ML20008G172

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First Request for Production of Documents Directed to Util. Proof of Svc Encl
ML20008G172
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 06/26/1981
From: Willman P
ILLINOIS, STATE OF
To:
ILLINOIS POWER CO.
Shared Package
ML20008G169 List:
References
ISSUANCES-OL, NUDOCS 8107020388
Download: ML20008G172 (5)


Text

O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 1

IN THE MATTER OF

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l ILLINOIS POWER COMPANY,

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SOYLAND POWER COOPERATIVE, INC.

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and WESTERN ILLINOIS POWER

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COOPERATIVE, INC.

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Docket Nos. 50-461 OL

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50-462 OL (Operating Licenses for Clinton

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Power Station, Units 1 and 2)

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THE STATE OF ILLINOIS FIRST REQUEST FOR PRODUCTION OF DOCUMENTS The State of Illinois (Illinois) hereby requests that Illinois Power Company (IP) produce the documents listed below, pursuant to 10 C.F.R. 52.741.

Illinois requests that IP produce said-documents, for inspection and copying, at the Office of the

' Attorney General for the State of Illinois, 500 South Second Street, Springfield, Illinois, by July 27, 1981, or at such time and place as Illinois and IP may agree.

In addition to the documents listed below, Illinois requests that IP produce documents that IP will identify in the State of Illinois' First Set of Interrogatories to Illinois Power Company. However, in the interest of avoiding inconvenience to the parties involved, Illinois defers making this request until suchtime as IP identifies specific documents in response to interrogatories At that time Illinois will be able to make specific document requests.

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DEFINITIONS 1.

"BWR" refers to the General Electric Company boiling-water reactor, Mark III.

2.

" CPS" refers to the Clinton Power Station, Units 1 and 2.

3.

" Document" means all written or recorded material of.any kind or character known to IP or in its possession, custody, or control, including, but not limited to, correspondence, letters, telegrams, memoranda, notes, records, minutes, contracts, agreements, records, studies, pamphlets, books, articles, treatises, records or notations of personal conversations or conferences, inter-office communications, micro-film, bulletins, circulars, blue prints, plans, drawings, photo-graphs, teletype messages, invoices, tape recordings, and work-sheets.

4.

" Person" means an individual, partnership, firm, company, corporation, association, political sub-division, governmental agency, or any other legal entity, or its legal representative, agent or assign.

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i DOCUMENTS REQUESTED 1.

The latest annual reports or statements for each of l

IP, Western Illinois Power Ccoperative, Inc., and Soyland Power Cooperative, Inc.

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All NRC I & E reports for the CPS, and all cor-respondence between NRC and'IP?related'thereto.

3.

All documents referring to, related to, or discussing the analysis or assessment of anticipated transient. without scram (ATWS) conditions.

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All documents pertaining to the measures IP intends to take to reduce the risk of an ATWS condition at the CPS.

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All documents

  • pertaining 'to the measures P plans to take to nitigate the consequences of an ATWS condition.

6.

All employment records for all persons employed in Quality Assurance or Quality Control f Tctions at the CPS within l

l the last five years.

7.

All documents-including any manual, dictionary, or

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i machine readable sotrce code - for the models used by IP or i

its suppliers to analyze fuel swelling and flow blockage in

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the core due to loss-of-coolant accident conditions.

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All documents discussing the seismic qualifications l

of the sump flow monitoring, calculation and indication devices to be used at the CPS as part of the reactor coolant l

pressure boundary leakage detection systems.

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All drawings, blueprints, and specifications describing the design and construction of the spent fuel transfer tube.

Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS TYRONE C. FAHNER, Attorney General State of Illinois M-BY:

PHILIP If. WILLMAN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 OF COUNSEL:

REED NEUMAN Assistant Attorney General 500 South Second Street Springfield, Illinois 62701 DATED:

June ~26, 1981

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PROCF OF SERVICE I, ELIZABETH SZKLARZ, having been sworn and under oath, do state that I have this 26th day of June, 1981, served the foregoing Notice and The State of Illinois' First Set of Interrogatories to Illinois Power Company and the State of Illinois' First Request for Production of Documents, upon the persons to whom said Notice is directed, by posting same in envelopes addressed to said persons, by first class mail, postage prepaid, with the United States Postal Service located at 160 North LaSalle Street, Chicago, Illinois 60601.

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SUBSCRIBED AND SWORN TO BEFORE ME THIS 26TH DAY OF JUNE, 1981.

NOTARY PUBLIC

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