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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML19351A6891989-12-0404 December 1989 Intervenors Supplemental Response to Licensee Discovery Requests,Interrogatory I.(A-B).* W/Supporting Info & Certificate of Svc.Related Correspondence ML20247F1011989-09-0808 September 1989 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 ML20246J6971989-08-29029 August 1989 NRC Staff Response to Ctr for Nuclear Responsibility & J Lorion First Set of Discovery Requests to NRC Staff.* Bj Elliot Unexecuted Affidavit Encl.Related Correspondence ML20246J2751989-08-28028 August 1989 Licensee Response to Intervenors First Set of Discovery Requests to Licensee.* W/Certificate of Svc.Related Correspondence ML20246B9511989-08-16016 August 1989 Licensee Followup Discovery Request to Ctr for Nuclear Responsibility & J Lorion.* W/Certificate of Svc.Related Correspondence ML20245F8111989-08-0808 August 1989 Intervenors Responses to Licensee First Set of Discovery Requests to Ctr for Nuclear Responsibility & J Lorion.* Certificate of Svc Encl.Related Correspondence ML20245F7651989-08-0707 August 1989 Intervenors First Set of Discovery Requests to NRC Staff.* W/Certificate of Svc.Related Correspondence ML20245F7891989-08-0707 August 1989 Intervenors First Set of Discovery Requests to Licensee.* Interrogatories & Documents Specific to Contentions 2 & 3 Requested,Per 10CFR2.740(b) & 2.741.Certificate of Svc Encl. Related Correspondence ML20245J6021989-06-21021 June 1989 Licensee First Set of Discovery Requests to Ctr for Nuclear Responsibility & J Lorion.* W/Certificate of Svc.Related Correspondence ML20137L8791985-11-27027 November 1985 Response to Licensee Interrogatories to Ctr for Nuclear Responsibility & J Lorion.General Interrogatories Answered for Each Contention Provided.Certificate of Svc Encl. Related Correspondence ML20137L9621985-11-27027 November 1985 Response to Licensee Interrogatories to Ctr for Nuclear Responsibilities & J Lorion.Addl Info Will Be Provided When Continuing Obligation Comes to Intervenor Attention. Certificate of Svc Encl.Related Correspondence ML20138L6451985-10-28028 October 1985 First Set of Interrogatories,Requesting All Documents,Books, Repts & Papers Intended for Use in Conducting cross- Examination of Witnesses Testifying on Contention 3.W/ Certificate of Svc.Related Correspondence ML20138L8951985-10-28028 October 1985 First Set of Interrogatories to Ctr for Nuclear Responsibility & J Lorion Re Spent Fuel Pool Expansion. Certificate of Svc Encl.Related Correspondence ML20106D2111985-02-0606 February 1985 First Discovery Request That NRC Provide Documents Listed in Encl App a Re Evaluation of Reactor Vessel Matls Data for Plant Reactor Vessels.Certificate of Svc Encl.Related Correspondence ML20090C2961984-07-10010 July 1984 Response to Interrogatories.Certificate of Svc Encl.Related Correspondence ML20091C9251984-05-29029 May 1984 Interrogatories on Contentions B & D.Certificate of Svc Encl.Related Correspondence ML20079N2181984-01-26026 January 1984 Discovery Request for Documents Listed on Encl App A.W/O App.Certificate of Svc Encl ML20079P8381984-01-26026 January 1984 Discovery Request as Part of Amended Petition to Intervene. Encl App a Inadvertently Omitted from Original Discovery Request.Certificate of Svc Encl ML17340B1291981-04-22022 April 1981 Response to Intervenor MP Oncavage 810414 & 15 Requests for Production of Documents.Licensee Will Provide Documents Except in Response to Requests 3 & 5.Certificate of Svc Encl ML17340B1401981-04-15015 April 1981 Request for Production of Listed Documents.Related Correspondence ML17340B1381981-04-15015 April 1981 Request for Production of Listed Documents.Related Correspondence ML17340B0341981-04-14014 April 1981 Request for Production of Listed Documents from Licensee. Certificate of Svc Encl.Related Correspondence ML17339A6301980-02-11011 February 1980 Supplemental Responses to MP Oncavage 791027 Interrogatories & Requests for Documents,Per ASLB 800124 Order.Includes Info Re Safety Retrofitting or Backfitting & New Technologies Re Coal Project.W/Affidavit & Certificate of Svc ML17339A6271980-02-0505 February 1980 Answers to Interrogatories Per ASLB 800122 Order.Nrc Safety Evaluation & Eia Are Deficient Due to NRC Reliance on Licensee.Prepared Steam Generator Repair Rept.Certificate of Svc & Licensee Complaint Encl ML17339A4461979-12-17017 December 1979 Answers to NRC Interrogatories & Request for Production of Documents.Confirms a Bowen,W Goldberg,R Anderson, D Bridenbaugh,Kz Morgan & AR Tamplin as Witnesses.Considers Safety Evaluation & Eia to Be Deficient ML17339A4511979-12-17017 December 1979 Responses to Intervenor MP Oncavage 791027 Interrogatories & Request for Production of Documents,Per ASLB 791115 Order. Objects to Majority of Questions as Irrelevancy & Immateriality.Certificate of Svc & Affidavit Encl ML17339A3321979-11-0707 November 1979 Responses to Intervenor MP Oncavage 791027 Interrogatories & Request for Production of Documents.Objects to Majority of Questions.Aslb 790927 Order Rejected All Issues Re Steam Generator Repairs.Certificates of Svc Encl ML17339A3341979-10-27027 October 1979 Interrogatories & Request for Production of Documents Directed to Licensee.Includes Questions on Licensee Preparedness to Protect Public & Environ in Event of Steam Generator Failure.Certificate of Svc Encl 1989-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEAR3F0999-05, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines1999-09-14014 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines L-99-201, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments1999-09-0707 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Fpl Followed Development of NEI Comments on Rulemaking & Endorse These Comments ML20206H4441999-05-0303 May 1999 Comment Opposing Proposed Rules 10CFR170 & 10CFR171 Re Rev of Fy 1999 Fee Schedules ML20205J0461999-04-0101 April 1999 Comment Supporting Proposed Draft Std Review Plan on Foreign Ownership,Control & Domination.Util Supports Approach Set Forth in SRP Toward Reviewing Whether Applicant for NRC License Owned by Foreign Corp.Endorses NEI Comments ML20205B3771999-03-16016 March 1999 Comment Opposing PRM 50-64 Re Liability of Joint Owners of Npps.Util Endorses Comments of NEI & Urges Commission to Deny Petition for Rulemaking ML17355A2511999-03-0909 March 1999 Comment Supporting Amend to Policy & Procedure for NRC Enforcement Actions Re Treatment of Severity Level IV Violations at Power Reactors.Util Also Endorses Comments of NEI on Revs L-98-306, Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP1998-12-10010 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirements for Monitoring Effectiveness of Maint at NPP L-98-272, Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses1998-10-28028 October 1998 Comment on Draft Reg Guide DG-4005, Preparation of Suppl Environ Repts for Applications to Renew Nuclear Power Plant Operating Licenses L-98-252, Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule1998-10-0606 October 1998 Comment Supporting Proposed Rules 10CFR2 & 51 Re Streamlined Hearing Process for NRC Approval of License Transfers.Fpl Also Endorses Comments of NEI on Proposed Rule L-98-248, Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement1998-10-0505 October 1998 Comment Supporting Statement of Policy on Conduct of Adjudicatory Proceedings.Fpl Also Endorses Comments of NEI on Policy Statement ML17354A8741998-03-27027 March 1998 Comment Opposing Proposed Generic Communication,Lab Testing of nuclear-grade Activated Charcoal (M97978) ML17354B1061998-02-26026 February 1998 Submits Listed Requests for NRC EA Per 10CFR2.206 to Modify OLs for All FPL NPPs Until Licensee Can Demonstrate Open Communication Channels Exist Between NRC & Licensee.Also Requests EA to Address Alleged Discriminatory Practices ML20217M0751997-08-13013 August 1997 Licensee Response to Supplemental 10CFR2.206 Petitions Filed by Tj Saporito & National Litigation Consultants.Petition Provides No Basis for Extraordinary Relief Requested. Petition Should Be Denied.W/Certificate of Svc ML20217J4321997-08-0707 August 1997 Memorandum & Order.* Grants Staff Petition for Review & Reverses Presiding Officer Decision Requiring Staff to Issue Tetrick SRO License.Order Disapproved by Commissioner Diaz. W/Certificate of Svc.Served on 970807 ML20148P8461997-06-25025 June 1997 Memorandum & Order (Determination of Remand Question).* Concludes That Presiding Officer Reaffirms Determination That Response of Rl Tetrick to Question 63 of Exam to Be SRO Was Incorrect.W/Certificate of Svc.Served on 970626 ML17354A5521997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, CR Insertion Problems. ML20141F5441997-06-13013 June 1997 NRC Staff Response to Presiding Officer Memorandum & Order (Questions Relevant to Remand).* Staff Submits That Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam Should Be Denied ML20141F5711997-06-13013 June 1997 Supplemental Affidavit of B Hughes & Ta Peebles.* Affidavit Re Tetrick Request for Reconsideration of Grading of Question 63 on SRO License Written Exam.W/Certificate of Svc ML17354A5181997-05-27027 May 1997 Licensee Response to 10CFR2.206 Petition Filed by Tj Saporito & National Litigation Consultants.Petition Should Be Denied,Based on Listed Info.W/Certificate of Svc ML20148G6531997-05-27027 May 1997 Notice.* Forwards Documents Received & Read by Author from Rl Tetrick on 970317 W/O Being Served as Required Under Procedural Rules.W/Certificate of Svc.Served on 970527 ML20148G7071997-05-27027 May 1997 Memorandum & Order (Questions Relevant to Remand).* Rl Tetrick May Respond to Questions W/Filing Served Pursuant to Procedural Regulations W/Notarized Statement to Be Received by 970617.Certificate of Svc Encl.Served on 970527 ML20148G7501997-05-20020 May 1997 Memorandum & Order CLI-97-05.* Staff May Withhold Issuance of SRO License to Rl Tetrick Pending Further Order of Commission.W/Certificate of Svc.Served on 970520 ML17354A5631997-05-17017 May 1997 Second Suppl to 970423 Petition Requesting Enforcement Against Listed Util Employees by Imposing Civil Penalties, Restricting Employees from Licensed Activities & Revoking Unescorted Access ML20141C7331997-05-16016 May 1997 Order Extending Until 970616,time within Which Commission May Rule on NRC Staff 970416 Petition for Review of Presiding Officer Initial Decision.W/Certificate of Svc. Served on 970516 ML17354A5611997-05-11011 May 1997 Suppl to 970423 Petition Requesting Enforcement Action Against Util Former Executive Vice President,Site Vice President & Maint Superintendent by Imposing Civil Monetary Penalty ML20138J2331997-05-0202 May 1997 Affidavit.* Affidavit of B Hughes Re Denial of Application for SRO License for Rl Tetrick.W/Certificate of Svc ML20138J2271997-05-0202 May 1997 NRC Staff Response to Questions Posed in Commission Order of 970425.* Staff Respectfully Submits That Commission Should Undertake Review of Presiding Officer Decisions in Proceedings LBP-97-2 & LBP-97-6 ML20138J2241997-05-0202 May 1997 Line (Providing Omitted Citation).* Informs That Submitted Citation Inadvertently Omitted from Response to Questions Posed in Commission Order of 970425.W/Certificate of Svc ML20138J2401997-04-25025 April 1997 Scheduling Order.* Staff Instructed to File W/Commission,By COB 970502,response to Tetrick Argument Re Question 63 & Discussion of Legal Significance of Consistent Staff Practices.W/Certificate of Svc.Served on 970425 ML17354A5651997-04-23023 April 1997 Requests That NRC Take EA to Modify,Suspend or Revoke FPL Operating Licenses for All Four Nuclear Reactors Until Licensee Can Sufficiently Demonstrate to NRC & Public That Employees Encouraged to Freely Raise Safety Concerns ML20137X5921997-04-16016 April 1997 NRC Staff Petition for Commission Review of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Undertake Review of Presiding Officer Decisions in Proceeding.W/Certificate of Svc ML20137X5511997-04-11011 April 1997 NRC Request for Issuance of Order Staying Effectiveness of Presiding Officer Decisions in Proceeding (LBP-97-2 & LBP-97-6).* Commission Should Stay Effectiveness of Decision in Subj Proceeding.W/Certificate of Svc ML20137R3531997-03-27027 March 1997 Correct Copy of Memorandum & Order (Denial of Reconsideration,Stay).* Denies NRC Staff Motion for Reconsideration.W/Certificate of Svc.Served on 970327 ML20137F5551997-03-25025 March 1997 NRC Staff Response to Memorandum & Order of 970321.* Presiding Officer Should Grant Staff 970310 Motion for Reconsideration.W/Certificate of Svc ML20137F8251997-03-21021 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Orders That Effect of Initial Decision Postponed Until Close of Business on 970326.W/Certificate of Svc.Served on 970321 ML20137F5081997-03-17017 March 1997 NRC Staff Motion for Issuance of Stay.* Requests That Presiding Officer Deny NRC Staff Request for Issuance of Stay in Matter of Issuance of SRO License ML20137F5371997-03-17017 March 1997 NRC Staff Motion for Reconsideration in Matter of Rl Tetrick.* Requests That Presiding Officer Deny NRC Staff Request for Reconsideration ML20136F2981997-03-12012 March 1997 Memorandum & Order (Grant of Housekeeping Stay).* Informs That Initial Decision Issued by Presiding Officer on 970228 Postponed Until 970321 & Rl Tetrick May File Response by 970318.W/Certificate of Svc.Served on 970312 ML20136F2351997-03-10010 March 1997 NRC Staff Motion for Reconsideration Introduction.* Requests That Presiding Officer Reconsider Determination That Tetrick Passed Written Exam & Find,Instead,That Tetrick Failed Written Exam ML20136F3411997-03-10010 March 1997 NRC Staff Request for Issuance of Order Staying Effectiveness of Presiding Officers Initial Decision LBP-97-2.* Staff Submits That Presiding Officer Should Stay Effectiveness of Initial Decision.W/Certificate of Svc ML20136F2721997-03-0606 March 1997 Supplemental Affidavit of B Hughes.* Supports Staff Motion for Reconsideration of Presiding Officer Initial Decision of 970228.W/Certificate of Svc ML20138Q0191997-02-28028 February 1997 Initial Decision.* Concludes That Rl Tetrick Had Passing Score of 80% & Should Be Granted License as Sro. W/Certificate of Svc.Served on 970228 ML20134A6551997-01-23023 January 1997 Written Presentation of NRC Staff.* Staff Concludes That SE Turk Failed Written Exam & Did Not Establish Sufficient Cause to Change Grading of Answers to Listed Questions. Denial of Application for SRO License Should Be Sustained ML20134A6661997-01-23023 January 1997 Affidavit of B Hughes & Ta Peebles Re Denial of Application for SRO License.W/Certificate of Svc.Served on 970124 ML20129J5681996-10-23023 October 1996 Memorandum & Order (Error).* Informs of Incorrect Caption Identified in Order .W/Certificate of Svc.Served on 961023 ML20129D4981996-10-21021 October 1996 Memorandum & Order (Grant of Request for Hearing Scheduling).* Requests for Hearing Hereby Granted. W/Certificate of Svc.Served on 961021 ML20129D6681996-10-18018 October 1996 NRC Staff Answer to Rl Tetrick Request for Hearing.* Staff Does Not Oppose Request & Will Be Prepared to Submit Hearing File.W/Certificate of Svc & Notice of Appearance ML20129D4401996-10-0909 October 1996 Designating of Presiding Officer.* Pb Bloch Designated to Serve as Presiding Officer to Conduct Informal Adjudicatory Hearing in Proceeding of Rl Tetrick Re Denial of SRO License.W/Certificate of Svc.Served on 961010 ML17353A6311996-01-19019 January 1996 Decision & Remand Order Re FPL Discrimination Against RR Diaz-Robainas.FPL Ordered to Offer Reinstatement to RR Diaz-Robainas W/Comparable Pay & Benefits,To Pay Him Back Pay W/Interest & to Pay His Costs & Expenses Re Complaint ML17353A2471995-06-27027 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style. 1999-09-07
[Table view] |
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- EATED CORRESPONOENqg c us rrt.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-
'69 [E -8 P2 Z6 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ;
In the Matter of )
FLORIDA POWER &' LIGHT COMPANY )
) Docket Nos.5 5 ]2500A]
Unit an (Pressure / Temperature Limits)
)
INTERVENORS' SUPPLEMENTAL RESPONSE TO LICENSEE'S DISCOVERY REQUESTS, INTERROGATORY I.(A-B)
Intervenors, the Center for Nuclear Responsibility and ,
Joette Lorion, hereby serve their Supplemental Response to Licensee's Discovery Requests, Interrogatory I. (A-B).
INTERVENORS' SUPPLEMENTAL RESPONSE TO INTERROGAORY I.A:
Intervenors intend to call Dr. George Sih, Director of Fracture Mechanics, Lehigh University, as an expert witness at hearing should the Board grant Intervenors' Motion to Modify Hearing Schedule filed on December 4, 1989. Dr. Sih's address is: Dr. George Sih, Institute of Fracture and Solid Mechanics, Packard Lab Building #19, Bethlehem, Pennsylvania 18015.
INTERVENORS' SUPPLEMENTAL RESPONSE TO INTERROGATORY I. B:
Dr. Sih will provide expert testimony in support of Intervenors' Contention 2 which contends that the use of test data from Unit 3 to calculate the ART and set revised PT limits for Unit 4 8912260021 891204 PDR ADOCK 05000250 0 PDR OSo3
+
(2) is not valid and could result in pressure / temperature limits being set for Unit 4 that are non-conservative which in turn could' threaten the integrity of the Turkey Point Unit 4 reactor -
vessel.
Dr. Sih's specific views on the issues addressed by Intervenors' Contention 2 are contained in the letters attached ,
to Intervenors' Supplemental Response, r i
Sincerely,,
7% b C' Joette Lorion Director, Center for Nuclear Responsibility .
7210 Red Road #217 Miami, Florida 33143 (305) 661-2165 Dated; December 4, 1989
m .- .
i LEHIGH UNIVERSITY:
-Institute of Fracture and solid Mechanics -
Packard Lab,' Bldg. #19 '
BETHLEHEM, PENNSYLVANIA 18o15 '
1
' Telephone No, (215) 758-4130 or 4133 - !
h Fax. No. (215) 758-4024 -
G. C. Sih Director Fax: (305)667-3361 October 18. .1989 ~ ,
.Ms. Joette Lorion -
Center for Nuclear Responsibility .'
7210 Red Road, Suite 217 Miami, Florida 33143 .
RE: TurkeyPointNuclearPowerPlantIntegratedSurveillanceProgram(ISP). ;
Document A. Affidavit of Stephen A. Collard on Contentions 2 and 3 by FPL. r Document B. Licensee's Response to Intervenors' First Set of Discovery Re-quests to Licensee (August 7, 1989).
Dear Ms. Lorion:
Based on the package of documents you mailed me on the Turkey Point Nuclear Power Plant Integrated Surveillance Program, I find that the unit 3 data are-in-complete-and not sufficient to predict the P/T limits for unit 4. Additional factors such as strain rate and load-history dependent damage accumulation should be ' considered; they cannot be discussed on an ad hoc basis without analytical and/or experimental support.
The following comments refer to documents A and B referenced above.
(1) Pressure /TemperatureLimit(DocumentA-SectionIB7,8and9onpp.7 to 9 inclusive).
While the P/T limits depend on the combined effects of material properties, operating temperature and neutron irradiation as mentioned on p. 7, change in 4.ttain ra,te c can significantly affect the fracture toughness and ART This NDT.
influence has not been taken into account in determining the P/T limits.
The supporting argument for measuring fracture toughness from the Charpy V-notch tests is not conclusive because fracture toughness is strain rate dependent and cannot be adequately described by the work done in ft-lbf . Work done per unit L time or ft-lb /sec f is the relevant quantity in determining damage thresholds.
This is illustrated in Table 1 for the HY-80 casting material. Note that the four p cases considered are the same in ft-lb f but the applied strain rates are different.
L The smaller weight 30 lb f falling through a larger distance 8 ft identified as Case l
IV giving rise LO a higher strain rate. Comparing with Case I, a small increase in strain rate by a factor of 1.1 can lead to almost four (4) times reduction-fracture toughness (dW/dV)c which is related to K lc by the relation
i October 18, 1989 Ms.-Joette Lorion Table l. Influence of Strain Rate on Yield Strength and Fracture Toughness Determined E-23 for HY-80 fromCastingThree-Point Material., Ref.Bent Sp(ecimen G..C. Sih and D. Y.asTzou, Specified by
" Dynamic Fracture Rate of Charpy V-Notch Specimen", Journal of Theoretical and Applied Fracture Mechanics, Vol. 5, pp.189-203, 1986).
Yield Strength Critical Energy Case No. Strain Rate Density (ftlb) i(sec-l) "ys(ksi) f (dW/dV)c(ksi) 78.28 24.46 I (1 x 240) 70.36 79.15 15.70 II (2 x 120) 74.00 80.02 10.08 III (4 x 60) 74.80 80.90 6.47 IV (8 x 30) 77.36 (1+v)(1-2v)K2
)c* 2nr cE The where v and E are, respectively, the Poisson's ratio and Young's modulus.
last ligament of material that triggers fast fracture is rc '
The local strain rates in the reactor vessel where defects prevail can be l a two-dimensional, if not three-dimensional, non-4 high and cannot be known unles:: No confidence can be placed I- linear elastic-plastic stress analysis is performed.
i in determining P/T limits unless the influence of local strain rates on the frac-1 ture toughness of reactor vessel materials is accounted for or shown to be other-i- wise. This effect cannot be dismissed on an ad hoc basis because it affects l calculations of ART, aRTNDT, etc.
J (2) Neutron Irradiation (Document A - Section IIIB 61 to 65 inclusiv pp. 42 to 44).
y 2 Referring to the data on neutron fluence (n/cm ) in Table 5 17 on n/cm2(life
- p. 43, it is
}
not sufficient to draw conclusions from the difference of 3.6 x 10 time) and 2.37 x 1017 n/cm2 (1985-90) between unit 3 and 4 based Material degradation caused by neutron irradiation being accumulative is a time-It would be more informative to investigate history and rate dependent process.
jl the rate
- at which the neutron fluence is accumulated in time on monthly or at
'l,
- The materials on p.14 of Licensee's Motion for Sumary Disposition of Inter-venors' Contentions state that -- "the rates or durationThis of statement accumulation not important in considering the effects of neutron irradiation.
appears to be in contrast with one of the most important unit nyt for measuring 5, irradiation damage of material. Here, n stands for theeffect Rate number of neutrons is reflected by vper and cm3 , y the velocity in cm/sec and t the time.
and duration by t.
Ms. Joette Lorion October 18, 1989
'least yearly-basis. This point will be highlighted in relation to EFPH.
Damage accumulation is a highly nonlinear process. Predictions based on the 4Lnemt 4um is not always conservative. The data in Table 5 are not supportive of the integrated surveillance program.
(3) Annual EFPH (Document B - Section on Licensee's Response C on p.11). !
A case in point on the influence of rate effect can be illustrated by the annual EFPH data on p.11 which is summarized in Table 2. Although the differ-Table 2. Annual EFPH for Turkey Point Unit 3 and 4 from 1985-88.
Year Unit 3 Unit 4 % Deviations 1985 5,032.5 7,706.5 + 53.1 1986 6,652.9 2,601.8 - 60.9 1987 1,344.6 3,950.2 +193.8 1988 5,176.3 4,828.9 - 6.7-18,206.3 19,087.4 + 4.8 ence in the total operating time between unit 3 and 4 is only +4.8%, the devia-tions on a yearly basis are enormous. A graphical representation of the data in Table 2 can be found in Figure 1. Unit 3 behaved very differently from unit 4; it possessed a slow down period. The two curves intersected at P between '
1986 and 1987 aside from the initial crossing. An overestimate would result to the left of P and underestimate to the rignt of P should the data of unit 3 be applied to predict that of unit 4. The net damage would not add and subtract as in arithmetic. n In general, Turkey Point Unit 3 and 4 do differ in their load history. The infonnation supplied by the ISP is not sufficient to conclude that the unit 3 data could be used to predict the behavior of unit 4.
Very sincerely yours,
.,N&{ ! h,.
, George C'.'Sih Professor of Mechanics GCS:bd l
Enclosure:
Figure 1 l
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,s ,
1
.20 -
o Unit 3 e Unit 4 ,
/ :
15 7
E "o -- p ./
W x
b i
/
10 _.
/ Slow down period for Unit 3 5_ 4 a-2 I i i 1986 1987 1988 l:.
1985 Figure 1. Data reproduced from section (c) on page 11 of Licensee's Response to Intervenors' First Set of Discovery Requests to Licensee (Au-gust 7,1989): Docket Nos. 50-250 OLA-4 and 50-251 OLA-4.
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LEHIGH-UNIVERSITY Institute of Fracture and Solid Mechanics Packard Lab. Bids. #19 .
BETHLEHEM. PENNSYLVANIA 18015 -
Telex No. Lehigh Univ. UD 710 670-1086 G.C.Sih Director October 10, 1985
^
Attorney Martin H. Hodder .
1131 N.E. 86th~ Street Miami, Florida 33138
-RE: Turkey Point Nuclear Power Plant Unit No. 4: Reactor Vessel Embrittlement
-and Surveillance Program
Dear Attorney Hodder:
g In response to your letter dated August 29, 1985 and the above referenced subject matter, I have read the package of documents on the RPV embrittlement program at Turkey Point Unit No. 4. A number of supporting arguments with ref-erence to the. calculation 'of ARTNDT are questionable, if not invalid from the scientific view po. int. In what follows, the SWRI report and the FPL letter shall be referred to as [1]* and [2]**, respectively.
(i) SWRI Prediction [1]
Based on the RPV material surveillance methodology, SWRI [1] estimated the shift- in RT NDT for Turkey Point Unit No. 4. The results pertaining.to wall locatier.1/4T based on the data of Capsule T in terms of EFPY are sumarized graphically on the sheet attached to this letter. The shift in RT NDT is found to be a:oroximately 324*F at 8 EFPY. This is beyond the NRC screening value of 300 F.
E. B. Norris, " Reactor Vessel Material Surveillance Program for Turkey Point Unit No. 4: Analysis of Capsule T", Southwest Research Institute Technical Re-port Nc. 02-4221, June 1976. '
Letter, Uhrig, FPL, to Eienhut, "Re: Turkey Point Unit 4, Docket Nos. 50-251, PTS to Reactor Pressure Vessels", January 21, 1982.
1 1
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..\
(2) FPL Response [2]
With reference- to the material in Docket No. 50-251 on PTS of RPV as statedin[2],alowerART value of 211'F was obtained for Unit No. 4. This NDT l result, however, was obtained by application of the surveillance data taken from 1 Turkey Point Unit No. 3. The justification was that the metallurgical properties of.the beltline welds of the Turkey Points Units No. 3 and No. 4 are the same and that data on Unit No. 4 are not sufficient. '
(3) Comments !
The rate at which the beltline weld material deteriorates and/or em-brittles depends on the combined effects of irradiation and pressurized thennal shock. It is plant-specific in the sense that the influence differs inherently from one unit to another. In other words, the metallurgical properties alone cannot determine the damage behavior of the welds. The iceding hi4. tony plays a major role. Unless the rates of irradiation, fluctuations in thermal gradients and time variation in pressure are exactly the same for both Units No. 3 and No. 4, one is not-justified to assume that data collected in Unit No. 3 could i be applied to predict the behavior of Unit No. 4. Hence, conclusions drawn on ART NDT for Unit No. 4 based on the data of Unit No. 3 cannot be considered valid.
I will not delve into the other details concerning the actual calculation of ART NDT as they are beyond the scope of our imediate concern.
j Very sincerely yours,
/George/4 A N'gJrhp C. fh Professor of Mechanics GCS:bd Enclosure 1
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L Data Reproduced from Table: on Page 31at Wall Location.1/4T,'
Report by E. B. Norris, " Reactor Vessel fiaterial Surveillance- -!
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Program for Turkey Point Unit No. 4:- Analysis of Caosule T",:
.;
Southwest Research Institute _ Technical Report No. 02-4221,
-June 1976..
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UNITED STATES OF AMERICA
' NUCLEAR. REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOARg? DEC -8 P2 :46 l In-the Matter'of ) s., j
'"^ '4 f ;
) Docket Nos. 50-250 OLA'- 1 FLORIDA POWER & LIGHT CO.- ) 50-251.0LA
-)
u (Pressure / Temperature Amendments) ni s and 4 i 1
CERTIFIt.sTE OF SERVICE j I hereby certify that copies of "Intervenors' Motion to f Modify Hearing Schedule" and "Intervenors' Supplemental Response ~
to Licensee's Discovery Requests, Interrogatory I. ( A-B) " have been served on the following parties by deposit in the United 3 States Mail, First Class, Postage Prepaid on the date shown !
below: i
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. Frant:
Atomic Safety & Licensing Board Newman & 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 g
- Janice Moore l
Office of General Counsel Joette Lorion U.S. Nuclear Regulatory Commission Director, Center for Washington, D.C. 2050s Nuclear Responsibility 7210 Red Road #217 Dated: December 4, 1989 Miami, Florida 33143 (305) 661-2165 i s l
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