ML20245F765

Intervenors First Set of Discovery Requests to NRC Staff.* W/Certificate of Svc.Related Correspondence

ML20245F765
Person / Time
Site:	Turkey Point
Issue date:	08/07/1989
From:	Lorion J CENTER FOR NUCLEAR RESPONSIBILITY, LORION, J.
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#389-9025 OLA-4, NUDOCS 8908150062
Download: ML20245F765 (6)

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':NiC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 89 AUG 10 P4 :20

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BEFORE THE ATOMIC SAFETY AND LICENSING EpARD- ...

In the Matter of )

y Docket Nos. 50-250 OLA-4 Florida Power & Light Company ) 50-251 OLA-4

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Turkey Point Units 3 & 4 } (Pressure / Temperature Limits)

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INTERVENERS' i FIRST SET OF DISCOVERY REQUESTS TO THE NRC STAFF '

Interveners, the Center for Nuclear Responsibility and Joette Lorion, hereby serves its First Set of Discovery Requests to the NRC Staff pursuant to 10 C.F.R. 2.740 (b) and 2.741.

Most of the proposed discovery requests concern the NRC Staff's Safety Evaluation for the above captioned amendments.

1. Identify the facts, transactions and documents on which the

-- NRC Staff relies in alleging on page 1 of the NRC Safety Evaluation that "It is estimated that TP3 will reach 10 EFPY early in 1989 and TP4 will reach 10 EFPY in mid-1989".

2.

Identify 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 not all, plants in the U.S."

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( 2) 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.

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 conservative copper content to use in calculating the RTNDT and setting the P/T limits for Units 3 and 4.

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".

6. Identify the facts, transaction 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 were made with weld wire from the same heat of material but from a different flux lot than the girth welds in both reactor vessels.

7. Identify the facts, transactions and 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 L_________.- - - - - --- --- - - - - - - - -

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( 3) specimens were considered to be representative of the girth welds in both reactor vessels because flux lot number is only of minor importance in determining the sensitivity to irradiation embrittlement".

8.

Identify all 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".

9. 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 expec:ed embrittlement from one weld sample from Unit 4 does not demonstrate that the beltline material in Unit 4 is as embrittled as the sample". -

10. Identify the facts, translations 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".

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Identify the facts, transactions and documents on which the NRC Staff relies in contending that the Turkey Point units no longer have the second and third hignest PTS screening nil-

. ductility temperature for all plants as stated on page 8 of the SE.

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12. State whether the RTNDT value identified for Unit 4 in Table 1 of the Safety Evaluation was calculated based on an Charpy energy level of 30 ft-lb or a Charpy energy level of 42 ft-lb.

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13. State whether the copper content of 0.26% identified in table 2 under 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. (Refers to Safety Evaluation)

14. State whether or not the Licensee has provided documents to the NRC Staff as required by 10 C.F.R. Appendix H,Section II C, Parts 1-6 since 1985. If the answer is yes, identify all such documents provided to the NRC Staff.

15. State the reason (s) that the NRC Staff allowed FPL 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 Appendix H, Section II C.

16. Identify any and all historical documents that support the NRC Staff's claim that Unit 4's surveillance capsules T and v used a different welding flux lot number.

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17. Copies of Minutes of the April 7, 1977, meeting between the NRC Staff and FPL concerning FPL's use of Unit 3 weld metal surveillance data to predict radiation damage to Unit 4.

Respectfully submitted, y bLb (

Joette Lorion Director, Center for Nuclear Responsibility Dated: August 7, 1989 e

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~gi' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

,g g 9 p 4 ;20 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) ~

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FLORIDA POWER & LIGHT CO. )

Docket Nos. 50-250 OLA

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50-251 OLA Turkey Point Plant )

Units 3 and 4 (Pressure / Temperature Amendments)

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CERTIFICATE OF SERVICE l I hereby certify that copies of " Interveners' First Set i

of Discovery Requests to the NRC Staff" have been served on the following parties on August 7, 1989, by deposit in the United States Mail, first class, postage prepaid:

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. Brighr Steven P. Frant:

Atcmic Safety & Licensing Board Newman & Holt:inger 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 Reculatory Commission l Washington, D.C. 20555 Cffice of Secretary .

i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Janice Moore CM feq Office of General Counsel U.S. Nuclear Regulatory Commission Jgette Lorion Director, Center .or Washington, D.C. 20555 Nuclear Responsibility 7210 Red Road #217 Dated: August 7, 1989 Miami, Florida 33143

, (305) 661-216s

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