ML20246J697
| ML20246J697 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/29/1989 |
| From: | Patricia Jehle NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J. |
| Shared Package | |
| ML20246J685 | List: |
| References | |
| OLA-4, NUDOCS 8909050242 | |
| Download: ML20246J697 (16) | |
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' August 29, 1989.
UNITED STATES OF AMERICA NUCLEAR REGULATORY' COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )
Docket Nos. 50-250 OLA-4~
FLORIDA POWER AND LIGHT 50-251 OLA-4 COMPANY i
(Turkey Point Plant, Units 3 and'4) ) (P/T Limits)
NRC STAFF RESPONSE TO THE CENTER FOR NUCLEAR RESPONSIBILITY AND J0ETTE LORION'S FIRST SET OF DISCOVERY REQUESTS TO THE NRC STAFF I. INTRODUCTION On August 7, 1989,:the Center for Nuclear Responsibility and Joette Lorion (Interveners), filed their "First Set of Discovery Requests to the NRC Staff". <The Staff notes that interrogatories to parties other than the Staff are governed by 10 C.F.R. 6 2.740b. -However, under 10 C.F.R. 52.720(h)(2)(ii), answers'tointerrogatoriesdirectedtotheStaffare required only on a finding by the presiding officer: 1)thatanswersto the interrogatories are necessary to a proper decision in the proceeding, o and 2) that answers to the interrogatories are not reasonably obtainable from any other sciurce. The Commission's' regulation concerning production of NRC records and documents, 10 C.F.R. 6 2.744, requires that a request to the Executive Director of Operations for the production of an NRC record or document not available pursuant to 9 2.790 by a party to an 4 . initial licensing proceeding state, among other things, why the requested record or document is relevant to the proceeding. Notwithstanding the regulations in 10 C.F.R. 65 2.744 and 2.720(h)(2)(ii), the Staff is voluntarily providing responses to the Interveners' interrogatories.
8909050242 890829-PDR ADOCK 05000250 l- ..G. PDR
L The Staff is responding to Interrogatories 1,3,4,5,6,7,8,9 10,12,13,16 and 17. Mr. Barry J. Elliot provides responses to all the interrogatories, except Interrogatory 5. Dr. Gordon E. Edison provides the response to Interrogatory 5. For the reasons set forth below, the Staff objects to Interrogatories 2, 11, 14 and 15. In responding to the Interveners' interrogatories, the Staff is not waiving its rights, pursuant to 10 C.F.R. 5 2.720(h)(2)(ii), to object to interrogatories in the future.
II. INTERROGATORIES INTERROGATORY 1 Identify the facts, transactions and i T.uments on which the NRC Staff relies in al'bging on page 1 of the NRC Sa'aty Evaluation that "It is estimated that Turkey Point 3 will reach 1 EFPY early in 1989 and Turkey Point 4 will reach 10 EFPY in mid-1989."
RESPONSE
Florida Power and Light Company's estimate is reported in a September 21, 1988, letter from the Licensee. The NRC staff estimate is based on the data reported in NUREG-0020, Vol. 12, No. 6, June 1988, " Licensed Operating Reactor Data as of 5/31/88."
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INTERROGATORY-2 M ildentify the facts ~ transactions and documents on which the'NRC Staff
. relies in stating'on-page 1 of the. Safety Evaluation that "P/T limits are
-among the. limiting. conditions of operation-in the:TS for nearly all, if l
- not :all, plants in the U.S."
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RESPONSE
Y, The: Staff-objects to_this interrogatory as irrelevant. The I iinterrogatory is'beyond. the scope of either Contention 2 or. Contention' 3
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es admitted by the Atomic Safety and Licensing Board's-(Board) Memorandum-andOrder(Ruling'UponContentions),LBP-89-15,29NRC_ , slip op.
(June'8,'1989)L(hereinafterMemorandumandOrder). The Board's Memorandum and Order limited Contention 2-to consideration'of the significance of the
' difference of five' percent in operating times at the . Turkey Point Units 3-Land 4 Memorandum and Order at 18, 26. Contention-3 was admitted as limited to whether the correct percentage of. copper content was'used in l predicting RTNDT of the critical be'ltline materials for setting'P/T--
limits. Memorandum and Order at 25, 26. The Board excluded Intervenor's challenge."upon thel. integrated surveillance test program itself or as s' specifically applied to the Turkey Point Units 3 and 4 by the 1985 license .!
amendments" from consideration in this proceeding. Memorandum and Order at.17.
-INTERROGATORY 3 State whether the weld wire heat number 71249 and Flux Lot 8445 identified on page 2 section 2 of the Safety Evaluation pertain to the surveillance capsules from both units 3 and 4.
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RESPONSE
Weld wire of heat number 71249 and flux. lot 8445 was used to fabricate.the intermediate-shell-to-lower-shell girth welds in Turkey Point 3 and Turkey Point 4 and the surveillance weld in Turkey Point 3.
The surveillance weld samples in Turkey Point Unit 4 were fabricated using weld wire from heat number 71249, but a dif'erent flux lot was used. ,
INTERROGATORY 4 Identify the facts, transactions and documents on which the NRC Staff relies in contending that the 0.26% copper content is the correct and j conservative copper content to use in calculating the RTNDT and setting H the P/T limits for Units 3 and 4
RESPONSE
The NRC staff did not use 0.26% copper content to confirm that the l
P/T limits for Turkey Point Units 3 and 4 meet the requirements of Appendix G, 10 C.F.R. 50. The increase in RTNDT resulting from neutron l l
radiction was calculated based on Section 2.1 of Regulatory Guide 1.99, ;
Rev. 2, " Radiation Embrittlement of Reactor Vessel Materials" (May 1988). j 1
The copper content of intermediate-shell-lower-shell girth welds in Turkey i J
Point 3 and Turkey Point 4 are reported in a Florida Power and Light l Company letter, dated February 10, 1984, i
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. ; INTERROGATORY 5 Identify the facts, transactions and documents on which the NRC Staff relies in contending on Page 6 of the Safety. Evaluation that "the twin
- units 3 and 4 at Turkey Point are nearly identical in their design, construction,' reactor vessel materials, operating procedures and neutron flux spectra".
RESPONSE
The Turkey Point Units 3 and 4, while not identical in every detail,.
are twin units. The Final Safety Analysis Report (FSAR) for Turkey Point zis a single document which applies to both units 3 and 4. The FSAR indi-cates that the units are very similar in design and construction, and that' major components of the reactor coolant system and the materials in the reactor vessel are virtually the same. In addition, a number of systems at the. plant'are shared by Unit 3 and Unit 4, for example, the emergency feedwater system, the high pressure injection system, and the emergency power diesel generators. While the units are both of the-same design, there minor differences between the units as a result of normal construction practices. The FSAR is updated annually and a current copy-is maintained in the local public document room. The NRC staff's many inspections of the Turkey Point Units over the past 20 years have 1
confirmed that the plant and its control room, the auxiliary equipment,
. and the supporting systems are very close in technical detail, although there are many minor differences in the units. The Technical Specificat-ions for the Turkey Point Plant indicate similar operating procedures for i I
the two units. The accumulated neutron fluence showed less than a five l
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. percent difference after 13 years of operation. " Turkey Point Units 3 and i
4, Evaluation of the. Flux Reduction Factor Using Part-Length Burnable
. Absorber Assemblies to Meet the NRC Pressurized Thermal Shock Criteria,"
February 27, 1985 and " Turkey Point Units 3 and 4 Supplemental Evaluation of the Flux Reduction Factor Using Part-Length Burnable Absorber Assemblies to Meet the NRC Pressurized Thermal Shock Criteria,"
February 27, 1935, 4
INTERROGATORY 6 1 1
Identify the facts, transactions and documents on which the NRC Staff relies in' contending on page 6 of the Safety Evaluation that the welds for Unit 4 test speciments [ sic] were made with weld wire from the same heat of material but from a different flux lot that the girth welds in both reactor vessels.
RESPONSE
The heat number and flux lot number of the weld wire used in the Unit 4 surveillance weld and used in the girth welds in the Turkey Point Units 3 and 4 reactor vessels are reported in a letter from Florida Power and Light Company, dated October 21, 1977.
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INTERROGATORY 7 Identify the facts, transactions a d documents on which the NRC Staff relies in contending on page 6 of the Safety Evaluation that "Although the Unit 4 surveillance weld specimens were fabricated using a different flux -
lot, the weld specimens were considered to be representative of the girth l welds in both reactor vessels because flux lot number is only of minor I importance in determining the sensitivity to irradiation embrittlement".
RESPONSE
The Turkey Point Units 3 and 4 surveillance welds and reactor vessel beltline girth welds were fabricated using Linde 80 type flux. Linde 80- )
l type flux is a neutral flux which does not increase or decrease the amount j l
of copper or nickel in the weld material. "B&W 177-FA Reactor Vessel 1 Peltline Weld Chemistry Study," BAW-1799, dated July 1983. Since irradiation embrittlement is dependent upon the amount of copper and nickel in the weld and the accumulated neutron fluence (see, Regulatory Guide 1.99, Rev. 2), the flux lot is not considered important in determining the sensitivity of the weld to irradiation embrittlement.
INTERROGATORY 8 Identify the facts, transactions and documents on which the NRC Staff relies in contending on page 6 of the Safety Evaluation that " Based on the similarity between materials in the center girth welds and the materials used to fabricate the surveillance weld specimens, the test results from capsules in either Units 3 and 4 can be used to monitor the neutron embrittlement in both reactor vessels."
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RESPONSE
Welds are fabricated using weld wire and flux. As was discussed in the response to Interrogatory 7, the flux lot does not contribute to irradiation embrittlement. The weld wire is the main contributor to irradiation embrittlement of the weld. Since the weld surveillance samples in Units 3 and 4 were fabricated using the same heat of weld wire as the center girth welds in Unit 3 and 4, the test results from the surveillance capsules in either unit can be used to monitor the neutron embrittlement in both reactor vessels. The heat number for the weld wire used to fabricate the center girth welds and the surveillance welds in Units 3 and 4 are reported in a letter from Florida Power and Light Company, dated October 21, 1977.
INTERROGATORY 9 l Identify the facts, transactions and documents on which the NRC Staff relies in contending on page 7 of the Safety Evaluation that "the greater than expected embrittlement from one weld sample from Unit 4 does not demonstrate that the beltline material in Unit 4 is as embrittled as the sample".
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RESPONSE
Embrittlement, as discussed on page 7 of the Safety Evaluation, is determined from the results of Charpy-energy tests which measure l
l Charpy-energy at different temperatures. Surveillance specimens are broken over a range of different temperatures to provide a curve of Charpy-energy versus temperature. The Charpy-energy test results have
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. uncertainties associated with them. Th'erefore, the NRC staff in Regulatory Guis 1.99,.Rev. 2, recommends that embrittlement be determined from test-data frca two or more surveillance capsules. In addition, an evaluation of the' amount of embrittlement must include a margin for the' uncertainties for the test method. The test.results from one surveillance capsule (for example, Capsule T from Unit 4) do not, alone, demonstrate.
the precise amount of embrittlement of the Unit 4 beltline' material, because more than one data point is necessary to obtain adequate- test '
results.
INTERROGATORY 10~
Identify the facts, transactions and documents on which the NRC Staff relies in contending on page 7 of the Safety Evaluation that "the Unit 4' data. point- is within the . uncertainty and scatter that can be expected from measurements of this type". j
RESPONSE
The uncertainty and scatter expected for the measurements of the increase in RTNDT resulting from neutron irradiation is discussed in Regulatory Guide 1.99, Rev. 2.
c INTERROGATORY 11
' Identify the facts, transactions and documents on which the NRC Staff relies in contending that the Turkey Point units no longer have the second
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- . and-third highest PTS screening nil-ductility temperature for all plants L as stated on page 8 of the SE.
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RESPONSE
The. Staff objects to this interrogatory as' irrelevant and beyond the 1
scope'of Contention 2 as admitted by the Board's Memorandum and Order.
The Board specifically excluded pressurized thermal shock (PTS) as an i
issue in this proceeding. Memorandum and Order at 19. The Board concluded that PTS was not the subject of the October 19, 1988, Federal Register Notice of Opportunity to Request Hearing. M.;see53 Fed.R3
'40981,-40988 (October 19,1988).
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! INTERROGATORY 12-State whether the RTNDT value identified for Unit 4 in Table 1 of the Safety Evaluation was calculated based en an Charpy' energy level of 30 ft-lb or a Charpy energy level of 42 ft-lb.
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' RESPONSE l
The increase in RTNDT reported in Table 1 for the Unit 4 surveillance data was measured at 30 ft-lb Charpy energy.
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-INTERROGATORY 13 .j i
State whether the coriper content of 0.26% identified in table 2 under.
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' the' Staff's calculation is the mean copper content for Unit 4 and explain:
whether ~or not.the NRC Staff factored in a Standard Deviation when -
performing'this calculation. -If the answer is no,. explain why: not.
-(ReferstoSafetyEvaluation) 1 R_ESPONSE. '.
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The copper content listed in the Table 2 under-the subheading " Staff Calculation" is the mean value for copper content for the beltline girth weld.in-Unit 4. The Staff calculation in Table 2 indicates the adjusted i
.RT NDT f r girth weld at iT (where T is the thickness of the reactor ve'ssel) and 20 effective full power years-(EFPY) is 251*F. The
-calculation' includes'a margin of 28'F, which is one standard deviation,.
.forTthe surveillance material. See Section 2.1 cf Regulatory Guide 1.99, Rev. 2..
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' INTERROGATORY 14
- ' State whether or not the Licensee has provided documents to the NRC Staff as required by 10 C.F.R. [Part 50) Appendix H,Section II C, Parts 1-6'[ sic]since1985. If the answer is yes, identify all such documents provided to the NRC Staff.
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RESPONSE
The staff objects to this interrogatory because the information requested is reasonably obtainable from another source, Florida Power and Light Company, the Licensee. See10C.F.R.52.720(h)(2)(11). The Staff also objects to the interrogatory as unclear. The Staff is not certain what information is being requested because no reporting requirements for a licensee, beyond the original proposal for a license amendnent to incorporate an integrated surveillance program, are set forth in 10 C.F.R. Part 50, Appendix H. Section IIC, Parts 1-4. (Section IIC of Appendix H contains only Parts 1-4, not Parts 1-6 as Interveners indicate.) A proposal was submitted by Florida Power and Light Company on February 8, and March 6, 1985.
INTERROGATORY 15 State the reason (s) that the NRC Staff allowed Florida Power and Light to implement the Integrated Surveillance Program in 1985 despite the fact.that actual weld metal tests for capsule T of Unit 4 did not agree with the original predictions for that Unit, in violation of the requirements of 10 CFR [Part 50] Appenoix H, Section 11 C.
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RESPONSE
The Staff objects to this interrogatory as irrelevant and beyond the scope of Contention 2 as admitted by the Board in its Memorandum and Order. The Board limited the scope of Contention 2 to a consideration of whether the difference of less than five percent in the operating times of l Turkey Point Units 3 and 4 is significant. Memorandum and Order at 18.
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c The Board ~specifically' excluded from Contention 2 attacks upon the integrated surveillance test program or_upon the progrua as applied at the
-Turkey Point Units 3 and 4 under the 1985 license' amendments. Memorandum and Order at 17.
INTERROGATORY 16 Identify any and all historical documents that support the NRC j Staff's claim that Unit 4's surveillance capsules T and V used a different .i welding flux lot number. 1 l
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RESPONSE
The Staff objects to.this interrogatory because it requests information from the Staff which is reason 1bly available from another source.. See'10 C.F.R. 5 2.70(h)(2)(ii). IPs documentation on flux lots was generated by the Licensee. For this etason the Licensee would be in a better position'than the Staff to provide the requested information. The
. presiding officer in'a proceeding may require that the Staff provide answers to interrogatories that are not reasonably obtainable from any othersourcepursuantto10C.F.R.52.720(h)(2)(ii). In addition, it would be overly burdensome to the Staff to review each and every document in this proceeding for references to the flux lot number of Unit 4 surveillance capsules.
The Staff is responding to this interrogatory by identifying all the documentary materials on which it relied in making its statement about the
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flux lot number of weld samples in the Unit 4 serve 111ance capsules.; The l
l flux lot number for the weld material samples placed in Capsules T and V in Turkey. Point Units 3 and'4 is identified in a letter from Florida Power and Light Company, dated October 21, 1977.- 1 L !
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INTERROGATORY 17 Copies of Minutes'of April 7, 1977, meeting between the NRC Staff and Florida Power and Light concerning FPL's use of Unit 3 weld metal.
. surveillance data to predict radiation damage to Unit 4.
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RESPONSE
Based on a review of our files the'only information that we have. 1 4
concerning an April 7, 1977, meeting between the NRC-staff and Florida 1 Power and Light Company staff is a document, " Agenda: Meeting with NRC on Turkey Point 4 Reactor Yessel, April 7, 1977." A copy of the Florida Power.and Light Company agenda is attached.
R ctfully submitted, o%
Patricia Jehle Counsel for NRC Staff 1 Dated at Rockville, Maryland I this 29th day of August, 1989.
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UNITED STATES OF AMERICA -
r NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'the Matter of )
) Docket Nos. 50-250 OLA-4 FLORIDA POWER AND LIGHT ) 50-251 OLA-4 COMPANY (Turkey Point Plant, Units 3 and 4) ) (P/TLimits)
AFFIDAVIT OF BARRY J. ELLIOT I, Barry J. Elliot, being duly sworn, state as follows:
I am employed as a Materials Engineer in the Materials and Chemical Engineering Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor' Regulation of the U.S. Nuclear Regulatory Commission.. I have provided responses to Interrogatories 1, 3, 4, 6, 7, 8, 9, 10, 12, 13, 16, and 17.
I hereby certify that the answers are true and correct to the best of my knowledge. -
Barry J. Elliot Subscribed and sworn before me this day of , 1989.
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BARRY J. ELLIOT U.S. NUCLEAR REGULATORY COMMISSION- i
' MATERIALS AND CHEMICAL ENGINEERING BRANCH l DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY OFFICE OF NUCLEAR REACTOR REGULATION
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STATEMENT OF PROFESSIONAL QUALIFICATIONS i
I am currently employed by the U.S. Nuclear Regulatory Commission as a Senior Materials Engineer in the Materials and Chemical Engineering Branch, Division of Engineering and Systems Technology, Office of Nuclear Reactor Regulation. I am responsible for the review and the evaluation of safety analysis reports which are related to the material engineering aspects of components in nuclear power plant systems. I also provide technical assistance to the Offices of Nuclear Reactor Regulation and Nuclear Regulatory Research on related feactor safety matters. I have been employed at the Nuclear Regulatory Commission since March 31, 1980. I graduated from Rensselaer Polytechnic Institute in 1968 with a Cachelor of Science degree in Materials Engineering. I attended evening classes at Fairleigh Dickinson University,
, where in 1971, I received a Masters of Science degree in Business Admini-stration.
I was employed by Curtiss Wright Corporation from 1968 to 1980. From 1968 to 1971 I worked in the Materials Development Laboratory of the Aeronautical Division where I performed failure analyses on reciprocating and gas-turbine engines, and developed test apparatus to evaluate material reliability. From 1971 to 1980 I worked in the Nuclear Division where I was responsible for developing and implementing non-destructive examination test l procedures and fusion weld procedures to be used in the fabrication and inspection of U.S. Department of the Navy nuclear pressure vessels, b
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