ML19351A689

Intervenors Supplemental Response to Licensee Discovery Requests,Interrogatory I.(A-B).* W/Supporting Info & Certificate of Svc.Related Correspondence

ML19351A689
Person / Time
Site:	Turkey Point
Issue date:	12/04/1989
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY
To:	FLORIDA POWER & LIGHT CO.
References
CON-#489-9589 OLA-4, NUDOCS 8912260021
Download: ML19351A689 (10)

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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]

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Unit an (Pressure / Temperature Limits)

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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

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(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

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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

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LEHIGH UNIVERSITY:

-Institute of Fracture and solid Mechanics -

Packard Lab,' Bldg. #19 '

BETHLEHEM, PENNSYLVANIA 18o15 '

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' Telephone No, (215) 758-4130 or 4133 -  !

h Fax. No. (215) 758-4024 -

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• 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.

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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.

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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

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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.

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(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

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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

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• 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

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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.

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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

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Professor of Mechanics GCS:bd l

Enclosure:

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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

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Attorney Martin H. Hodder .

1131 N.E. 86th~ Street Miami, Florida 33138

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-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.

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• 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,

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PTS to Reactor Pressure Vessels", January 21, 1982.

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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,

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/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",:

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Southwest Research Institute _ Technical Report No. 02-4221,

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UNITED STATES OF AMERICA

' NUCLEAR. REGULATORY COMMISSION l BEFORE THE ATOMIC SAFETY AND LICENSING BOARg? DEC -8 P2 :46 l

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In-the Matter'of ) s., j

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) Docket Nos. 50-250 OLA'- 1 FLORIDA POWER & LIGHT CO.- ) 50-251.0LA

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u (Pressure / Temperature Amendments) ni s and 4 i

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1 CERTIFIt.sTE OF SERVICE j

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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

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7210 Red Road #217 Dated: December 4, 1989 Miami, Florida 33143 (305) 661-2165 i s l

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