ML20008G156

Interrogatories Directed to Il Power Co Per First Round of Discovery Re Contentions 1-11.Certificate of Svc Encl

ML20008G156
Person / Time
Site:	Clinton
Issue date:	06/26/1981
From:	Samelson A PRAIRIE ALLIANCE
To:	ILLINOIS POWER CO.
Shared Package
ML20008G150	List: ML20008G149 ML20008G155 ML20008G156 ML20008G160 ML20008G166
References
ISSUANCES-OL, NUDOCS 8107020370
Download: ML20008G156 (22)

Text

,N .

U

- CNITED STNIES OF AMERICA NUCIDR RK;UIAICIE CCNMISSION In the Matter of )

)

ILLIICIS POWER CQ4PANY et al. ) Docket Nos. 50-4610L

) 50-4620L (Clinton Power Station Units 1 and 2) )

PRAIRIE ALLM'S FIRST 100ND OF DISCOVERY

'IO ILLINDIS POWER QJMPANY, et al.

Pursuant to 10 CFR 2.740b of the Nuclear Regulatory Camission's regulations, Prairie Alliance requests that Illinois Power Capany (IP) answer the attached interrogatories fully, to the best of .aeir knowledge, in writing, and under oath, and that the answers be signad by the person (s) making than.

In addition, pursuant to 10 CFR 2.741, Prairie Alliance requests that IP produce and permit Prairie Alliance to inspect and copy designated dcv'_wnts in p ssession, istody or control of IP.

Each quesdon shal'1 be answered as follows:

1. Provide the direct answer to the question.

2. Provide hwnts, including research, sttriies, calculations, menoranda, correspondence, reports, diagrams, cmputer codes, and all other records, that were relied upon by IP in answering the question, and also those which serveci as the basis for the answer. Identify the particular parts of such dev' = nts that were used in fr-lating the answer.

3. Identify by name, title, and qmlifications the IP etployee that has the expert knowledge required to support the answer to the question.

4. Explain whether IP is presently engaged in or intends to engage in any )

further research or work which may affect the answer. Identify such research i or work.

5. State the names, addresses, titles, and qualifications of the persons IP intends to call as witnesses or experts for the answer and the subject matter which they intend to testify about. l c , ,; , .

. o + ,, ,

.,,3 4

• " 0 " " M ._.

\

6. Pfovide the cmputer codes, in machine readable source code, of any ccuputer mndala or similations relevant to the question asked.

i l

1

..,,.,,.,,6...,,, .,,

x , .a '. . , , , a rv, ..

n. . . . . , , , , ,

.-. - . . , , - _ - . - - . ~ . . . . . - . . . _ _ _ - _ , . , _ . , _ . - - . . . _ . . - _ - .

. i INTERROGMDRIES Contmtion 1

1. Provide a ccmplete copy of the Empcy Plan proposed for the C.P.S.

2. Provide all internal menoranda, studies and reports, including calculations, which analyze or determine the plune E.P.Z. and the ingestion E.P.Z. for.the C.P.S.

3. Provide mpies of all studies, reports, da'w=nts and internal memoranda which di m a, supplement or update the empcy plan delineated in

the F.S.A.R.

4 4. (regarding contention 1(a)(1)) St.te what actions if any are proposed to i effect termination of activities at outdoor recreational facilities within the plune E.P.Z. and the ingestion E.P.Z.

l (a) Identify by name each outdoor recreational facility for which such

' acticms are proposed; (b) Specify the nunber and types of recreational uses expected to be involved in such actions; i

(c) Specify the estimated maximzn and mininum nunbers of the public expected,to be involved in such actions; .

(d) Specify the razrbers and qtmlifications of C.P.S. personnel expected .

to be involved in such actions; (e) 9wify the raznbers and qmlifications of the emergency planning Emmuel exp ci.ed to be invol 31 in the planning of such actions; (f) Describe with specificity, e.g. by brand name, type, manufacturer and the 13ke, the types of equipment proposed to be utilized for such acticns; (g) Specify the estimated time required for the acocmplishnent of such actions; (h) Specify whether there will be any pre-operational rehersals for such actions; (i) Identify all local and state agencies which will be involved in -

such actions; (j) Provide an estimate of the mst of such actions and identify the l

party or parties responsible for the payment of these costs.

l.

,s'  ?. ~ l A ;, **

• i - &'-

. Y ,'y h ' * . .

• 4 ,. y ? o, ,, .

' = ,,>,; , .

- . - . - - . . , , . - , - , ,, - , . . . , , , , - - . - - . . . . - , - - - , - - - - . ,-----...-.,..------.-,--.-e.~. - ,,-v -..,,-. - ,-,, ~ ,,,.- - -c., - n

l 5 (regarding aantention 1(a) (2) .) State what' actions if any are proposed j to effect proper energency responses at the special facilities described i in contention #1(a) (2) . l 1

(a) Identify by name each special facility for which such actions are l planned; (b) Specify the number of people expected to be involved at each such '

action at each such facility;.

(c) Specify the estimated maximum and minimum numbers of the public expected to be involved in such actions; (d) Specify the numbers and qualifications o!! C.P.S. personnel expected to be involved in such actions; l

l l (e) Specify the numbers and qualifications of the energency planning personnel expected to be involved in the planniry of such actions; (f) Describe with specificity, e.g. by brand name, type, manufacturer and the like, the types of equignent pmposed to be utilized for such actions; (g) Specify the estimated time required for the accanplishment of such .

actions; (h) Specify whether tha.re will be any pre-coerational rehersals for -

• such actions; ,

(i) Identify all local and state agencies which will be inv>1ved in l such actions; l

(j) Provide an estimate of the cost of such actions and i'lentify the party or parties responsible for the payment of these costs.

6. (regarding 1(a) (3)) State what provision if any is m Me in the C.P.S.

Energency Plan for such severe weather conditions as may be expected in the site vicinity and plume and ingestion EPZF throughout the year.

(a)

Describe the types of severe weather corditions which IPS has anticipated to occur in the CPS site vicinity and the plume and ingestion EPZs.

(b)

Describe in detail what problems or impediments each such weather corxiition poses for energency planning at the CPS.

(c)

Describe what actions are planned, if any, to deal with each severe weather condition listed in response to (a) above.

(d) Specify the estimated maximum and minimum numbers of the public expected to be involved in such actions;.

(e) Specify the numbers and qualifications of C.P.S. personnel expected to be involved in such actions; k

r, ,

.: , ::, ,, .. , . . , , . . ,; .. y

F

. L-(f) Specify the numbers and qualifications of the energency planning pe. m l expected to be involved in the planning of such actions; (g) Describe with specificity, e.g. by brand name, type, manufacturer and the like, the types of equignent proposed to be uM14 =1 for such actions; (h) Specify the estimated time required for the acomplishment of such actions; 1 .

(i) Specify whether there will be any pre-operational rehersals for such actions;

! (j) Identify all local and state agencies which will be involved in such actions; (k) Provide an estimate of the cost of such actions and identify the party or parties responsible for the payment of these costs.

7. Identify all state and local agencies with whan IPC has executed or intends to execute agreenents in the area of emergency planning and response actions.

(a) Identify the person in each named agency with whan IPC has had principal contact; (b) Produce all agreenents IPC has executed to date with each namrd ,

agency; I

(c) State w' hen IPC intends to execute sa teenents with all agencies listed in response to Interrogatory #4 a'~ve.

(d) Identify the person (s) responsible for executing such agreements I with local and state agencies.

(e) Provide copies of all camunication with such agencies in regard to such existing or proposed agreements.

< 8. (regarding contention 1(c)) Describe,or outline, and provide a'dtv - ntary evider of the eT=.u.yency Weiures training to be provided for local services perscnnel.

(a) Identify by agency or organization all local personnel for whan sn;h tcsining is plan ud; (b) State een that training will be providad and how often it will be i provident (c) Identify who if any one 1 responsible for training local services personnel in energency p3 anning and response action.

S

f. y j a ,., ,, .- 9 ,. . ',e u . , . , , , , , , . . , , ,

.~ . - .- .,. ..-. .-.,. ..--.- - - - ... - - -- , - .. - . - . - . - -

(d) State the number of people anticipated to be involved in such training; (e) State the cost of providing such training and identify the party or peJ.es who~will be responsible for such mst.

9. (regarding entention 1(c)) Describe, or outline, and provide h_mntary evidence of the training plans for all accident assessment personnel and the "Dnergency Respcxuie Organization".,

(a) Identify by agency or o"ganization all local personnel for whczn such training is planned; (b) State when that training will be provided and how often it will be provided; (c) Idertify who if anyone is responsible for training local services personnel in energency planning and, response action.

(d) State the number of people anticipated to be involved in such training; i

(e) State the cost of providing such training and identify tha party '

or parties who will be responsible for such cost.

~

10. (regarding contention 1(c)) Describe or outline and provide ,h=ntary evidence of the provisions if any, which have been or are being made for energency preparedness training of security personnel at the CPS. -

(a) Identify all pw.w ael by name or by position for whom such training is planned.

(b) State when that training will be provided and how often it will be provided; f

l (c) Identify who if anyone is responsible for training local services pechael in emergency planning and response action.

(d) State the nLunber of people anticipated to be involved in such

! training; l (e) State the cost of providing such training and identify the party l

or parties who will be responsible for such m st.

11. (regardingcontention 1(c)) Describe or outline ~ and provide documentary evidence for a radiological orientation training program for local services perscinel, including news d ial persons.

(a) Identify by agency or organization all local personnel for whczn such training is planned; l

(b) State when that training will be provided and how often it will be provided; ,

i s ,

• • '< 4 y 1 " , * *p .% , . ,.e,, o ,

I

l. _

(c) Identify who if anyone is responsible for training local services personnel in emergency planning and response action.,

(d) State the number of people anticipated to be involved in such training; (e) State the cost of providing such training and identify the party or parties who will be responsible for such cost.

12. Describe or outline the suu.Sency preparedness training to be provided for local services personnel.

(a) Identify oy agency or organization all local personnel for whan such training is planned;

.b) State when that training will be provided and hcw oftern it will be provided; (c) Identify who, if anyone, is responsible,for training local services personnel on sau.yacy planning and response action.

(d) State the nunber of people anticipated to be involved in such training; (e) State the cost of providing such training and who will pay for the costs involved;

13. (regarding contention 1(dl) Identify and describe the items listed .in' contention

- #1(d) (1)-(8) . If no response is provided, state when, if ever, each its will be provided.

14. (regarding contention 1(e)) State ahd describe what actions will be taken to assure isolation of people fran the plume and ingestion EPZz in case of an offsite or general mergency or other serious accident: For each such acticn state the following:

(a) The number of w=u.gency response personnel to be involved; (b) The criteria for de+ambing when each such action shall be taken; (c) The expected number of people in the general population to be l involved; j

(d) The time duration for inplanenting each action; I (e) Whether pre-operational rehersals will be held for each action; i

i (f) Whether the public wilh. be involved in each such rehersal.

I 15. (regardinJ contention 1 (f)) Provide all documentation concerning provisions for following mergency support facilities:

1

! (a) Technical Support Center (b) Operational Support Center i

f, (c) E'argency Operations Facility (d) Safety Parameter Display Syst(sn ,

,) gg gg, ,,

t , . ,. , : 3 . . , , , . ,

I In each facility's du'=antation include:

(1) Current status of provision g % .u, includig degree of cmpletien achieved to date; (2) Expected ocmpletion date, (3) PE9 -wal staffing information, including ntxnber of perscnnel, name of positions, qualifications required.

(4) Prospective personnel.

S 8

e 8

O 8

e i

l l

l l

l 'aC , ,"J A. - i. 4;.4 )> .. , ,

, ; *, ; -f ., , . g. ',-

,. A . . , , ,

,,=,

. . . . - _ . . , . . , _ . , _ _ . _ _ , _ _ _ - - _ - - . , _ . . _ - ~ , . . . . , _ _ . - , _ . _ . _ _ _ . _ _ _ _ _ _ , , ,_ - ,.__,,, . . _ ,

I Centention 4 ,

1. In order to satisfy the employment suitability criteria of 10 CFR 73 Appendix B, (a) Specify the aptitude tests to be administered to security personnel 1 applicants; I (b) Specify the criteria developed to assess thoce " felony convictions that reflect on the individual's reliability";

(c) Specify those felony convictions which would not be considered as reflecting on the individual's reliability.

2a. How many central alarm stations will there be?

b. Will each central alarm star. ion be equipped with an independent power source in the event of power outage?

c. Will the doctors who perform the examinations of security personnel be IP splayees, independently enployed, or enployees of contract security ccrupanies?

)

d. What assurances are there that ccuplete medical histories can be obtained on all applicants?

3. Pursuant to 10 CFR Part 73 Appendix B(2)(c) (mental qualifications) specify the methods to be enployed in the " continued observation of security personnel". , ,

4. Will an enployee be notified when he is the subject of,other 'than reutine observation?

5. Does continued observation involve o.-site observation only?

6. What actions observed in on site observation are to be construed as indications of motional stability?

7. On what basis have such actions been so classified? .

c. If no actions have been so classified how will the en site determination be made?

9. Will off site observation of personnel be a part of the " continued observation" raquired by Appendix B?

10. If so what criteris have been developed to indicate when off site observation should be instituted?

11. What is the basis for such criteria? -

12. Who was responsible for the develognent of these criteria and what qualifications and experience do they possess?

,, ; '. =c '

, ,, 8 r;. : .c- *R.,.

. ,p .. .;,,l*., .>. .

?') e,.. , ,, .u , d a:

13. If no such criteria have been developed how and by whcm will the decision be made to ihstitute off site observation?

14. What" appropriate cocrectiva measures"are proposed by IP" pursuant to 10 GR 73.55, App B 2c?

15. Who will dec'da on the. measures to be taken and what qualifications will be required of such personnel?

16. Nhat qualifications wl.11 be rquired of " responsible supervisors"?

17. What additional training will they receive to fit them for their task?

18. Will " licensed trained perscnnel" be eroployees of IP? If not what will be their relationship to IP?

19. What cypes of off site observation are proposed?

20. Will non-plant exployees be placed under observation because of their association with a plant etployee under observation?

21. What safeguards will be crployed to ensure that observation will not be used as a form of sexual harrassment?

22. Has IP developed a program for assessing the suitability of contract security personnel?

23. If such a program has been developed, provide a detailed description of it,

24. If no such program has been developed, is one being developed?

j

25. If the answer to 24 is yes, identify by rame and position the persons responsible for this work.

26. What are their qualifications for this work and what is their experience in this type of work?

i

27. If no such pwp.mn has been or is being develoyd, how does IP intend to satisfy the requirements of 10 GR Part 73 Appendix B 1.D.?

28. Does IP intend to investigate or judge the rwHng habits, political or religious beliefs, or attitudes on social econmic or political issues of any applicant for a position as a mernber of the security I

personnel at CPS?

l

29. Does IP intend to seek the applicants permission to make such investigations?

30. Where such invust.igations are made, will the applicant be providcd with a copy of the results of same?

31. If such investigations are not intended, how will IP guard against violent extremists frm gainirs e 'ployment as security personnel at CPS?

 :, i: v o. . < ,. , r a,m 7 s .

, c r ...; '- ,

. _ _ - . _ . _ . . _ . ._,_ , _ _ , _. . ~. - _ . . _ _ _ ,_.__. . _ _ _ _ _ _ . . . _ _ . . _ _ - - . . _ . ,

4

32. If such investigations are demed to be neccessary who will authorize th e , what position will they hold in IP, whet will be their qualifications and experience, and what criteria will be used to determine when such investigation is de m ed necessary!

33. Will IP seek the cocpa & tion of local state and federal law enforcernent agencies in making such investigations?

34. Have any diviaicns, negotiations or meetings taken place between IP and any law enforca. u nt agency to discuss the question of IP obtaining the assistance of such agency in either the develognent or operation of the program to meet the requirements of 10 T R Part 73 App. B.?

35. Describe each such meeting, listing the parties involved, the matters di=saad and the conclusions reached. Provide dcv'm=ntary records of these meetings.

36. Have procedures been developed to determine when the assistance of local state or federal law enforcernent should be sought in implementing

" continued observaticn" of security personnel?

! 37. With reference to the FSAR 1.8-25, why was the plant security system not considered a safety related system?

38. Who made this determination?

39. Pursuant to CPS-FSAR reg Guide 1.117 Rev 1 (1973) list all electronic cr= m nants purchased for the security systs.

40. Define the function of each such cmpontent.

I

41. What was, (and provide an it=49ad breakdown of), the cost of the electronic u - nents purchased for the security system?

42. How many suppliers were electronic equignent purchased frcm?

43. Who were these suppliers?

44. Was em petitive bidding sought and obtained prior to the purchase of such equignent?

! 45. Explain why IP feels that it is entitled to deviate frcm the G.S.A.

l quality assurance program.

46. Define the phrase "the highest quality cmmercially available cmponents".

47. How was such quality detaminad?

l 48. Who made such determinations?

l l ~49. Who was responsible for the purchase of the electronics ccrq~snents of the plant security system, what were their qualifications and what experience did they have in this field?

t i e

! * ' n .. . .. , c. o,.a 4 , y ,, , , , :; e N

..,,3.. ,A,e v , . .s.,n

50. In preparation of the plant security systs, what breaches of security were considered probable?

51. How were these pr

• hi14 ties deternu.ned?

52. hho will conduct the security program review as required by 10 GR 73.44 (g) (4)?

53. htat qualifications will be required of the reviewing authority?

54. htat will be the nature of the inspection for such reviews?

55. Will the rewmerdations of the reviewing party be binding?

56. If so, who will impleent the rendations?

57. If re > - srdations by the reviemr will not be binding, why not?

58. What provisions have been made in the event that security personnel with access to security information leave the staff at CPS?

59. What steps have been taken to eisure that cmmunication between Plant security personnel and official ;~w enforcement agencies is available at all times?

60. Will such cmmunications be on radio frequencies accessible to camercially available police scanners?

61. What is the estimated cost of impimenting the security plan for the GS? Provide a cmplete breakdown of the budget for the plan.

62. What is the actual failure rate of mechanical security syste s? Provide any studies done, if they exist.

63. Are systes provided by more than one supplier proven to have more syst e failures than those systems provided by single suppliers?

If so, provide copies of any data available.

4 . &h y 4 s, # )/ 4.

%- 8 y e p 2 i) M .[ D g

Contention 6

1. Describa and provide IP's, BWR Owners Group's, and any other research and studies pertaining to the CPS central water level monitoring syst s .

2. What has IP done to address 'the need for level nonitoring to the dcme in BWRs? Provide relevant documents.

3a. What instrumentation is proposed for detecting inadequate core cooling in case of an abnormal occurrence? ' Provide relevant dments.

b. Has this instrumentation been tested?

c. If so, describe and provide the tests and studies which have been

enducted pertaining to the efficency of this instrumentation.

d. Does IP plan on following the NRC's reccmrendation of further instrumentation, specifically incorporation of core-exit thermocouples for BWR's? If so, provide the plan. If not, provide the documents and studies justifying IP's position, and all other relevant documents and studies.

4a. Will an accoustical nenitoring systen be used at CPS, pursuant to NURE 0737 II.D.3?

b. If so, how will this qualify as a direct monitoring instrixnent? Provide dm=nts explaining the accoustical monitoring systen and how it qualifies as a direct monitoring systen, if it does.

c. Have any studies been made to assure that reliability and accuracy can be maintained, given specific conditions of BWR, for instance, cors vibration that could result in deterioriation of devices and/or spurious signals? If so, describe and provide such studies. If not, explain why not.

Sa. What plans, if any, exist for providing a safety parameter display systen for use in the main control roczn? Describe and explain any such plans.

b. Provide a list of all meetings of BWR Owner's TMI Group and industry contractors where control rocm design and instramentation for CPS was discussed. Provide the agendas for these meetings, and the documents l produced frcxn these meetings.

l 6a. Describe fully the planned instrumentation for monitoring accident conditions.

b. Provide &v _immtaticn of in-house, industry and contractor st.udies that relata to IP's MW nce to NRC directives of additional instrumentation for monitoring accident conditions (the installing of extended range monitors and inproving post-accient sanpling capability) . Provide the substance of design changes.

u, ... ;g .

n .

..,e,

v. ., .

7. Describe and provide any IP, BWR Owner's 'IMI Group, or contractor studies to identify and correct control ro m design deficiencies. 1

8. Describe and provide any in-house, industry, or <nntractor evaluations as to control rocan design and instrunentation and their interaction with human factors.

9. Describe the criteria used to arrange the physical layout of instruments and control panels in the control rocxn. Include descriptions of any accessibility probles.

10. What new criteria, regarding CPS control rocxn layout and instrumentation, resulting from the accident at 'IMI, has been included in the FSAR?

Provide docmentation.

11. What new criteria, regarding modification of the design of GS, resulting frcxn the accident at 'IMI, has been included in the FSAR? Provide d m.naritation.

O 8$ % *W 8 '

• eh $

8 g* j ep' a *p q a , 4 f s

-Contention 7

1. Describe the CPS design in detail regarding its capability to withstand earthquakes of the intensity of the worst that have ever been known to occur in the site region. Provide the dnm =_nts containing the -

calculations behind the design. Provide documents relevant to the 4

subject matter.

2. What are the calenlations that justify the stated prnhahilities of inpact stated in FSAR 3.5-8? Provide the dnn_= nts containing the calcilaticms and related pertinent material.

3. Has IP considered the prnbahilities of impact regarding the two private airports, Baker and Thorp, that are within a six mile radius cf the CPS?

If so, provide the Anm = nts containing the calc 3 1ations and the

- prnhabilities of upact. If not, exclain why not.

, 4. Has IP considered the probabilities of impact regarding the three federal i airways, V233, V173, and V434, that are within a six mile radius of the CPS? If so, provide the Anm = nts containing the calculations and the probabilities of impact. If not, explain why not.

5. Define " low altitude airway" as used in the FSAR in calc 11ating inoact prnhabilities. Explain why only low altitude airways, as opposed to higher altitude airways, are mentioned and considered by IP in the FSAR. Provide calculations and doctanents that justify why only low altitude airways are considered. .

6.' Define " acceptably small" as used in the FSAR at 3.5-8, to describe the calculated inpact prnhability frcm V313 as 2 x 10-8/ year. Explain why impact. Provide 2

the x 10 8/ year that Anm-nts is enjustify

" acceptably the positionsmall" prnhability that 2 x 10- og/ year is " acceptably small" along with all other documents behind the calculations and justification.

7. culated inpact probability frcm the private airport, Martin, of Is 2.3 x 1 the g0 , which is larger tiumn V313's calcilated impact prohnhility by l more than a factor of 10, also considered " acceptably small"? If so, explain why, and provide the Anm=nts that justify the explanation.

8. Where did IP obtain the figures used in the FSAR 3.5-8 for the amount of

' air trcffic that occurs due to the airports of V313 and Martin? Provide Anm=mts containing the calm'iations and justification for such figures.

f-

9. Has IP considered the projected increase in air traffic for airports in Chanpaign-Urbana, Blocznington, Decatur, and Springfield of 23%, projected by the FAA, in FAA Aviation Forecasts, 7Y80-91?- If so, provide the l

Anm = nts and calculations that show this, and explain why this information i

is not found in the FSAR. If not, explain why this information is not l considered by IP.

i f

*' ' , . , ,, , x,. p s s v. .,

n. . p :., ,

I i _

10. Identify the person or persons involved with the following activities:

a. The ml< ilation of effects on plant biiltiings and structures to an earthquake of the same intensity as that of the worst ever known to have occurred in the site region.

b. The sapling of all geologic data relevant considered in calculating the on-site effects of such an ear *Jysake,

c. The calculations of the inpact probabilities due to aircraft.

d. The decision not to include the private airports of Baker & Thorp in calculating inpact probabilities.

e. The decision not to include Federal vector pathways V233, V173 & V434 in ml_<'ilating inpact probabilities.

f. The decision to consider only " low altitude airways" in <-al<'ilating

' impact pr*hilities.

g. The develemant of criteria, used to distinguish " acceptably small" impact probabilities as opposed +4 unacceptably small impact prnhahi1i ties.

h. The de*armination of air traffic on federal airway V313.and for the private airport Martin.

i. The consideration of projected future increases in air traffic and future shifts in the types of aircraft flying air routes.

For these people, give their names, addresses, business phone numbers, and gialifications (including aav ational & mnational experience) .

.e .r .. , ,, ; .. - l ,; . ,. 4

Contention 9 9.1. In reference to CPS FSAR IL 3.4.1 concerning the design objectives of the Area Radiation Monitor (ARM), state what is meant by

" maintaining exposure to personnel As Iow As is Reasonably Achievable."

(AIARA) Include (but do not limit your answer to) the radiation level in millirems per hour which Illinois Power considers AIARA3the method by which such a level was calculated. dod 9.2. Identify the person or persons who determined the level of radiation which Illinois Power considers AIARA. As to each person, state their name, address, and qualifications (including educational and occupational experience).

l 9.3. Identify all dumants connected in any way with the determination of the AIARA level, (and attach a copy o" each such document) .

9.4. State the number of Area Radiation Monitors which will be in constant use at the CPS, their exact plac m ent on or near the CPS site, and the qualifications (including educational and occupational experience) of the person (s) responsible for the observation and maintenance of the Area Radiation Monitors.

9.5. In reference to CPS FSAR 12.3.4.1.1.1. concerning the accuracy of ARM readings:

(a) State how the accuracy figure of 1 20% was arrived at, including an itsized description of all' sources of the +20% deviation and a description of the method'by which the 120% 2feviation frcm accuracy was determined.

(b) Identify the person (s) responsible for making any caloCations or measurments concerning the accuracy of the ARM. As to each person, state his/her/their name, address, and gmlifications, including educational and occupational experience.

(c) State why Illinois Power considersthe +20% deviation frcm accuracy of the ARM to be a reasoanble assurance of accuracy.

(d) Identify and attach all d m aants and other papers which are connected in any way with the accuracy of the ARM 9.6. With regard to CPS FSAR 12.3.4.2.3. concerning the nonitoring of radiation levels:

(a) State the frequency or amount of monitoring which Illinois Power considers to be " minim e monitoring".

(b) State the method of calculation and the name(s), address (es), and qualification (s) of the person (s) making the calculation.

a . , g 3 . ,,y

,-,.e. , -

--- . . -. . - - . . ,,,--,,,-,r-. , , - -

(c) Identify and attach all documents aid other papers which are connected in any way with the anount or frequency of nonitoring.

9.7. In reference to CPS FSAR 12.3.4.4.2.B. concerning the detection of maxinun pami=lle concentrations:

(a) State what is meant by Maxuun Permissable Concentrations.

Include in your answer what Illinois Power Cmpany c3nsiders '

to be a "Maxinun Permissable Concentration", and the names, addresses, and gmlifications of the persons who deramim the Maxinun Permissable Concentrations.

(b) State the reasons why it may take up to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to detect such concentrations.

(c) State what danger exists for plant workers and local residents who are exposed to more than the Maxinun Permissable Concentration for periods of up to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.

(d) State what data or calcule. cions were utilized in determining the answer to 9.7. (c) abcee, t

(e) Identify and attach any d e nts or other papers connected in any way with the deternination, detection, and effects of the Maximum Permissable Ccncentration.

9.8. In reference to CPS FSAR 12.3.4.5.1.1. concerning representative samples:

(a) State the method by which representative sanpling will be

- performed in worker occupied zones, ventilation ducts, ard other areas.

(b) If the method (s) listed in 9-8(a) deviate in any manner fran the rh ardations of the A.N.S.I. Guides, state the nature l

of each such deviations and the reason for each such deviation.

If Guides other than the A.N.G.I. Guides were used, identify the guide (s) used.

(c) State the ramns why any deviation fran A.N.S.I. guides are justified.

(d) State the name(s), address (es), and qm1ifications of the person (s) responsible for formulating the method by which -

randan sanpling would be performed.

(e) Identify and attach all deanents or other papers connected in any manner with the method of representative M11ng at CPS.

l l *

./ *-

. r T , q,< i rg , a ca .:. . it,, .

l p9..,..

l

~

i .

l 9.9. In reference to CPS FSAR page 1.8 -161 (2) concerning Illinois Power Ctspany's request for an exception fran 10 TR 20.203:

(a) State the reasons why Illinois Power Ccmpany is justified in seeking an exception fran 10 GR 20.203.

c (b) State whether Illinois Power Ccmpany wishes to increase the radiation levels in lockout zones. If so, state the amount by whica Illinois Power Ca pany wishes to increase such levels (over the level specified in 10 CFR 20.203) and the reasons wny the Ccmpany wishes to increase such levels.

l (c) State the type of Adminiatrative controls which will be utilized to insure the safety of plant workers if an exception

- fran 10 CFR 20.203 is granted. Include in your answer the name(s) l address (es), and qnalifications of the person (s) who formulated l the Ad:ninistrative Ccatrols.

t (Ei) State whether the administrative controls referred to in 9.9(c) i have ever been tested. If so, state the date and location of any such tests, and the name(s), address (es), and qualifications of the person (s) who formulated and/or administered, and/or evaluated such tests. ,

i i

(e) State what is meant by " radiation levels requiring locking".

Include in your answer an explanation of locking, and state what level of radiation requires locking. .

(f) State the maximum amount of time that plant workers'or pw.wunel will be allowed in any lockout zone or area where radiation levels require locking.

(g) State in detail the location of'any lockout zone or area where radiation levels require locking. Include a map of such areas in relation to the rest of the plant.

j i

l 9.10. In reference to CPS FSAR page 1.8-161(3) concerning deviations fran l positions stated in the Regulatory Guide:

(a) State the nature of any deviations fran the Regulatory Guide Specified in CPS FSAR, page 1.8-161(3), and explain why such deviaticas are justified.

l (b) State the nare(s), address (es), and qualifications of the person (s) who fornulated and/or approved any procedures deviating fran the Regulatory Guide.

l f

h *t

' C. . V l *; C,,  ; . r, . .& > s ,

s U *- Vl *s

Contenticn 11 11.1. In reference to CPS FSAR 12.3.4.4.2.1 page 12.3-24:

(a) State the highest and lovest anticipated radiation levels at CPS, the method by which such levels were ocanputed, and the name(s),  ;

address (es), azzi gulifications of the person (s) who made the

ccanputations.

(b) State what is meant by the'" sufficient margin" mentioned on page 12.3-24 in the second paragraph.

(c) State the method by which "a sufficient margin" is determined, and the gulifications and job titles of the person (s) who would make such a determination.

< (d) Identify and attach any documents or other papers relating to the determination of a sufficient margin.

11.2. In reference to estimated population doses of radiation:

(a) State the method by which estimated population doses were m1eilated. Include in your answer the name(s), address (es),

j and qualifications of.the person (s) making such calculations.

(b) State whether gaseous effluents from Clinton Unit 2 were considered in the above almilation. If not, state the reasons l

why Clinton Unit 2 should not be used in such calculations.

I In reference to CPS FSAR page 1.8-20, Regulatory Guide 1.111, 11.3. . concerning the mleilation of atmospherig6ffluents of routine releases:

(a) na= -iha in detail the methods used in the calmilation of such effluents. Include in your description the name(s),

address (es), and qmlifimtions of the person (s) who made such calci 1=tions.

(b) State why " conservative estimates considered here are unnecessary" (CPS FSAR Page 1.8-20) .

(c) State the name(s), address (es), and qualifications of the person (s) who deidad that conservative estimates were unnecessary.

11.4. In referenca 4 CPS FSAR page 1.8-169, Regulatory Guide ?.19, concerning dose assessments:

l l (a) State whether re.u.ds of review procedures, dtv'imantation requirements, and identification of principal ALARA related

[ changes resulting frcza the does assessment will be included in L

the assessment. If not, explain why not in detail.

1 i

I p . . 'g pf, gF i . ' = + ' a t t .,) , f,,.sp,, .j,

'g i

>*x Tp I,', R' *'t,

, q." ,p -) 4,*j 3 ,** .,  : i

[

i

. . .--. .- . _ - . - - - _ . - _ _ _ . . . - . - . - . . - . . - _ . - . - - _ . ~ . - - -

(b) If the items in 11.4(a) are not to be included in the

- assessment, state the name(s), address (es), and qualifications of the Am(s) who determined that such iterns shculd not be included in the dose assessment.

11.5. In reference to the release of radionuclida frcm Clinton Units 1 and 2:

l. (a) State whether there would be any resiaml low level radiation resulting frca the release of radionuclides.

(b) State whether such usidual radiation was assessed and factored into the N.E.P.A. cost-benefit analysis. If so, state the method by which such residual rMiation was so assessed and factored, and the reasons why such assessment and factoring should be adequate under N.E.P.A. If not, explain why such l

resiaal radistion should not be properly included in a N.E.P.A.

cost-benefit analysis.

1 l

e l

l l

l-l

' ^: ## # ,t. r Y Ia g [ *7 ['[ 8, ,7

'l'

• w 6 , > e, , , 8, ,

h 3 e

= , , - - , - , ,.----c - . - y- --. ,--wv - , _ , ,,.e- y77w a yC6-r ** vu'- gm ve* e in - e e - e W e+www w- -g - 'et 7--evtw %m-et=*e-e-gC-

u:.Kn n CATE OF SERVICE I hereby certify that on this day I served PRAIRIE ALLIAtCE'S FIBS' FOUND OF DISCOVERY upon each person designated below by deposit in the United States Mall, First Class postage prepald.

Hugh K. Clark, Esq. Philip L. Willman, Esq.

P.O. Box 127 A Susan Sekuler, Esq.

Kennedyville, Maryland 21645 Assistant Attorneys General Environmental Control Division 188 West Randolph Street, Suite 2315 Dr. George A. Ferguson Chicago, IL 60601 School of Engineering Howard University 2300 Sixth Street, N.W. Reed Neuman, Esq.

Washington, D.C. 20059 Assistant Attorney Ceneral 500 South Second Street Springfield, IL 62701 Dr. Oscar H. Paris Atcznic Safety & Licensing Board U.S. Nuclear Regulatory C = hsion Washington, D.C. 20555 Counsel for NBC Staff Office of the Executive Iegal Director Peter V. Fazio, Jr., Esq. U.S. Nuclear Regulatory Ccromission Schiff, Hardin and Waite Washington, D.C. 20555 7200 3 ears Tbwer

~

233 South Wacker Drifle Chicago, IL 60606 - Secretaty of the Ccmnission U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Dated this [ [0 day of June, 1981.

$K2 Allen Samelson i  : f&tH l' "OM4/

Representative for Prairie Alliance P.O. Box 2424 Station A Champaign, Illinois 61820 p' 7; ,w j,,,,;c ,, J. , , , .q . ,o c,,K..-,, , .. i., . , 3,..

- --- --- .- , . , - . . . - - . . , - . - - . - ,, . . , _ - . - . . - - .. , -- . .__ -