ML20247F101

Intervenors Response to Licensee Followup Discovery Request to Ctr for Nuclear Responsibility & J Lorion.* Intervenors Believe That Unit 4 plant-specific Surveillance Data Only Credible Data.W/Certificate of Svc.Related Correspondence

ML20247F101
Person / Time
Site:	Turkey Point
Issue date:	09/08/1989
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:	FLORIDA POWER & LIGHT CO.
References
CON-#389-9161 OLA-4, NUDOCS 8909180081
Download: ML20247F101 (4)

Text

A. l.k.[

E1/TED COfMEF.UNEN l CatxETED unc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'89 SEP 12 A10:04 BLFORE THE ATOMIC SAFETY AND LICENSINGf,BOASD '

uvCnt - o .t MiW In the Matter of )

cket Nos.

FLORIDA POWER'&' LIGHT COMPANY )

)

]200 ]4 (Turkey Point Plant, )

Units 3 and 4) ) _

INTERVENERS' RESPONSE TO LICENSEE'S FOLLOW-UP DISCOVERY

. REQUEST 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 follow-up discovery request:

Respcnse to Interrogatory 1 (a): Interveners would agree that the NRC Staff has accepted the methods identified in Revision 2 to Regulatory Guide 1.99 as appropriate for determining the adjusted reference temperature (ART) of the materials of reactor vessels in general and the materials of the Turkey Foint reactor vessels in particular. Interveners are currently researching the issue of whether the use of Revision 2 for the aged Turkey Point reactors is appropriate for determining the ART. Interveners believe that the use of Revision 2 may not be the most conservative method for calculating the ART for the aged reactor vessels. In addition, Interveners do not believe the use of Revision 2, part 2 to calculate the ART for Turkey Point Unit 4 is either appropriate or conservative.

I' 8909180081 890908 DR ADOCK0500gggO

'11 503 l

( 2')

Response to Interrogatory 2 (b): At this time, Interveners are not aware of specific statements or provisions in Revision 2 that are inappropriate. Interveners believe that it ip the Licensee's use of Section 2 of the regulatory g'uide to predict ART for Unit 4 that is inappropriate. Interveners believe that Licensee does not meet the criteria for an Integrated Surveillance Program, thus use of the combined-Unit.3 and 4 da'ta is not appropriate and-not conservative. Interveners believe that the Unit 4 plant specific surveillance data is the ohly credible-data that can be used to predict ART.and set P/T limits for <

Unit 4. ~

I

. 1 Response to Interrogatory'2 (c) : As stated in response to 2 (b)

Interveners do not believe that FPL properly implemented Revision 2 for determination of the ART for Unit 4, because Interveners

,, do,not believe that. Turkey Point Units.3 and 4 meet the crit'eria-for an integrated surveillance program, and thus Licensee is underestimating the ART and not being conservative in their setting of the P/T limits for Unit 4. Licensee did not properly-implement Revision 2, because they used Section 2 of the guide to calculate ART and set the P/T limits for Unit

4.

• Respectfully submitted,

@@ sk Q- -

Joette Lorion Director, Center for Nuclear Responsibility 7210 Red Road #217 Miami, F1. 33143 (305) 661-2165 Dated: September 8, 1989 L _ _____- _- --

l

.(6,,

^V UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

'89 gp 12 A10:05 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f.ocn': In the Matter of ) g r , .[ _

FLORIDA POWER & LIGHT CO. )

Docket Nos. 50-250 OLA

)

Uis and (Pressure / Temperature Amendments)

CERTIFICATE OF SERVICE' I hereby certify that copies of " Interveners' Responses

.to Licensee's_Foloow-up. Discovery Request to the' Center.for .. _.... -.

Nuclear Responsibility and Joette Lorion" have been served on the following by deposit in the United States Mail, first class, properly stamped and addressed 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. Frantz Atomic Safety & Licensing Board Ne:rman & 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 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janice Moore 1 I Office of General Counsel U.S. Nuclear Regulatory Commission Joette Lorion Director, Center for Washington, D.C. 20555 Nuclear Responsibility 7210 Red Road #217 Miami, Florida 33143

'Date: September 0, 1989 (305) 661-2165

• John Butler was hand delievered a response on September 8, 1989.

, -d p

y e ,

b i

2

- STATE OF, FLORIDA

' COUNTY OF DADE Before me the undersigned authority, personally appeared -

JOETTE LORION,:who after being' duly sworn deposes and says that the foregoing INTERVENERS' RESPONSE TO LICENSEE'S FOLLOW, UP DISCOVERY ~ REQUEST TO THE CENTER BOR NUCLEAR RESPONSIBILITY ~ ~ ~

- AND JOETTE.LORION propounded on the /M day of g

! , 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.

O A fx l e t h '

W Notary Public, State -

of Florida at Large s' i ,

l MY COMMISSION EXPIRES:

NCIARY PUBLlg stait CF FLORIDA aY CCRMI:5106 (IP JUk! 13.1991 l

_ . - _ _ _ . _ - - _ _ _