensee's Response -
As stated in Licensee's Response to Interrogatory A.1, FPL did not utilize a value of 0.26% copper in calculating the P/T limits in 1988.
If a value for copper content had been utilized, a value of 0.31% copper would have resulted in P/T limits that would be slightly more restrictive (especially at higher temperatures) than a value of 0.26% copper, utilizing i
i the methodology in Revision 2 to Regulatory Guide 1.99.
l Interrogatory A.7 -
State whether Licensee or the NRC Staff attempted to calculate RT,oy 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.
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U Licensee's Response -
FPL does not know whether the NRC Staff attempted to calculate the RT,7 for Turkey Point using a value of 0.28% or above for l
.the copper content.
For purposes of litigation (and not for revising the P/T limits for Turkey Point), FPL did calculate RT,7 using a copper content of 0.30% copper.
A copy of this calculation will be made available for inspec'sion by the Interveners and, upon requ' ist,
will be provided to the
,.10 per page.
As stated in Interveners at a cost of Licensee's Responr.e to Interrogatory A.1, use of a value of 0.26% copper would have been appropriate under Revision 2 to Regulatory Guide 1.99; use of a value of 0.30% copper would have been inconsistent with the regulatory guide.
- However, no percentage of copper value was in fact used.
Interrogatory A.s -
State whether Licensee agrees that a
reduction in the percentage of copper content could result in an increase of EFPY.
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. Licensee's Response -
The Licensee does not understand this interrogatory.
The copper content of the Turkey Point reactor vessel welds is based upon the materials used in fabricating the reactor vessels and is not subject to being " reduced".
Furthermore, the current EFPY for the Turkey Point units is unrelated to the copper content of the Turkey Point reactor vessel welds.
Document Recuest A.9 -
Copies of any and all calculation of RT for Turkey Point g7 Units 3 and 4 for revision of the P/T limits as set out by Regulatory Guide 1.99, Revision 2.
Licensee's Response -
The Licensee previously provided the Interveners with a copy of the calculation of the RT,7 used in revising the P/T limits for Turkey Point in 1988.
See letter dated August 4,
- 1989, from Steven P. Frantz to Joette Lorion.
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Interrogatory B.1 -
Documents that provide information concerning the respective design, fluence, and operating histories for Turkey. Point l
Units 3 and:4, including but not limited.to documents that provide information on the following:
p.
a)
. weld wire heat number and flux lot for the welds and surveillance. test capsules;,
b).
operating procedures; 1
c)
EFPY;'
d) loading history; e) accumulated neutron spectra, flux and fluence; f) cycle lengths; l-g) capacity fac' tor; l
h) fuel management.
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.. Licensee's Response --
Based upon discussions with the Interveners on August 15, 1989, Licensee understands that this request will be satisfied if the Licensee provides information corresponding to the infermat!9n set forth below.
In accordance with the Licensing Board's 'lemorandum and Order, this information corresponds to operation of Turkey Point for the years since 1985, when the NRC accepted the integrated surveillance program for Turkey Point.
Weld Heat Flux Lot a)
Number Number Number Units 3&4 Critical SA 1101 71249 Linde 80, Welds Lot 8445 Unit 3 Weld SA 1101 71249 Linde 80, Capsule Lot 8445 Unit 4 Weld SA 1094 71249 Linde 80, Capsule Lot 8457 b)
The operating procedures for Turkey Point Units 3 and 4 l
are required to conform with the Technical Specifications for Turkey Point.
The limits in the Technical Specifications applicable to operation of the reactors are the same for each unit.
Therefore, the operating procedures for each unit are similar if not identical.
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Annual EFPH Unit 3 Unit 4 1985 5032.5 7706.5 1986 6652.9 2601.8 1987 1344.6 3950.2 1988 3176.3~ 4828.9 1985-1988 18,206.3 19,087.4 Total lifetime EFPY for Turkey Point Units.3 and 4 as of August ~23, 1989, are 10.203 and 9.732, respectively.
d)~
.The design features utilizea in each core loading since 1985 are similar in mechanical design, type of neutron absorbers, enrichments and arrangements within' the core.
e)
Unit 3 Lifetime Cumu ative Fluence End of N/cm}; E> 1. 0 MEV Cyclp Fluence Cycle
.Q.ySJ,g N/cm ;
E> 1.0 MEV 9
3/30/85 1.3 x 10
7.1 x 10'I 10 3/15/87 1.3 x 10
7.4 x 10'I 11 2/15/90*
1.4 x 10 "
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x 10 "
1 1
2.3 x 10"'
9-11 Unit 4 10 1/10/86 1.2 x 10
11. 7 x 10 17 11 9/20/88 1.3 x 10' 8.0 x 10 1
17 i
1 12 10/7/90*
1.4 x lo "
8.6 x 10 "
2.5 x 10"'
. 10-12
- Estimated f)
Unit 3 Unit 4 Cycle Start EDd Start End 9
1/7/84 3/30/85 10 7/17/85 3/15/87 6/1/84 1/10/86 11 9/5/87 2/15/90*
8/31/86 9/20/88 12 6/10/89 10/7/90*
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- Estimated g)
CaDacity Factors Unit 3 Unit 4 Lifetime Lifetime Cumulative Annual Cumulative Annual 57.4 68.9 88.0 1985 65.9 1986 66.8 75.9 65.1 29.7 1987 63.2 15.3 63.7 45.1 1988 63.0 58.9 63.3 55.0 51.9 54.4 1985-88 h)
See response to (d), above Document Recruest B.'2 -
Copies of any and all documents that Licensee has supplied to the NRC since 1985 as required by 10 CFR Appendix H, Section l
II C, Parts 1-6 [ sic).
l Licensee 8s Response -
10 CFR Part 50, Appendix H, Section II.C (which contains only four subsections) does not require a licensee to submit any
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documents to the NRC.
In documents submitted on February'8, i
1985,'and March 6, 1985, FPL applied for amendments to the J
Turkey Point Technical Specifications to permit use of an integrated surveillance program under 1C CFR Part 50, Appendix
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t7 H,Section II. C.
These documents should be in the NRC Public Document Room.
If Interveners are unable to obtain copies from this source, Licensee will make these documents available to the Interveners for inspection and upon request will provide a copy to the Interveners at a. cost of $.10 per nage.-
Interrogatory B.3 -
1 State whether Licensee has a contingency plan as required by Appendix H to assure that the surveillance program for.each 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 NFC as a result of such outage.
If tne answer is no, state why no such plan exists.
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Licensee's Response -
l FPL has a contingency plan.
This plan is documented in the letters identified in Licensee's Response to Interrogatory B., 2.
Turkey Point has not experienced operation at a reduced 1
I power level or an extended outage sufficient to invoke this l
contingency plan.
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- 14 Interrogatory B.4 -
State whether Licensee believes that the Charpy weld metal test results for capsule T of Unit 4 agreed with the original embrittlement predictions for that reactor unit.
Licensee's ResDonse -
The adjusted reference temperature of Unit 4 capsule T was higher than the adjusted reference temperature predicted by-Revision 1 to Regulatory. Guide 1.99, which was the applicable regulatory guide at the time capsule T was tested. Using currently applicable Revision 2 to Regulatory Guide 1.99 (and utilizing 0.26% copper and 0.60% nickel),
the predicted adjusted reference temperature is about 2%~below the ART determined from the capsule T test results.
Interrogatory B.5 -
State whether TP Units 3 and 4 have had equivalent core loadings since 1985 and provide documents that support your response.
.. i Licensee's Response -
Turkey Point Units.3 and 4 have had equivalent core loadings since:1985. The design features utilized in each core loading -
since 1985 are similar in mechanical design, type of. neutron absorbers, enrichments, and arrangement within the core.
i copies of documents that provideLsupport for this response will be made available for inspection by the Interveners and, upon request, will be provided to be Interveners at a cost of
$.10 per page.
' Interrogatory B.6 -
State whether the neutron spectra profiles for Turkey Point Units 3 and 4 are and have been equivalent and provide documents that support your response.
Licensee 8s Response -
The Licensee concludes that the neutron spectra profiles for Turkey Point Units 3 and 4 are and have been similar since 1985.
The conclusion is based on the similarity in core
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- loadings (see response to Interrogatory B.5) and _.the similarity in neutron fluences above 1.,0 MEV (see response to. Interrogatory ~ B.1.e).
The Licensee 'does not.have any-l..
documents that explicitly address this issue.
Document Recuest'B.7 l
Provide documents that show the ' prediction of radiation damage as a function-of power output for both Turkey Point Units 3 and 4.
Licensee's Response -
Radiation damage is not directly a function of power output.
- Instead, radiation
_ damage is a
function of, neutron irradiation,_which is affected by power output.
Regulatory Guide 1.99, Revision 2 contains equations that identify RT,
as a
function of neutron fluence.
This document was previously provided to the Interveners in a letter dated August 4, 1989, from Steven P. Frantz to Joette Lorion.
While radiation damage could be expressed as a
function of cummulative power output, FPL has no documents that do this.
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Interrogatory B.s -
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
' i results of tests for TP 3 and 4.
If the answer is no, explain L
why no such tests are conducted.
' Licensee 8s Response -
FPL installed in cavity dosimetry for Turkey - Point Units 3 l
i and 4 to bench-mark FPL's fluence calculational methods in support of the initiation of the integrated surveillance program in 1985.
FPL has not conducted any additional in cavity dosimetry to project neutron fluence, because in-reactor dosimetry is sufficient for this purpose.
copies of the documents containing the test results will be made available for inspection by the Interveners and, upon request, will be provided to the Interveners at a cost of $.10 per page.
1 Interrogatory B.9 i
fitste whether in cavity dosimetry testing was ever incorporated into the integrated surveillance program for i
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Units 3-and 4.
1 Licensee's Response -
i The in cavity (ex vessel) dosimetry was used in conjunction l
with the initiation of the integrated surveillance program 1
for Turkey Point Units 3 and 4 to bench-mark FPL's fluence 4
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calculations.
FPL expects to use in cavity dosimetry again l'
in conjunction with FPL's flux reducticn program but has no plans to conduct further in cavity dosimetry tests in conjunction with the integrated surveillance program.
Interrogatory B.10 -
State whether Licensee agrees with the NRC Staff statement on I
page 6 of the Safety Evaluation for the P/T amendments that flux lot number is only of minor importance in determining the sensitivity of irradiation embrittlement. State the basis and or-justification for Licensee's agreement or disagreement.
Licensee's Response -
Bulk chemistry, specifically percent copper and nickel, are the primary variables in determining the sensitivity of reactor vessel materials to irradiation embrittlement.
However, flux type and concentrations of other elements also affect this sensitivity.
- _ = _ - _ - _ _ - _ _ - _ - _ _ _ _ _ _ _
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The flux lot numbers for the weld capsule material and the weld material for Turkey Point Unit 4 are different.
Based-upon test results for capsule T for Unit 4, FPL believes'that this difference may result in an RT for Unit 4 that is g7 higher (i.e., more conservative) than would be the case if the flux. lot numbers were the same.
3t this time, it is not possible to quantify with -certainty the impact of this-difference.
Therefore, FPL is not at this time in a position to agree or disagree with the.NRC's statement.
Interrogatory B.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.
Licensee's ResDonse -
Responses to discovery requests B.1,B.5,and B.6 discuss the similarity in the operatining features for Turkey Point Units 3 and 4.
Licensee has not asserted that radiation damage can be predicted as a function of total power output.
- Instead, Licensee has stated that the RT of reactor vessel can be g7
. predicted based upon the materials in the reactor vessel and the neutron fluence for the materials.
This position is supported by, among other documents, Revision 2 to Regulatory 1
Guide 1.99.
i Document Recuest B.12 l
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 l
calculate RT,7 based on Unit 4 capsule T surveillance data.
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Licensee's Response -
The RT 7 used in preparing the P/T limits for Turkey Point Units 3 and 4 in 1988 were calculated using a 30 ft-lb charpy adjusted reference temperature for the surveillance capsules of both Unit 3 and Unit 4.
This calculation was previously provided to the Interveners in a letter dated August 4,
- 1989, from Steven P. Frantz to Joette Lorion.
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d Respectfully submitted,-
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.MV61 Ifarold F. Reis
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Steven P.
Frantz Kenneth C. Manne Newman & Holtzinger, P.C.
1615 L Street, N.W.
i Suite.1000 l
. Washington,'D.'C.
20036
-(202)-955-6600 Co-Counsel
.for Florida Power &' Light Company.
E August 28,~1989-Co-Counsel John.T. Butler Steel, Hector &. Davis
-4000 Southeast Financial Center Miami, Florida 33131 (305)~577-2800.
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STATE OF FLORIDA COUNTY OF PALM BEACH J. A. DeMastry, being first duly sworn, deposes and says:
I am the Staff Engineer-Licensing for Florida Power & Light Company (FPL) and am responsible for coordinating FPL's activities for the
' Turkey Point P/T Limits proceeding.
The foregoing. responses to
~ Interveners' first set of discovery requests were' prepared under my supervision and' control and are true and correct to the best of my knowledge, information, and belief.
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DeMastry Dated August 28, 1989 Subscribed and sworn to before me this 28th day of August, 1989.
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My Commission Expires:
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BO E E 1
M'n In the Matter of
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buchtigj{
)
FLORIDA POWER & LIGHT
)
Docket Nos. 50-250 OLA - 4 COMPANY
)
50-251 CLA - 4
)
(Turkey Point Plant,
)
(P/T Limits)
Units 3 and 4
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Interveners' First Set of Discovery Requests to Licensee" 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 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C..
20555 Jerry Harbour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Chief, Docketing and Service Section (Original plus two copies)
_ -_ _-_A
- o Joette Lorion,-Director-Center.for Nuclear. Responsibility 47210LRed Road #217 Miami, Florida 33143 Janice Moore
' Patricia'A. Jehle
. Office of General Counsel
-U.S.-Nuclear Regulatory Commission m.:
' Washington, D.C.: '20555 Richard Goddard U.S.. Nuclear Regulatory Commission
'101 Marietta St., N.W.
- 2900
. Atlanta,'GA' 30323 John T. Butler Steel, Hector.& Davis-4000 Southeast Financial Center.
Miami, Florida 33131 Dated this'28th day of August 1989.
Kenneth C. Manne' Newman & Holtzinger, P.C.
1615 L Street, N.W.
Suite 1000~
l Washington, D.C.
20036 l
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