ML20247F208

Licensee Statement of Matl Facts as to Which No Genuine Issue to Be Heard W/Respect to Intervenors Contentions.* Provides Facts Re Contentions 2 & 3

ML20247F208
Person / Time
Site:	Turkey Point
Issue date:	09/11/1989
From:	Frantz S FLORIDA POWER & LIGHT CO., NEWMAN & HOLTZINGER
To:
Shared Package
ML20247F159	List: ML20247F153 ML20247F185 ML20247F208 ML20247F246
References
OLA-4, NUDOCS 8909180106
Download: ML20247F208 (6)

Text

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t UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-250 OLA-4 .

1 FLORIDA POWER & LIGHT COMPANY )59-251 OLA-4

)

(Turkey Point Plant ) (P/T Limits)

Units 3 & 4) )

)

LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE i TO BE HEARD WITH RESPECT TO INTERVENO'tS' CONTENTIONS Licensee contends there is no genuine issue to be heard

-with respect to the following naterial facts:

Background for Contentions 2 and 3

1. The purpose of Pressure / Temperature (P/T) limits is to ensure that,.during normal operation, the pressure and ,

i temperature of the reactor coolant are maintained within limits i 1

sufficient to ensure an adequate margin against postulated brittle fracture of the reactor vessel. (Affidavit of Stephen A.

Collard on Contentions 2 and.3 (September 11, 1989) at is 7 and 17).

2. The fracture toughness of a material is primarily dependent upon its chemical composition, temperature, and neutron irradiation. The fracture toughness of a metal decreases with decreases in temperature, with increases in neutron fluence, and with increases in copper and nickel content. (Id. at is 7-16).

8909180106 890911 PDR ADDCK 05000250 0 PDR

i *

3. One measure of the fracture toughness of a reactor vessel is its Adjusted Reference Temperature (ART). NRC Regulatory Guide 1.99, Revision 2, " Radiation Embrittlement of Reactor Vessel Materials" (May 1988) (hereinafter " Regulatory Guide 1.99") contains an appropriate and conservative method for calculating ART. (Id. at is 13-14, 20-21).

4. Appendix G to the American Society for Mechanical Engineers (ASME) Code provides an appropriate procedure for calculating P/T limits for a reactor vessel given the ART for the vessel. (Id. at i 20).

5. The calculation of the P/T limits for operation of Turkey Point up to 20 effective full power years (EFPY) was performed in conformance with the methodologies cpecified in ,

Appendix G of the AfiME Code and Regulatory Guide 1.99. (Id. at 5 26).

6. The methodologies used to calculate the P/T limits for Turkey Point contain a number of conservatism and a large margin of safety. (Id. at 5 28).

Contention 2 l

7. At the beginning of operation, Turkey Point Units 3 and 4 each had eight reactor vessel surveillance capsules containing material specimens and dosimeters. In each unit, five 1

of the eight capsules contained material specimens of the shell forgings of the reactor vessel; the remaining three capsules l contained material specimens of the shell forgings, the reactor l I

's W

welds, and' material in the heat affected zone around the welds.

(Id. at s'37).

B. To date, three capsules containing weld specimens

- have been removed from Turkey Point Units 3 and 4 (capsule T from-

- Unit'4 and capsules T and V from Unit 3). Two capsules containing shell forging materials have also been removed. (Id.

at 1 42).

9. Weld material is the critical material for purposes of calculating the Turkey Point P/T curves. (Id. at is 27 and 42).

10. In 1985, the NRC issued-license amendments authorizing Turkey Pointito conduct an integrated surveillance program. Under this program, the results of tests of the surveillance ccesules'from each unit are combined to predict the fracture toughness of the reactor vessels for Turkey Point Units 3 and 4. (Id. at 11 6, 44-45).

11. The Turkey Point integrated surveillance program has a contingency plan which consists of each reactor relying on

. the data from its own surveillance capsules in the event of an extended outage or period of low power operation at the other reactor. (Id. at 1 49).

12. Existing surveillance capsule test data for Turkey Point. Units 3 and 4 are sufficient for purposes of calculating-P/T limits up to 20 EFPY. (Id. at is 51-58). I

13. Any extended outages or periods of low power operation at either Turkey Point Unit 3 or Unit 4 since 1985 l

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(. 1 i

1 would not affect the validity of the calculation of the P/T limits up to.20 EFPY because the current P/T limits are based upon test data from surveillance capsules that were removed from the reactor vessels in 1985 or earlier. (Id.).

14. . In determining the effects of neutron irradiation on_ fracture toughness, the total amount of fluence a material has received is of importance. Outages, EFPY, capacity factors and operation at low power are of significance to fracture toughness only to the extent th'y e affect total fluence. (Id. at i 61).

15. The difference in the total amounts of fluence  ;

received by Turkey Point Units 3 and 4 reactor vessels is less than 3%. This difference is not sufficient to call into question the use of Unit 3: data to help predict the P/T limits for Unit 4.

(ld. at i 62).

16. The total EFPY and capacity factors of Turkey Point Units 3 and 4 are very similar vver their operating lifetimes. The differences in EFPY and capacity factor between these units are not sufficient to cali into question the use of Unit 3 data to help predict the P/T limits for Unit 4. ;d. at if 64-66).

17. The current differences in fluence and EFPY for Turkey Point Units 3 and 4 are less than the differences that existed in 1985 when the NRC accepted the integrated surveillance program. (Id. at i 65).

18. In 1981, on two occasions, the pressure in the reactor coolant system at Unit 4 exceeded technical specification i

l-

"+ -s-limits by 700 psi and 325 psi, respectively. These events did not affect the structural integrity of the Unit 4 reactor vessel.

(Id. at 1 69).

19. If the methodologies in Regulatory Guide 1.99 and Appendix G of the ASME' Code are used, the P/T limits for Turkey Point Unit 4 alone would be almost identical to the P/T limits ,

for Turkey Point Units 3 ani 4 based upon tha Turkey Point integrated surveillance prog.am. (Id. at 11 72-74).

Contention 3

20. Regulatory Guide 1.99 contains two methods which can be used for determining the -hemistry factor used in calculating the ART. First, when surveillance capsule test data are not available, the chemistry factor is to be calculated using the copper and nickel content of the material. Second, when credible test data are available from two or more surveillance

. capsules, then the test data are to be used for purposes of ,

calculating the chemistry factor (unless the use of the test data ,

i provides for a lower ART than the use of copper and nickel content, in which case eitber may be used). (Id. at 1 22).

21. In accordance with Regulatory Guide 1.99, FPL calculated the chemistry factor of the Turkey Point reactor )

i vessel welds based upon the surveillance capsule test data from  :

its integrated surveillance program. (Id. at 1 31). i

22. FPL did not use any value of copper content in calculating the P/T limits for Turkey Point Units 3 and 4.

(Id.).

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23. If the chemistry factor is calculated based upon copper and nickel content, Regulatory Guide 1.99 states that the "best estimate" of the copp?r and nickel content should be used.

Regulatory Guide l'.99 defines "best estimate" as the mean of measured values. ( E at'1 32).

24.- The mean of the measured values of the copper, content of the type of material in the critical' welds in the i.

Turkey Point reactor vessels is 0.26%. Use of this.value would-

.have been appropriate under Regulatory Guide 1.99. (Id.).

Respectfully submitted, h

Harold F. Reis /

Steven P. Frantz Kenneth C. Manne Newman & Holtzinger, P.C.

1615 L Street, N.W.

Suite 1000 Washington, D.C. 20036

'(202) 955-6600 Co-Counsel for Florida Power.& Light Company Co-Counsel John T. Butler Steel, Hector & Davis 4000 Southeast Financial Center Miami, Florida 33131 (305) 577-2800 September 11, 1989

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