ML20009H063
| ML20009H063 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/27/1981 |
| From: | Fazio P, Koch L ILLINOIS POWER CO. |
| To: | PRAIRIE ALLIANCE |
| Shared Package | |
| ML20009H052 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8108050405 | |
| Download: ML20009H063 (72) | |
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* -0 1gB\ ? 40 UNITED STATES OF AMERICA O I,.n . Lgj 2 NUCLEAR REGULATORY COMMISSION
, V_ I) q:, L s c)l^*'
/ [3 IN THE MATTER OF )
N _. J c, ILLINOIS POWER COMPANY, )
SOYLAND POWER COOPERATIVE, INC. )
and WESTERN ILLINOIS POWER ) COOPERATIVE, INC. ) Docket Nos. 50-461-OL T ) 50-462-OL (Operating Licenses for Clinton ) Power Station, Units 1 and 2) ) qg RESPONSE OF ILLINOIS POWER TO PRAIRIE ALLIANCE'S f FIRST ROUND OF DISCOVERY O Illinois Power Company (" Illinois Power" or "the Company" or "IP") has objected to a number of Prairie Alli-e ance interrogatories. In some cases, all or part of the c) information requested in the interrogatory is provided , despite the objection. The information is provided in j3 the hope that it will resolve the issue and eliminate any perceived need for further discovery efforts. In each case, however, Illinois Power expressly reserves the right to reassert its objection in response to any additional gp discovery requests . 9' Illinois Power's Answer to General Interrogatory g No. 2 applies to each Interrogatory answered herein: [ General Interrogatory No. 2: Provide p documents, including research, studies, t calculations, memoranda, correspondence, reports, diagrams, computer codes, and all -{j other records that were relied upon by IP o in answering the question, and also those 4 8108050405 810727 C PDR ADOCK 05000461 G PDR
/3 C which served as the basis for the answer.
() Identify the particular parts of such docu-ments that were used in formulating the answer.] ANSWER: Illinois Power will make available for inspection () at its offices all such documents in its possession, custody, or control.
' Illinois Power's Answer to General Interrogatory LC) No. 5 applies to each Interrogatory answered herein:
[ General Interrogatory No. 5: State the names, addresses, titles, and qualifica-tions of the persons IP intends to call O as witnesses or experts for the answer and the subject matter which they intend to testify about.] ANSWER: Illinois Power has not yet determined which persons () it will call as witnesses should a hearing prove necessary. Contention 1 4 C) [ General Interrogatory No. 3: Identify by name, titla, and qualifications the IP employee that has the expert knowledge required to support the answer to the question.] ANSWER: The Illinois Power employee with knowledge neces-Y sary to support the answers to interrogatories submitted under this contention is John G. Cook, his title is Super-visor-Technical, and his qualifications are as follows: O > Formal Education: B.S. Engineering Physics, University of Illinois, 1969 e 0 U
O 4 c) M.S. Nuclear Engineering, University of Illinois, 1970 M.B.A. Golden Gate University, 1976 A Registered Professional Engineer, () Illinois, 1976 Training: BWR Fundamentals 4 CPS Systems Training Work Experience: Illinois Power Company () 1977 - Present Supervisor - Technical, Clinton Power Station Supervises the activities of the Nuclear Results Engineers assigned to Clinton O Power Station. 1975 - 1977 Training Coordinator Supervised Training Instructcrs in
' the preparation of training courses, (3 interfaced with outside contractors who were presenting training, taught courses related to the Clinton Power Station , Other Experience: U.S. Navy O
1970 - 1975 Instructor, U.S. Navy Nuclear Power School Taught courses in Heat Transfer, Reactor Physics, and Core Design to naval personnel. O [ General Interrogatory No. 4: Explain whether IP is presently engaged in or intends to engage in any further research or work which 4 may affect the answer. Identify such research or work.] 'O ANSWER: Illinois Power is currently revising the Emergency Plan for the Clinton Power Station (" CPS"). The revised 4 Plan identifies further work that will be necessary to implement the Plan. O
9 g [1. Provide a complete copy of the Emergency gg Plan proposed for the C.P.S.] ANSWER: The presently proposed CPS Emergency Plan is contained in the CPS Final Safety Analysis Report ("FSAR") 4 as Appendix B to Chapter 13. 3 Illinois Power is currently revising the Emergency O Plan. Draft Revision 1 (" Draft Emergency Plan") is available for inspection at the offices of Illinois Power. When 3 the Draft Emergency Plan has been finalized, it will be provided as a revision to the FSAR that has already been 3 furnished to Prairie Alliance. [2. Provide all internal memoranda, studies and reports, including calculations, which a analyze or determine the plume E.P.Z. and the ingestion E.P.Z. for the C.P.S.]
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ANSWER: The documents requested are available for inspec-tion at the offices of Illinois Power. J J [3. Provide copies of all studies, reports, documents and internal memoranda which dis-cuss, supplement or update the emergency plan delineated in the F.S.A.R.]
.g ANSWER: The documents requested are available for inspec- {
tion at the offices of Illinois Power. o- [4. (regarding contention 1(a) (1) State what actions if any are proposed to effect termina-3 tion of activities at outL;or recreational f acilities within the plume E.P,'.. and the i ingestion E.P.Z. 'c (a) Identify by name each outdoor recrea-jp tional facility for which such actions l are proposed; O
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(5) Specify the number and types of recrea-tional uses expected to be involved in such actions; (c) Specify the estimated maximum and minimum numbers of the public expected to be
, involved in such actions; ) (d) Specify the numbers and qualifications of C.P.S. personnel expected to be involved in such actions; c'
(e) Specify the numbers and qualifications of the emergency planning personnel
) expected to be involved in the planning of such actions; d
(f) Describe with specificity, e.g. by brand nane, type, manufacturer and
) the like, the types of equipment proposed to be utilized for such actions; (g) Specify the estimated time required for the accomplishment of such actions; a
(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 cost of such actions and identify the party or parties responsible for the payment of these costs.)
ANSWER: Any required termination of activities at outdoor recreational facilities will be accomplished through the cooperative efforts of Illinois Power and state and local government agencies under the integrated Emergency Plans
) of each entity. Illinois Power's primary responsibility, as set forth in 10 C.F.R. Part 50, Appendix E, is to notify e
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9 e the appropriate governmental agencies under the notification ab procedures described in the Draft Emergency Plan. Following notification by Illinois Power, offsite o emergency response actions are carried out under the provi-U sions of state and local emergency plans. Termination of activities at recreational facilities will be accomplished under the appropriate governmental agency's public notifica-U tion system. Under "The Illinois Emergency Services and Disaster Agency Act of 1975," the State has the power necessary to secure the safety and protection of the civilian popula-tion in the event of an emergency, including the power c to recommend tvacuation and prescribe the method of evacua-tion. The Act established the Emergency Services and Dis-aster Agency ("ESDA") for the purpose of preparing disastet plans and carrying out the progrea for emergency services. Illinois Power will assist state and local agencies in the preparation and implementation of their emergency plans. The State of Illinois has prepared a plan to O deal with emergencies at Illinois nuclear facilities. The plan will include provisions for CPS, it will be approved by the Federal Emergency Management Agency (" FEMA"), and o'^' emergency exercises will be conducted under the plan prior to the loading of fuel at CPS. O
3
- For the reasons explained above, the specific 4
information requested in subparagraphs (a )- (j ) of Interroga-tory No. 4 concerns matters outside the scope of Illinois Power's emergency planning responsibility and authority. O [5. (regarding contention 1(a) (2) .) State what actions if any are proposed to effect proper emergency responses at the special facilities described in contention #1(a) (2) . D (a) Identify by name each special facility for which such actions are 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 ninimum numbers of the public expected to be involved in such actions; c) (d) Specify the numbers and qualifications of C.P.S. personnel expected to be involved in such actions; (e) Specify the numbers and qualifications of the emergency planning personnel C) expected to be involved in the planning of such actions; (f) Describe with specificity, e.g. by brand name, type, manufacturer and the like, the types of equipment proposed () to be utilized for such actions; (g) Specify the estimated time required for the accomplishment of such actions; (h) Specify whether there will be any pre-O 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 cost of C) such actions and identify the party O
O or parties responsible for the payment () of these costs.] ANSWER: For the reasons explained in the Answer to Inter-rogatory No. 4, the specific information requested in sub-() paragraphs (a )- (j ) of Interrogatory No. 5 concerns matters outside the scope of Illinois Power's emergency planning responsibility and authority. O [6. (regarding 1(a) (3)) State what provision if any is made in the C.P.S. Emergency Plan for such severe weather conditions as may be expected in the site vicinity and plume and inger lon EPZs throughout the year. O (a) Describe the types of severe weather conditions which IPS has anticipated to occur in the CPS site vicinity and the plume and ingestion EPZs. O (b) Describe in detail what problems or impediments each such weather condition poses for emergency planning at the CPS. (c) Describe what actions are planned, . (J 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 13 involved in such actions; (e) Specify the numbers and qualifications of C.P.S. personnel expected to be involved in such actions; O (f) Specify the numbers and qualifications of the emergency planning personnel expected to be involved in the planning of such actions; (g ) Describe with specificity, e.g. by () brand name, type, manufacturer and O
1 i O the like, the types of equipment proposed to be utilized for such actions; (h) Specify the estimated time required for the accomplishment of such actions; (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 O or parties responsible for the payment of these costs.] ANSWER: Since on-site emergency responses described in the Draft Emergency Plan can be carried out inside CPS buildingo, they are not affected by severe weather conditions. With respect to off-site responses, for the reasons explained in the Answer to Interrogatory No. 4, the specific information requested in subparagraphs (a)-(j) of Interrogatory No. 6 concerns matters outside the scope of Illinoi Power's emergency planning responsibility and authority. ) [7. Identify all state and local agencies with whom IPC has executed or intends to execute agreements in the area of emergency planning and response actions. g (a) Identify the person in each named agency with whom IPC has had principal contact; (b) Produce all agreements IPC has executed to date with each named agency; g (c) State when IPC intends to execute agree-ments with all agencies listed in re-sponse to Interrogatory #4 above. O O
O (d ) Identify the person (s) responsible C) for executing such agreements with local and state agencies. (e) Provide copies of all communication with such agencies in regard to such existing or proposed agreements.] ANSWER: All required letters of agreement with state and local agencies have been executed. The general agreements with ESDA and the Illinois Department of Conservation will be worked out in greater detail prior to the exercises referred to in the Answer to Interrogatory No.13(8) . Other information requested by Interrogatory No. 7 appears in the letter agreement 3, which are presented as Appendix B to the Draf t Emergency Plan. C) [8. (regarding contention 1(c)) Describe , or outline, and provide a documentary evidence of the emergency procedures training to be provided for local services personnel. Os) Identify by agency or organization C all local personnel for whom such train- - ing is planned; (b) State when that training will be provided and how of ten it will be provided; C) (c) Identify who if any one is responsible for training local services personnel in emergency planning and response action. (d ) State the number of people anticipated O 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.) O
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) ANSWER: The structure of the Illinois Power training , ) program to support emergency activites is presented in the Draft Emergency Plan and in CPS Procedure No. OAP 1102.32N, EMERGENCY PLAN TRAINING. Illinois Power will make available 3 training that will apply to unique situations that could arise during emergencies related to nuclear power plants. This training will utilize lesson plans that have been or will be developed by the Company. The lesson plans and procedures developed to date are available for inspection at the offices of Illinois Power. 3 The training supplied by Illinois Power will focus on radiological theory, practices, and safety. For personnel who may require access into the facility, training will include familiarization with plant layout and hazards. A consultant will provide training for physicians and medical personnel in the treatment of radiation injuries. 3 General training for offsite emergency response agencies will be carried out primarily by ESDA, with the corporation and assistance of Illinois Power as needed. O Training in the integrated operation of the many independent organizations that will participate in emergency activities will be provided by exercising the plan through 3' periodic drills in accordance with 10 C.F.R. Part 50, Ap-pendix E, IV.F. Illinois Power will cooperate closely with offsite agencies in the training f, unction. 3 O
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, The number of personnel involved in each training activity will depend on the type of training provided, the existing experience and qualifications of personnel, , and on the offsite agency itself.
[9. (regarding contention 1(c)) Describe, or out-line, and provide documentary evidence of the training plans for all accident assessment per-sonnel and the " Emergency Response Organization". 3 (a ) Identify by agency or organization all local personnel for whom such training is planned; (b) State when that training will be provided g and how often it will be provided; (c ) Identify who if anyone is responsible for training local services personnel in emergency planning and response action. g (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.] ANSWER: Accident assessment personnel, the emergency re-sponse organization, and security personnel will be employees or contractors of Illinois Power. All non-clerical personnel O at the CPS will have some role in assessment, response, or ! security; this group will consist of about 300 individuals. l Virtually all training that will be received by CPS personnel O In general, l could be applied in response to an emergency. it is not possible to separate training activities into l those that are specific to emergency planning a'id those O which are not. For this reason it is impossible to isolate O
h those training costs that apply to only emergency training. The total direct costs and expenses for all training up to the time of fuel load is estimated to b between four and five million dollars. 3 All employees receive general employee training which addresses radiological safety and the response of individuals during an emergency. Security personnel are 3 trained as outlined in 10 C.F.R. Part 73, Appendix B. Additionally, each group receives specialty training which covers the specific activities of that group. The various training programs and materials are described in numerous manuals, lesson plans, and other documents. These documents are available for inspection at the of fices of Illinois Power. [10. (regarding contention 1(c)) Describe or outline and provide documentary evidence 3 of the provisions if any which have been or are being made for emergency preparedness training of security personnel at the CPS. (a) Identif y all personnel by name or by position for whom such training is planned. (b) State when that training will be provided j and how often it will be provided; 4 (c ) Identif y who if anyone is responsible for training local services personnel 4> in emergency planning and response action, t ! (d) State the number of people anticipated to be involved in such training; i (e ) State the cost of providing such training f) and identify the party or parties who will be responsible for such cost.]
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O ANSWER: See the Answer to Interrogatory No. 9. O [11. (regarding contention 1(c)) Describe or outline and provide documentary evidence for a radiological orientation training program for local services personnel, includ-ing news medial persons. O (a) Identify by agency or organization all local personnel for whom such train-ing is planned; (b) State when that training will be provided O and how often it will be provided; (c) Identify who if anyone is responsible for training local services personnel in emergency planning and response action. O (d) State the number of people articipated to be involved in such training; (e) State the cost of providing such training and identify the party or parties who C) will be responsible for such cost.] ANSWER: See the Answer to Interrogatory No. 8. [12. Describe or outline the emergency preparedness C) training to be provided for local services personnel. (a) Identify by agency or organization all local personnel for whom such train-ing is plannad;
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(b) State when that training will be provided and how often it will be provided; (c) Identify who, if anyone, is responsible for training local services personnel .d) on emergency planning and response action. (d) State the number of people anticipated to be involved in such training; 10 l l0 i L
3 (e) State the cost of providing such training 3 and who will pay for the costs involved;] ANSWER: See the Answer to Interrogatory No. 8. [13. (regardi ng contention 1(d)) Identify and a describe the items listed in Contention
# 1(d) (1)-(8) . If no response is provided, state when, if ever, each item will be pro-vided.
(1) The special qualifications of non-IP 3 employees who will be utilized in emergency training operations or recovery] ANSWER: The qualifications of consultants are identified in Section 1.4.1 of the CPS FSAR. Additionally, Radiation J Management Corporation ("RMC") has 10 years' experience in emergency medical assistance, which includes training local hospital personnel. RMC acts as a consultant to q ~ aproximately 1/3 of .311 nuclear power plant facilities. Their training team consists of a physician experienced in treating radiation injuries and an experienced health O physicist. [13 ( 2) The criteria for determining the need for notification and participation e of local, state and federal agencies] ANSWER: The criteria for determining the need for notifica-tion and participation of local, state, and federal agencies D are contained in Chapter 6 of the Draft Emergency Plan. [13(3) An analysis of the time required to evacuate or provide other protective measures for various sectors and distances D within the plume exposure and ingestion EPZs for both transient and permanent publics] 1 l 1 0
D ANSWER: Evacuation time estimates have been prepared for 3 the plume expcsure EPZ and are in Chapter 12 of the Draft Emergency Plan. 10 C.F.R. Part 50, Appendix E. does not require evacuation time estimates for the ingestion EPZ. D [13(4) A sufficient identification of the persons who will be responsible for making off-site projections] ANSWER: Identification of those responsible for CPS emer-gency activities including offsite dose projections is , given in Chapters 4 and 15 of the Draft Emergency Plan. U [13(5) An adequate description of how off-site dose projections will be made and how the results will be transmitted to appropriate governme.it entities] g ANSWER: Chapter '2 of the Draft Emergency Plan describes how offsite dose projections will be made. Transmission of results to state and local government agencies will be made through the Nuclear Accident Reporting System ("NARS" ) . 7) Transmission of results to the Nuclear Regulatory Commission ("NRC") will be made through the Emergency Notification g System. Both systems are described in chapter 8 of the Draft Emergency Plan. [13(6) Plans for yearly dissemination to the public within the plume exposure and ingestion EPZs of basic emergency planning l3 information, general information as to the nature and effects of radiation, and a listing of local broadcast stations that will be used for dissemination of information during j an emergency] C O
3 ANSWER: Plans for the yearly dissemination of basic emer- ') gency planning information to the public within the plume EPZ are described in Chapter 9 of the Draft Emergency Plan. Dissemination beyond the plume EPZ is not required. 3 [13(7) An identification of the apprcpriate state and local government officials within the EPZ which will require notification under accident conditions] ANSWER: Emergency information is transmitted directly by Illinois Power to ESDA, which acts as a clearinghouse for dissemination of tne information to appropriate state J and local government officials. The determination as to which officials require notification in a given set of circumstances is made by ESDA. O [13(8) A demonstration that state and local cfficials have the capability to make a public notification decision promptly upon being informed of an emergency condition.] o ANSWER: The capability of state and local officials has been demonstrated in the past by their ability to contend with numerous emergencies of a non-radiological nature.
'7 For example, according to the ESDA annual report for 1979, from January 1, 1979, through July 31, 1979, ESDA received and handled over 800 calls involving hazards. In addition O
to this proven capability, an exercise of emergency planning of CPS involving state and local agencies will be conducted prior to fuel load. FEMA representatives will observe O
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O l this exercise and verify that the emergency response capability
# is adequate.
[14. (regarding contention 1(e)) State and de-scribe what actions will be taken to assure isolation of people from the plume and inges-O tion EPZZ in case of an offsite or general emergency or other serious accident: For each such action state the following: (a) The number of emergency response person-g nel to be involved; (b) The criteria for determining when each such action shall be taken; (c) The expected number of people in the 3 general population to be involved; (d) The time duration for implementing each action; (e) Whether pre-operational rehersals will cs be held for each action; a (f) Whether the public will be involved in each such rehersal.] ANSWER: For the reasons explained in the Answer to Inter-r rogatory No. 4, the information requested concerns matters outside the scope of Illinois Power's emergency planning responsibility and authority. O [15. (regarding contention 1 (f)) Provide all documentation concerning provisions for following emergency support facilities: g (a) Technical Support Center (b) Operational Support Center (c) Emergency Operations Facility 73 (d ) Safety Parameter Display System 0 1 l
9 (e) Nuclear Data Link. O In each facility's documentation include: (1) Current status of provision program, including degree of completion achieved to date; (2) Expected complGtion date; (3) Personrel staffing information, including number of personnel, name of positions, , qualifications required. J (4) Prospective personnel) ANSWER: The provisions for the Technical Support Center, 3 Operational Support Center, and Emergency Operations Facility are described in Chapter 19 of the Draf t Emergency Plan. Other relevant documents are available for inspection at 3 the offices of Illinois Power. Neither the Safety Parameter Display System nor the Nuclear Data Link are physical facilities. They are 3 information systems that allow the plant operators and the Nuclear Regulatory Commission ("NRC"), respectively, to monitor the power plant. Illinois Power believes that U) the design of the CPS control room meets the intent of the Safety Parameter Display System. The NRC is primarily responsib.'e for implementation C of the Nuclear Data Link. Illinois Power intends to cooper-ate with the NRC in implementing the Nuclear Data Link O O
S at CPS if prototype systems prove usefal when they are O installed in other facilities. Contention 4 [] OBJECTION NO. 1: Illinois Power objects to Interrogatories 1-36 and 50-63 on the grounds that the information requested is beyond the scope of the admitted ccatention, and is 7) therefore irrelevant. Prairie Alliance Revised Contention 4 alleged that the PSAR "does not give adequate assurance that all 3 regulatory requirements have been or will be met prior to operation," citing generally as follows: "See, e.g., FSAR Regulatory Guide 1.17, Rev. 1." In admitting this 3 contention, the Board narrowed the general FSAR citation as follows: "See FSAR, p. 1.8-25, Regulatory Guide 1.17, Revision 1." Page 1.8-25 of the FSAR contains Illinois 3 Power's project positions with respect to compliance with Regulatory Guide 1.17. Recognition of issues raised by 9 specific project positions citing specific Regulatory Guide standards does not justify a general inquiry into every aspect of the CPS security plan. O OBJECTION NO. 2: Illinois Power f urther objects to Inter-rogatory Nos. 39-41, 50, 51, 59, and 60 on the grounds O that the information requested (1) is not relevant, and
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O (2) is exempted from disclosure under 10 C.F.R. S 2.790 (d) (1) , and disclosure is not necessary to a proper decision in this proceeding. O [ General Interrogatory No. 3: Identify by name, title, and qualifications the IP employee that has the expert knowledge required to support the answer to the question.] g ANSWER: The Illinois Power employee with knowledge neces-sary to support the answers to interrogatories submitted under this contention is Alan L. Ruwe, his title is Supervisor - n Electrical Engineering, and his qualifications are as follosa: v Formal Education: B.S., Electrical Engineering, University of Illinois, 1970 Graduate Program Certificate, Electrical -) Engineering University of Illinois, 1973 M.S., Nuclear Engineering, University of Illinois, 1977
) Registered Professional Engineer, State of Illinois, 1976 Training: Graduate of Operator Training course, University of Illinois research reactor facilities, 1976.
c) Graduate of GE-BWR course in Plant Design and Fundamentals, 1975. Work Experience: Illinois Power Company 1977 - Present Supervisor - Electrical Engineering, Nuclear Station Engineering Department. Supervisory responsibility for the design and engineering of electrical systems for the BWR unit at Clinton Power Station. () O
I J 1974 - 1977 Senior Electrical Engineer - Nuclear Projects Department. Responsible for 3 design review and coordination with consultant, vendor and NSSS contractor for the two BWR units at Clinton Power Station. 1972 - 1974 Power Plant Electrical Engineer, Engineer-O ing Department. Responsible for design and coordination of all electrical systems (including switchyard) modifica-tions to fossil generating facilities and directing and coordinating the design work of consultants for two O new fossil units. 1970 - 1972 Electrical Engineer - Substation Design, Engineering Department. Responsible for design of substation and switchyar6s.
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; [ General Interrogatory No. 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 or work.]
ANSWER: Illinois Power is continuously engaged in moni-toring incorr that may affect the design, construction, i or operation oc ti?e CPS. Unless new information indicates i the need for further investigation, Illinois Power does i ! not plan to conduct further research or work which may affect the answers to interrogatories submitted under this
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contention. l 1 [37. With reference to the FSAR 1.8-25, why was the plant security system not considered
- 7) a safety related systen?]
ANSWER: The security system does not meet the criteria for safety related syst ems as set forth in section 3.2.3 of the FSAR. Furthermore, security systems do not meet i 1 1 () 1 1
1 O the criteria for safety systems described in Regalatcry C) Guide 1.29, "Saismic Design Criteria." [38. Who made this determination?) ANSWER: This determination was made by Illinois Power's
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Nuclear Station Engineering and CPS Operations Departments. [42. How many suppliers were electroniv equipment purchased from?]
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[43. Who were these suppliers?) ANSWER: To date, electronic components for the security c) system have been purchased from three suppliers: Johnson Controls, Inc., Ion Track Instruments, Inc., and New Security Concept, Inc. ( [44. Was competitive bidding sought and obtained prior to the purchase of such equipment?) ANSWER: Yes. O [45. Explain why IP feels that it is entitled to deviate from the G.S.A. quality assurance program.) AN3WER: This question apparently stems from the CPS project O positionc on Regulatory Guide 1.17, Revision 1, as set forth on page 1.8-25 of the FSAM. Position 1 takes exception to a QA program implied in GSA Interim Federal Specifications O W-A-00450A, " Components for Interior Security Alarm Systems." Paragraph C.l.b of Regulatory Guide 1.17 states that "All intrusion alarms, emergency exit alarms, alarm systems, O
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6 and line supervisory systems should, as a minimum, meet
;(3 the level of performance and reliability indicated by GSA Interim Federal Specification W-A-00450A (GS A-FSS) . " The Regulatory Guide does not reference the QA requirements t
(3 of the GSA specification. Illinois Power therefore takes j the position that the GSA QA program is not applicable to the security system for a nuclear power plant. l(3 10 C.F.R. Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," requires that QA programs be applied to "... struc-
-(3 tures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause 1
undue risk to the health and safety of the public." The () components for the security alarm system do not meet this criterion. [46. Define the phrase "the highest quality commer-C) cially available components".] ANSWER: This question apparently stems from the CPS project positions on Regulatory Guide 1.17, Revision 1, which take C) exception to the QA program of a referenced GSA specification (see response to Question 45). The context of the phrase in question is: " Highest quality commercially available I) components were ordered using standard specifications." This sentence means that, although Illinois Power has not committed to the GSA QA program, overall quality of system O I O
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O performance was the principal criterion for selection of I3 equipment with similar specifications. [47. How was such quality determined?] ANSWER: The quality of security equipment was and is C) determined by: (a) reviewing proposed equipment against prepared specifications, (b) evaluating supplier qualifica-tions, (c) considering supplier experience, (d) witnessing C) factory acceptance testing, (e) preoperation field and acceptance testing, and (f) continuing inspection and mainte-nance programs.
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[48. Who made such determinations?] i ANShER: The determinations of security equipment quality were made by Illin is P wer's Nu lear Station Engineering,
- O f CPS Operations, Power Production, and Data Processing Depart-4 mants, and by Sargent & Lundy. Personnel in all of these
) organizations contributed to the determination of system o i quality through the mechanisms listed in response to Inter-l rogatory No. 47. l iO [49. Who was responsible for the purchase of l the electronics components of the plant security system, what were their qualifica-l tions and what experience did they have l in this field?]
!O ANSWER: All the organizations listed in response to Inter- j i
rogatory No. 48, plus the Illinois Power Purchasing Depart- , l ; ment, were involved in the procurement process.
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O Contention 6 O [ General Interrogatory No. 3: Identify by name, title, and qualification the IP employee that has the expert knowledge required to support the answer to the question.] O ANSWER: The Illinois Power employee with knowledge neces-sary to support the answers to interrogatories relative to this contention is John P. O'Brien, his title is Super-O visor-Instrumentation and Controls Engineering, and his qualifications are as follows: Formal Education: B.S.E.E. Iowa State University M.S.N.S. University of Illinois Presently working toward M.B.A. at Illinois State University Work Experience: Illinois Power Company 1976 - Present Supet visor - Insttilmentation & Controls Engineering, Generation Engineering Depa r tment . Supervision of control O and instrumentation design preparation and review. 1968 - 1976 Supervisor of Systems and Programming Engineering, nata Processing Department. Supervision or computer programming O on application of an engineering or scientific 6:,ture. 1967 - 1968 Senior Engineering Systems Programmer, Data Processing Department. Engaged in computer program development of .O an engineering or scientific nature. 1964 - 1967 Electrical Engineer - Computer Engineering Depar tment . Involved in computer program development, installation, and processing f r the Engineering Department. O O
O 1960 - 1964 Engineer. Engineering Department. D Involved in generation and transmission planning related to capacity additions. [ General Interrogatory No. 4: Explain whether IP is presently engaged or intends to engage D in any f urther research or work which may affect the answer. Identify such research or work.] ANSWER: An evaluation of the layout and instrumentation O for the CPS control room against the requirements contained
'in NUREG-0737 and other regulatory documents is currently in nrogress. Since this evaluation is not completed, no O planned instrumentation beyond that described in the FSAR has been identified. If regulatory deficiencies in the layout and instrumentation for the CPS control room are C) found, appropriate modifications will be made.
[1. Describe and provide IP's, BWR Owners Group's, and any other research and studies pertaining to the CPS central water level monitoring O system.) ANSWER: S'.udies have been performed by General Electric Company ("GE") and the Boiling Water Reac'cor ("BWR" ) Owners' O Group with respect to the reqpirements contained in NUREG-0660, NUREG-0694, and NUREG-0737. These studies have verified the reliability and adegpacy of the BWR war:er level monitor-O ing instrumentation system. Relevant document *. are available for inspection at the offices of Illinois Power, O 0 l
i lO [2. What has IP done to addttss the need for 13 level monitoring to the tone in BWRs? Provide relevant documents.] l 1 ANSWER: The reactor water level monitoring system presently provided on CPS is capable of measuring reactor water level up to the dome. The shutdown range indicator provides this capability. Documents discussing the shutdown range 1 level instrumentation and other relevant documents are available for inspection at the of fices of Illinois Power . [3a. What instrumentation is proposed for detecting inadequate core cooling in case of an abnormal
;O occurrence? Provide relevant documents.]
ANSWER: The installed reactor vessel water level instru-mentation, as described in CPS FSAR Sections 7.4 and 7.5, 33 will be used for detecting inadequate core cooling. Other relevant documents are available for inspection at the offices of Illinois Power. LO [3b. Has this instrumentatica been tested?] ANSWER: The water level instrumentation to be used at CPS was developed by GE ar.d is typical of that used in
)
currently operating BWRs. Operating experience has cemon-strated the instrumentation performance to be proper , accu-rate, and reliable. Instrumentation components are tested q) by GE to assure that they will function properly under the environmental and scismic conditions postulated to occur during a loss-of-coolant accident ("LOCA"). 3
!O
O [3c. It so, describe and provide the tests and !e studies which have been conducted pertaining to the efficency of this instrumentation.] ANSWER: The GE tests 'md studies concerning water level instrumentation are not in tt'e possession, custody, or e control of Illinois Power. They are in the possession of GE. G [Jd. Does IP plan on following the NRC's recommende-tion of further instrumentation, specifically incorporation of core-exit thermocouples for BWR's? If so, provide the plan. If not, provide the documents and studies justify-ing IP's position, and all other relevant O documents and studies.] ANSWER: It is Illinois Power's understanding that the NRC is still reviewing the question of incore thermocouples O for BWR's. See NUREG-0519, " Safety Evaluation Report Related to the Operation of LaSalle County Station Units 1 and 2," dated March, 1991. Since installation of incore thermocou-O ples is not required by the NRC, Illinois Power does not currently plan to install them. Also, as discussed in response to Interrogatory No. 3a above, the instrumentation O provided at CPS is fully capable of detecting inadequate core cooling. Relevant documents are available for inspection LO at the offices of Illinois Power. [4a. Will an accoustical monitoring system be l i used at CPS, pursuant to NUREG 0737 II.D.3?] l O ( l
'O ANSWER: CPS will utilize an acoustical monitoring system 10 to satisfy the requirement II.D.3 in NUREG-0737. [4b. If so, how will this qualify as e direct monitoring instrument? Provide documents o explaining and how it the accoustical monitoring system qualifies as a direct monitoring system, if it does.] ANSWER: NUREG-0737 requirement II.D.3 states:
<3 " Reactor coolant system relief and safety valves shall be provided with a positive indication in the control room derived from a reliable valve-position detection device or a reliable indication of flow in the discharge pipe." (emphasis added)
- O The acoustical monitoring system ("AMS") purchased for the safety / relief valves at the CPS will satisfy this re-quirement by providing a reliable indication of flow in O
the discharge pipe. The AMS for the CPS is described in the specification and proposal utilized in the procurement of this system and other related correspondence. Relevant O documents are available for inspection at the of fices of Illinois Power. O [4c. Have any studies been made to assure that reliability and accuracy can be maintained, given specific conditions of BWR, for instance, core vibration that could result in deterioria-tion of devices and/or spurious signals? If so, describe and provide such studies. O If not, explain why not.] ANSWER: Since 1978, Technology for Energy Corporation ("TEC") has been performing research for the Electric Power t3 Research Institute ("EPRI") in Research Project 1246 entitled O
O
" Acoustic Monitoring for Power Plant Valves." In May 1979, g) the scope of that project was amended to include " Extended Relief and Safety Valve Monitoring." As part of the a* ended scope, TEC performed tests on various types of relief and g
safety valves. TEC's measurements showed that acoustic monitoring can unequivocally indicate valve position. The project verified that it is possible to differentiste O ! poritively between ordinary background noise in the plant when a valve is shut and the higher level of noise when steam is flowing through it. The technique was shown to O be sufficiently sensitive that a clear distinction can be made even when the valve is slightly open. Due to the success of this test program, acoustical ,O monitoring systems similar in design to the one to be used I at the CPS have been supplied to approximately 20 operating nuclear power station units. () [Sa. What plans, if any, exist for providing. a safety parameter display system for use in the main control room? Describe and explain any such plans.] .(3 ANSWER: Illinois Power is currently planning to display safety parameters et a cathode ray tube mounted on a control jo room panel. The safety parameter display will be driven by the existing CPS computer system. !O
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o [5b. Provide a list of all meetings of BWR Owner's () TMI Group and industry contractors where control room design and instrumentation for CPS was discussed. Provide the agendas for these meetings, and the documents produced from these meetings.] o A listing of the meetings of the BWR Owners' TMI Group and its Control Room Subcommittee is set forth below: January 9, 1980 BWR Owners Authorize Subcommittee Activities O Subcommittee Meeting February 20, 1980 February 21, 1980 Subcommittee and NSAC on BWR Efforts February 29, 1980 Subcommittee and NRC on Nuclear Data Link O March 18, 19, 1980 NSAC Workshop in Dallas March 26, 27, 1980 BWR Owners Meeting > April 16, 1980 Subcommittee and Sol Levy Inc. () April 17, 1980 AIF Subcommittee Meeting in Chicago April 17, 18, 1980 Subcommittee Meeting May 7, 1980 AIF Subcommittee and NRC May 7, 8, 1980 Subcommittee Meeting . C) May 19, 20, 1980 BWR Owners Meeting ) May 30, 1980 Subcommittee and NSAC on PNR Efforts June 4,5, 1980 Subcommittee Meeting June 12, 1980 Subcommittee and L'onsultants O July 1, 1980 BWR Owners Meeting July 7, 0, 9, 1980 Subcommittee Meeting July 21, 1980 Subcommittee and NSAC July 22, 1980 Subcommittee and General Electric
- O July 24, 1980 AIF Subcommittee on Parameter List July 29, 1980 Subcommittee and NRC August 6, 1980 AIF Subcommittee and ACRS
' C) August 12, 13, 1980 Subcommittee Meeting August 28, 1980 AIF Subcommittee
- O
. . - - . _ _ - - ~ - _ _ - - _ . , ,. -. . _ - .
O September 2, 1980 BWR Owners Meeting September 8, 1980 Subcommittee with Sandia O on NDL September 16, 17, 18, 1980 Subcommittee Meeting October C-15, 1980 Control Room Survey Workshop October 21, 22, 23, 1980 Subcommittee Meeting O November 3-14, 1980 CRS Validation Survey at DAEC November 19-20, 1980 BWR Owners' Meeting December 1-3, 1980 Subcommittee Meeting O January 21,22, 1981 BNR Owners Meeting February 2-4, 1981 Subcocc;tttee Meeting March 3-5, 1981 Subcommittee and General Electric March 10-11, 1981 Subcommittee Meeting O March 18-19, 1981 BWR Owners Meeting April 1, 1981 SPDS Working Group April 13, 1981 SPDS Working Grocp April 14-15, 1981 Subcommittee Meeting April 29-30, 1981 SPDS Working Group O May 1, 1981 SPDS Working Group June 1, 1981 SPDS Working Group June 2-3, 1981 BWR Owners Group O Relevant documents are available for inspection at the offices of Illinois Power. [6a. Describe fully the planned instrumentation C) for monitoring accidant conditions.] ANSWER: All currently planned instrumentation for monitor-ing accident conditions, except the post-accident sampling O system, is described in CPS FSAR Chapters 7, 11, and 12. The post-accident sampling system is described in the specifi-cation and proposal utilized for its procurement and uther O O
related correspondence. Relevant documents are available for inspection at the offices of Illinois Power. [6b. Provide documentation of in-house, industry and contractor studies that relate to IP's q compliance to NRC directives of additional ' instrumentation for monitoring accident conditions (the installing of extended range monitors and improving post-accient sampling capability). Provide the substance of design changes.] 3 ANSWER: Relevant documents are available for inspection at the offices of Illinois Power. 3 [7. Describe and provide any IP, BWR Owner's TMI Group, or contractor studies to identify and correct control room design deficiencies.] ANSWER: Relevarit documents are available for inspection at the offices of Illinois Power. [8. Describe and provide any in-house, industry, or contractor evaluations as to control room design and instrumentation and their , interaction with human factors.] ' J ANSWER: Relevant documents are available for inspection at the offices of Illinois Power. [9. Describe the criteria used to arrange the physical layout of instruments and control panels in the control room. Include descrip-tions of any accessibility problems.] g ANSWER: The criteria used to arrange the physical layout of instruments and control panels in the control room are described in documents available for inspection at the g offices of Illinois Power. No accessibility problems have been noted. O
O [10. What new criteria, regarding CPS control room layout and instrumentation, resulting O from the accident at TMI, has been included in the FSAR? Provide documentation.] ANEWER: The CPS FSAR has not been revised to address , TMI-related requirements regarding control room layout and instrumentation. The first revision to the CPS-FSAR addressing TMI-related requirements is expected to be issued , in Autumn 1981. [11. What new criteria, regarding modification of the design of CPS, resulting from the accident at TMI, has been included in the
) PSAR? Provide documentation.]
ANSWER: The CPS FSAR has not been revised to address TMI-related requirements regarding control room design. The first revision to the CPS-FSAR addressing TMI-related requirements is expected to be issued in Autumn 1981. D Contention 7 [ General Interrogatory No. 3: Identify by name, title, and qualifications the IP employee that has the expert knowledge required to 3 support the answer to the question.] ANSWER: The Illinois Power employee with knowledge neces-sary to support the answers to interrogatories submitted ) under this contention is Harry B. Perkins, Jr., his title is Supervisor-Civil Structural Engineering, and his qualifica-tions are as follows: D D
O Formal Education: BSCE-Furdue University, 1949
,)
Graduate Certificate - University Of Illinois, 1965 Graduate Certificate - University of California, 1968 Graduate Certificate -University of Wisconsin, 1972 Miscellaneous: Registered Structural Engineer-Illinois, 1955 g Registered Professional Engineer-Indiana, 1962 Registered Land Surveyor, 1962 n Certified Level III Inspection Engineer-J NCEE, 1976 Member American Concrete Institute Work Experience: Illinois Power Company q' " 1979 -Present .up?rvisor-Civil / Structural Engineering, nuclear Station Engineering Department. Plan, organize, and direct design for modifications and additions to fossil fuel power plants. Direct and monitor
- the design for construction of Clinton J Unit 1 Nuclear Power Station. Siting studies for new power plants.
1975 - 1979 Supervisor-Civil Construction Clinton Unit 1.
, Supr.rvision of civil / structural staff lit the construction of Clinton Unit 1.
Coordination of design for constructibility and construction progress. 1974 - 1975 Senior Engineer-Civil / Structural, Nuclear ,a Project Dept. Review of design and specifications for Clinton Unit 1. Other Experience: g 1959 - 1974 Senior Civil / Strut:tural Engineer; Argonns National Laboratory-design and construction of various nuclear related facilities. O
O 1954 - 1959 Structural Engineer - Vern Alden Co., C) Chicago, Ill. Power plant and industrial design. 1951 - 1954 Design Engineer - A. J. Boynington Co., Chicago, Ill. - Steel mill design. C) 1949 - 1951 Civil Engineer-State of Indiana Resident Engineer large earth dam. [ General Interrogatory No. 4: Explain whether IP is presently engaged in or intends to O en9a9e in any further research or work which may affect the answer. Identify such research or work.] ANSWE R: Illinois Power is continuously engaged in moni-O toring information that may affect the design, construction, or operation of the CPS. Unless new information indicates the need for further investigation, Illinois Power does O not plan to conduct further research or work which may affect the answers to interrogatories submitted under this contention. O [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 documents containing the calcula-O tions behind the design. Provide documents relevant to the subject matter.) ANSWER: Illinois Power objects to Interrogatory No.1
. on the grounds (.nat the information sought is beyond the scope of the admit.ted contention, and is therefore irrele-vant. The relevant contention is as follows:
The seismic qualification of the CPS design C) does not account for the worst case seismic O
J dCtiVity noW knoWn to occur in the site region. J In its order issued May 29, 1981, the Board admit-ted this contention (Prairie Alliance Revised Contention 10 (a ) (2) ) because "[plart (a) (2) alleges new information." Order at 11. The "new information" cited by Prairie Alliance at the Second Special Prehearing Conferehte allegedly shows that a seismic event has occurred in the site region that exceeds the severity of seismic events that the CPS was designed to withstand. The Board rejected the other parts of Revised Contantion 10 that challenged the CPS design. Accordingly, interrogatorica are within the scope of the admitted contention only if they seek to elicit information concerning the severity of the seismic event that the CPS
.)
was designed to withstand. Interrogatory No. 1 asks for a detailed description of the CPS design itself, and for - the production of design documents. It is therefore beyond J the scope of the admitted; contention. The information requested in Interrogatory No. 1 is contained in the FSAR, except for "the documents contain-g ing the calculations behind the design." The relevant subsections of the FSAR are as follows: 2.5.2 Vibratory Ground Motion 3.7.1 Seismic Input 3.7.2 Seismic System Analysis 3.7.3 Seismic Subsystem Analysis O
!O h
3.8 Design of Seismic Category I Structure () 3.9 Mechanical Systems and Components 9.10 Seismic Qualification of Seismic Category I Instrumentation and Electrical Equipment O Other documents televant to the subject are listed in the following cubsections of the FSAR: I) 2.5.7 (reference number 61 through 78) 3.7.5 (all references) )
- ,, [2. What are the calculations that justify the D' stated probabilities of impact stated in FSAR 3.5-8? Provide the documents containing the calculations and related pertinent materi-al.)
ANSWER: Relevant documents containing the calculations
)
! and related material are available for inspection at the offices of Illinois Power. O [3. C3s IP considered the probabilities of impact regarding the two private airports, Baker and Thorp, that are within a six mile radius of the CPS? If so, provide the documents containing the calculations and the probabili-g ties of impact. If not, explain why not.1 ANSWER: The aircraft activities at Baker and Thorp airports explicitly were not considered in the provooility calculations. Baker and 'fhorp airports are 6 miles away f rom the CPS. O ' Under the criteria established in Regulatory Guide 1.70, Section 2.2.2 and Standard Review Plan (SRP) Section 3.5.1.6, the number of flights per year at those airports would {) have to exceed 18,000 (500 d2, d is distance in miles) O
O in order to be considered in probability calculations. This level of activity translates into about 50 flights per day, whf ch is several times higher than the actual activity at these private airports. [4. Has IP considered the probabilities of impact regarding the three federal airways, v233, V173, and V434, that are within a six mile radius of the CPS? If so, provide the docu-D ments containing the calculations and the probabilities of impact. If not, explain why not.] ANSWER: The federal airways J233, V173, and V434 were h) not coissidered in the probability calculations because they are more than two miles away from the CPS. Under Reg. *:uide 1.70, Section 3.5.1.6, only those federal airways 3 passing within two miles of a nuclear facility need be considered. [5. Define " low altitude airway" cs used in the FSAR in calculating impact probabilities. Explain why only low altitude airways, as opposed to higher altitude airways , are mentioned and considered by IP in the FSAR. Provide calculations and docume:.ts that justify why only low altitude airways are ) considered.] ANS:CR: A low altitude airway, as defined in the FSAR, includes that airspace extending upward from 1,200 feet ) above the surface of the earth to 18,000 feet above Mean Sea Level (MSL) . J
O - High altitude airways were not considered in the FSAR because there are no high altitude airways within two miles of CPS. Under Reg. Guide 1.70, Section 3.5.1.6, only those federal airways passing within two miles of a nuclear facility need be considered. [6. Define " acceptably small" as used in the FSAR at 3.5-8, to describe the calculated D impact probability f rom V312 as 2 x 10-8/ year . Explain why 2 x 10-8/yeac is an " accept-ably smail" probability of impact. Provide the documents that justify the position that 2 x 10-8/ year is " acceptably small" along with all other documents behind the 3 calculations and justification.] ANSWER: Regulatory Guide 1.70, Section 2.2.3 defines probabilities "on the order of about 10 -7 per year" as D acceptable, before an event becomes a design basis event. Similar criteria are given in SRP Sections 2.2.3 and 3.5.1.6. Based on these criteria, -d 2 x 10 / year probability of 3 impact is acceptably small. Relevant documents are available for inspection at the offices of Illinois Power. [7. Is the calculated impact probability from 3 , the private airport, Martin, of 2.3 x 10-7, which is larger than V313's calculated impact prcbability by more than a f actor of 10, also considered " acceptably small"? If so, explain why, and provide the documents that justify the explanation.]
)
ANSWER: The calculated impact probability of 2.3 x 10 -7 is "on the order of about 10 -7 per year" and is therefore i D k I l
O acceptably small under the criterion established by Regula-C) tory Guide 1.70, Section 2.2.3. [8. Where did IP obtain the figures used in the FSAR 3.5-8 for the amount of air traffic that occurs due to the airports of V313 C) and Martin? Provide documents containing tl.e calculations and justification for such figures.] ANSWER: The amount of air traffic for Martin airport C) was obtained by direct contact with the airport. The amount of air traffic on Federal Airway V313 was obtained from Chicago Air Route Traffic Control Center. Relevant documents O are available for inspection at the offices of Illinois Power. c) [9. Has IP considered the projected increase in air traffic for airports in Champaign-Urbana, Bloomington, Decatur, and Springfi'ld of 20%, projected by the FAA, in FAA Aviatioq Forecasts, FY80-91? If so, provide the documents and calculations that show this, g and explain why this information is not found in the FSAR. If not, explain why this information is not considered by IP.] ANSWER: Traffic at the four airports cited was not consid-g ered in the probability calculations because it need not be considered under criteria established by Regulatory Guide 1,70, Section 2.2.2 and SRP, Section 3.5.1.6. Each f the four airports is more than 10 miles away from the O CPS. Under Regulatory Guide 1.70, therefore, the number of operations per year must exceed 1000 d2, where d is the distance of the airport from the plant in miles, for () O 2- --.
b l L these airports to be considered in probability calculations. 3 Traffic at these airports is compared with that given by the Regulatory Guide 1.70 criterion in the following table: ,, Distance Operations 20%
- Airport (d) (Miles) 1000 d2 in 1978 Increase Champaign
/ Urbana 31 961,000 188,591 226,309 Bloomington 22.5 506,250 86,970 104,364 Decatur 22.5 506,250 91,826 110,191 J Springfield 51 2,601,000 141,516 169,819 As that table nhows, the value for 1000 d 2 exceeds the actual number of operations at each of these airports and ,J also exceeds any reasonable projection of the future number of operations.
@ [10. Identify the person or persons involved with the following activities:
- a. The calculation of effects on plant buildings and structures to an earthquake of the same intensity as that of the G worst ever known to have occurred in the site region.
- b. The sampling of all geologic data re-levant considered in calculating the on-site effectc of such an earthquake.
O
- c. The calculations of the impact probabili-ties due to aircraft.
- d. The decision not to include the private airports of Baker & Thorp in calculating 8 impact probabilities.
- e. The decision not to include Federcl vector pathways v233, v173 & V434 in calculating impact probabilities.
9 O
C)
- f. The decision to consider only " low
; C) altitude airways" in calculating impact i proba bilities .
( g. The development of criteria, used to distinguish " acceptably smail" impact probabilities as opposed to unacceptably C) small impact probabilities .
- h. The determination of air traffic on l federal airway V313 and for the private sirport Martin.
- C) 1. 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 ,
- O business phone numbers, and qualifications
! (including educational & occupational ex-perience) . ] ANSWER: The person most closely involved with the activi-
.O ties listed in Interrogatory No. !0 is Richard A. Witt, Associate and Senior Structural Project Engineer at Sargent
& Lundy, 55 East Monroe Street, Chicago, Illinois 60603, (312) 296-7092. Mr. Witt's qualifications are as follows:
l Education: M.S.C.E. 1967, South Dakota School of Mines
. B.S.C.E. 1963, South Dakota School of Mines 10 Occupational Experience:
Mr. Witt has been working at Sargent & Lundy , since 1968. He has extensive experience in the 33 structural- design and engineering of major steam-electric generating stations. Prior to assuming his present responsibilities , Mr. Witt was the structural project engineer for the Clinton Power Station and coordinated the structural and civil !O ! iO
O engineering design effort which included plant structure design, cooling lake design, highway O and trackwork alterations, site development work, and state and federal permit application work. Mr. Witt has also been an assistant chief atructur-al engineer with responsibility for coordinating the work of several design sections within the Structural Department, including the precipitator 's structures design section and the coal handling structures design section. Mr. Witt has also served as e supervising design engineer on a fossil-fusled power station project, and as a structural analyst involved in the detailed design of coal power station structures. Prior to joining O Sargent & Lundy in 1968, Mr. Witt was an engineer-ing officer with the U.S. Army Corps of Engineers. He did construction work ir. Korea. Professional License:
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Structural Engineer, State of Illinois The person at Illinois Power most closely involved with the activities listed in Interrogatory No. 10 is identi-fled in the answer to General Interrogatory No. 3 under this contention. Contention 9 [ General Interrogatory No. 3: Identify by name, g title, and qualification the IP employee that has the expert knowledge required to support the answer to the question.] ANSWER: The Illinois Power employee with knowledge neces-O sary to support ~the answers to interrogatories relative to.this contention is Larry S. Brodsky, his title is Assis-O O ,
P ( tant Power Plant Manager, and his qualifications are set forth in the answer to Interrogatory No. 9.4. [ General Interrogatory No. 4: Explain whether IP is presently engaged or intends to engage in any further research or work which may 3 affect the answer. Identify such research , ' or work.] ANSWER: Illinois Power is continuously engaged in monitor-ing information that may affect the design, construction, g or operation of the CPS. Unless new information indicates the need for further investigation, Illinois Power does , not plan to conduct further research or work which may affect the answers to interrogatories relative to this contention. [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 Low As is Reasonably Achievable." (ALARA)
Include (but do not linit your answer , to) the radiation level in millirems per hour which Illinois Power considers ALARA, and the method by which such a level was calculated.] g [9.2. Identify the person or persons who deter-mined the level of radiation which Illinois Power considers ALARA. As to each person', state their name, address, and qualifica-tions (including educational and occupation-al experience).] D [9.3. Identify all documents connected in any way with the determination of the ALARA level, (and attach a copy of each such document).] D D
J ANSWER: Illinois Power objects to Interrogatory Nos. D 9.1 through 9.3 on the grounds that the information sought is beyond the scope of the admitted contention, and is therefore irrelevant. Prairie Alliance Revised Conten- [) tion 13 contained five subparagraphs relating to maintenance of occupational radiation exposure levels "as low as reason-ably achievable" (" ALARA") . Only two of these subparagraphs
) were admitted; one addressed the accuracy of area radiation monitors (" ARMS" ) , and the other addressed the number and sensitivity of continuous air nonitors (" CAMS" ) . The selec-D tive admission of two narrowly defined issues relating to the adequacy of radiation monitors does not justify a general inquiry into all potential ALARA issues.
O The definition of ALARA requested in Interrogatory 9.1 is set forth in 10 C.F.R. S 50. 34a (a) . ALARA means "as low as is reasonably achievable taking into account 9 the state of technology, and the economics of improvements in relation to benefits to the public haaith ano safety and other societal and socioecoromic considerations, and 8 in relation to the utilization 9f atomic energy in the public interest." ( A definition of ALARA cannot be provided in terms 8 of an exposure rate in millirems per hour because tne concept of ALARA is based on maintainir.g cumulative exposure "as low as is reasonably achievable." Similarly, it is not 9 9 1 I
C) l
- 1 1
feasible to calculate an ALARA '* radiation level.* Therefore
'0 there are no persons responsible for , or documents connected with, calculations of an "ALARA level."
l
- (3 [9.4. State the number of Area Radiation Monitors i which will be in constant use at the CPS, i their exact placement on or near the CPS site, and the qualifications (including i educational and occupational experience)
{ of the person (s) responsible for the obser-
- (3 vation and maintenance of the Area Radiation Monitors.]
ANSWER: Illinois Power objects to Interrogatory 9.4 on ] the grounds that the information sought is beyond the scope LO
! of the admitted contention, and is therefore irrelevant.
l The information requested in Interrogatory 9.4 does not relate to the accuracy of ARMS.
,Q The number and placement of Area Radiation Monitors l
l are set forth in Table 12.3-2 and Figures 12.2-1 through 12.2-23 of the CPS FSAR.
'O The persons responsible for the observation and
{ maintenance of Area Radiation Monitors are Larry S. Brodsky, j Robert E. Harris, O. Erskin Hickman and Don Y. Cain. Their O j qualifications are as follows: J
- 1. Larry S. Brodsky C) Formal Education: BS Chemistry University of Illinois, 19C9 Training: CPS Systems Training BWR Fundamentals U.S. Navy Nuclear Power Prototype C) UeS. Navy Nuclear Power School O
O Work Experience: Illinois Power Company O 1980 - Present Assistant Power Plant Manager, Clinton Power Station. Responsibili-ties include overall supervision , of the Operations and Radchem Departments at Clinton Power Station. O 1977 - 1980 Supervisor - Plant Operations , Technical Supervisor , Plant Super-visor, Clinton Power Station. Responsibilities included plant procedure preparation and review, O design review, development of Technical Specificatior,s , training, and supervision of Operations staff. 1975 - 1977 Results Engineer , Assistant Plant O Supervisor, Baldwin Power Station (fossil fueled) Responsibilities included plant testing, inspection, and supervision of operating personnel. C) Other Experience: U.S. Navy 1969 - 1975 Qualified Engineer Officer and Engineering Officer of the Watch in submarines. Responsibilities included supervi-O sion of reactor plant / steam o; ant operation and maintenance and training of personnel. Membe rships : American Nuclear Society O 2
- 2. Robert E. Harris Formal Education: B.S. Chemistry,1975 University of Hartford (Conn . )
O Training: U.S. Navy Nuclear Power School U.S. Navy Nuclear Power Prototype U.S. Navy Engineering Laboratory Technician School CPS Operator Training Program O O _ .- _ _ _ _ - - - - - - - - - - - - - - - - - - - - --- J
O Work Experience: Illinois Power Company O 1976 - Present Supervisor - Radchem at Clinton Power Station. Duties include supervision of chemistry, radiation protection (3 and radwaste operation staf f during design and construction of Clinton Power Station. Other Experience: O 1973 - 1976 Health Physicist at Millstone Nuclear Station. Duties included supervision of H,P. for 1BWR and 1 (CE) PWR during construction, startup and operation. BWR experience included two refuelings O with feedwater sparger replacements. 1967 - 1973 Operations Department and Radchem Department at Connecticut Yankee Atomic Power Station, Maddam Neck, Conn. () Duties included operatioa of plant, chemistry and radiochemistry and radiation protection. Participated in initial plant startup, four refuelings, including steam generater repair , turbine overhauls' plant O modifications (LPCI ins tallation ) , spent f uel shipment. 1960 - 1967 U.S. Navy nuclear program One year formal school and prototype C) training. Six months Engineering Laboratory School. Three years instructor duty. Three years aboard nuclear (PWR) powered sub-marine. O
?. O. Erskin Hickman Formal Education: B.S., Physics, 1978, s University of North Alabama 0
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- O 4
Work Experience: Illinois Power Company !C) 1981 - Present Supervisor - Radiation Protection at Clinton Power Station. Duties include supervision of radiation protection staff during design and construction of Clinton Power Station. !O Other Experience: 1979 - 1981 Nuclear Engineer, Tennescee Valley Authority, Chattanooga, Tennessee. 4 Provided engineering support to 33 nuclear stations in the area of radioactive waste management. 1978 - 1979 Health Physicist, Browns Ferry Nuclear Plant. Provided supervision of radiation protection staff. 1976 - 1978 Radiochemical Analyst, Tennessee Valley Authority. Provided Research and development support for TVA's uranium milling and mining environ-mental assessment program. 1975 - 1976 Health Physics Technician, Browns l Ferry Nuclear Plant. Provided + Health Physics surveillance and assistance for all station opera-i tions involving radiological work.
- O 1974 - 1975 Health Physics / Radiochemical Techni-
- ciant D.C. Cook Nuclear Plant.
Provided Health Physics, chemistry j and radiochemistry cssistance for operations.
)
1973 -1974 Health Physics Technician, University of Maryland. Provided Health Physics assistance for students 4 and staff in an education environment. 3 Professional Organizations: Member of American Nuclear Society, Chattanooga Section; Member of Health Physics Society; Alterr. ate member of EEI Health Physics Com-mittee. g iO
9
- 4. Don Y. Cain D
Formal Education: B.S.M.E. Auburn University, 1960-1965 M.S. in Nuclear Engineering Georgia Institute of Technology, [) 1971-1972 Training: Westinghouse Nuclear Training Center, 1972-1973 SRO License Preparatory Training CPS Systems Training Work Experience: Illinois Power Company 1980 - Present Assistant Power Plant Manager, Clinton Power Station. Responsibilities include overall D supervision of the Mechanical, Stores Electrical and C&I Departments at CPS. 1976 - 1980 Supervisor - Maintenance , Clinton Power Station 9 Duties include direction and super-vision of the development of the mechanical, electrical and instrument / controls maintenence program, and development of the plant stores Other Experience 1971 - 1976 Alabama Power Co., Farley Nuclear Plant. ) Maintenatace Supervisor. Directed development of plant mechanica], electrical, and instrument / controls maintenance program. 1969 - 1971 Alabama Power Co. , Greene Country ) , Steam Plant. Generating Plant Engineer in a 500 MW coal-fired power plant ) d
O 1968 - 1969 E.E. duPont deNemours and Co.g g Inc. Provided engineering consulting I services to several duPont plants. 1966 - 1968 Southern Electric Generating Co. , Test Engineer in a 1000 MW coal-fired power station 3 1965 - 1966 Southern Services, Inc., Junior Engineer and Assistant Engineer in a power plant mechanical design section.- D [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 ) j 120% was arrived at, including an itemized description of all sources of the +20% deviation and a description of the method by which the 120% devia-tion from accuracy was determined.] j ANSWER: The 120% figure in Section 12.3.4.1.1.1 of the FSAR refers to the degree of accuracy specified by Illinois Power. This degree of accuracy meets the requirements The ARMS ordered by Illinois Power are
) of ANSI 6.8.1.
accurate to within 115%, which is consistent with ARMS that are commercially available.
)
Accuracy may fluctuate by as much as 120% because of the inherent energy dependence of the detector , which ref ers to the variation in response of the detector when i
)
exposed to equivalent gamma dose rates but different gamma energies. Since gamma radiation at CPS will be f rom a number of different isotopes within the range of 0.05 to
)
3 MeV, it is possible that the observed response of the
)
O detector mey deviate as much as 120% from the true value. O As part of calibration, the energy dependence of the detectoc will be periedically checked to ensure that it does not , exceed 120%. [9.5.(b) Identi fv the person (s) responsible for making any calculations or measure-ments concerning the accuracy of the ARM. As t o each person, state his/her/their name, address, and qualifications, including educational and occupational experience.] ANSWER: The persons responsible for calculations and measurements during calibration are Larry S. Brodsky, Robert E.
)
Harris and O. Erskin Htckren. Their addresses and quali-fications appear on their resumes attached to the Answer to Interrogatory No. 9.4.
)
[9. 5. (c) State why !111nois Power considers the 120% deviation from accuracy of the ARM to be a reasonable assurance of accuracy.] 3 ANSWER: ANSI 6.8.1 states that 120% energy dependence is an acceptable value. Alarm setpoints are based on conser-vative values to compensate for the 120% energy dependence. 3 [9. 5. (d) Identify and attach all documents and other papers which are connected in any way with the accuracy of the ARM] 3 ANSWER: Relevant documents are available for inspection
- at the offices of Illinois Power.
D J
O [9.6. With regard to CPS FSAR 12.3.4.2.3. concern-ing the monitoring of radiation levels:
)
(a) F:cate the frequency or amount of
- nonitoring which Illinois Power con-siders to be " minimum monitoring".]
ANSWER: A continuous air monitor (" CAM") by dnfinition
)
samples continuously. The reference to " frequency" or
" amount" is therefore unclear.
[9. 6. (b) State the method of calculation and tne name (s) , addresa (es) , and qualifica-l tion (s) of the person (s) making the I calculation.] ANSWER: The request for " method of calculation" is unclear. 7) Since monitoring is continuous, there is no calculation of monitoring " frequency" or " amount," nor is there any q) reference to calculations in the relevant FSAR sections. [ 9. 6. (c) Identify and attach all documents and other papers which are connecteG in any way with the amount or frequency of monitoring.] {) ANSWER: Relevant documents are available for inspection at the offices of Illinois Power. S [9.7. In reference to CPS FSAR 12.3.4.4.2.B. concerning the detection of maximum permissa-ble concentrations: (a) State what is meant by Maximum Permiss-g able Concentrations. Include in your answer what Illinois Power Company considers to be a " Maximum Permissable Concentration", and the names, addres-ses, and qualifications of the persons who determine the Maximum Permissable e Concentrations.] O
O ANSWER: The term Maximum Permissible Concentration (MPC) O is an industry and regulatory standard measure of airborne radioactivity concentrations. The values for MPC are set forth in 10 C.F.R. Part 20, Appendix B. a v . [9.7. (b) State the reasons why it may take up to 10 hours to detect such concentra-tions.] ANSWER: The 10-hour detection time is a reflection of g the low levels of radioactivity being measured, not the sensitivity of the monitors. Standard Review Plan 12.3,
" Radiation Protection Design Features," in paragraph II.4.b.1, g
j states that "the monitoring system should be capable of detecting ten MPC-hours of particulate and iodine radioacti-vity in any compartment which has a possibility of containing I) airborne radioactivity and may be occupied by personnel." The CPS CAMS meet or exceed this requirement. 3 [9.7. (c) State what danger exists for plant workers and local residents who are exposed to more than the Maximum Permissable Concentration for periods of up to 10 hours.] ANSWER: Illinois Power objects to Interrogatory No. 9.7. (c) on the grounds that the information sought is beyond the scope of the admitted contention, and is therefore irrele-a ' The information requested in Interrogatory No. 9.7. (c) vant. does not relate to the number or sensitivity of CAMS. 3 O
O Illinois Power is not aware of any specific study C) of the effects of exposure to radioactivity concentrations in excess of MPC for time periods of less than ten hours, i nor can Illinois Power summarize all the information in O the public domain concerning effects of exposure to radi-ation. - [ 9. 7. (d ) State what data or calculations were D utilized in determining the answer to 9.7. (c) above.] ANSWER: Not applicable. O [9.7. (e) Identify and attach any documents or other papers connected in any way with the determination, detection, and effects of the Maximum Permissable Concentration.] C) ANSWER: Illinois Power has no documents connected speci-fically with the determination, detection, or effects of radioactivity at MPC. Documents concerning the determination, 3 detection, or effects of radioactivity concentrations in general are outside the scope of the admitted contention and are too numerous to identity or provide. r3- [9.8. In reference to CPS ESAR 12.3.4.5.1.1. concerning representative samples: (a) State the method by which represenca-tive sampling will itc performed in J worker occupied zones, ventilation ductr, and other atocs. (b) If the method (s) listed in 9-8(a) deviate in any manner from the recom-mendations of the A.N.S.I. Guides,
~57-t c
l,- - - . . - ., - -. ,- _, ,. _ _ _ . _ _ _ . _ . . _ _ _ _ . _ . . . , . . _ _ _ . , _ . , ., _ . . _ _
O state the nature of each such devia-tions and the reason for each such
- 1) deviation. If Guides other than the A.N.S.I. Guides were used, identify the guide (s) used.
(c) State the reasons why any deviation from A.N.S.I. guides are justified. (d) State the name (s) , address (es) , and qualifications of the person (s) respons-ible for formulating the method by which random sampling would be per-formed. (e) Identify and attach all documents or other papers connected in any manner with the method of representa-tive sampling at CPS.] ) ANSWER: Illinois Power objects to Interrogatory 9.8 on the grounds that the information sought is beyond the scope of the admitted contention, and is therefore irrelevant. 3 The information requested in Interrogatory No. 9.8 does not relate to the accuracy of the ARMS or the number or sensitivity of CAMS. J [9.9. In reference to CPS FSAR page 1.8.-161 (2) concerning Illinois Power Company's request for an exception from 10 CFR 20.203: (a) State the reasons why Illinois Power ) Company is justified in seeking an exception from 10 CFR 20.203. (b) State whether Illinois Power Company wishes to increase the radiation levels in lockout zones. If so, ) state the amount by which Illinois Power Company wishes to increase such levels (over the level specified in 10 CFR 20.203) and the reasons why the Company wishes to increase such levels. 7
)
iO i (c) State the type of Administrative controls which will be utilized to [3 insure the safety of plant workers i if an exception from 10 CFR 20,203 . is granted. Include in your answer the name (s) address (es) , and qualifica-tions of the person (s) who formulated ! the Administrative Controls.
- O
, (d) State whether the administrative controls referred to in 9.9(c) have i ever been tested. If so, state the date and location of any such tests, and the name (s) , address (es) , and
- O qualifications of the person (s) who j formulated and/or administered, and/or d
evaluated such tests, j i (e) State what is meant by " radiation "q) 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 personnel will
-) ' be allowed in any lockout zone or j area where radiation levels require
! locking. t i (g) State in detail the location of at:7 lockout zone or area where radiation
- 5) levels require locking. Include a map of such areas in relation to the rest of the plant.]
ANSWrn: Illinois Power objects to Interrogatory No. 9.9
'O on the grounds that the information sought is beyond the I
scope of the admitted contention, and is therefore irrele-vant. The information requested in Interrogatory No. 9.9 does not relate'to the accuracy of ARMS or the number or
- sensitivity of CAMS. The information requested relates to
! precautionary procedures under 10 C.F.R. S 20.203. Prairie O
c
}
O
1 l l e Alliance Revised Contention 13(a), which raised issues 8 concerning compliance with 10 C.F.R. S 20.203, was specifical-ly rejected by the Board in its Order of May 29, 1981. [9.10. In reference to CPS FSAR page 1.8-161(3) S concerning deviations from positions stated in the Regulatory Guide: (a) State the nature of any deviations from the Regulatory Guide specified in CPS FSAR, page 1.8-161(3) , and 9 explain why such deviations are justified.] (b) State the name (s) , address (es) , and qualifications of the person (s) who formulated and/or approved any 3 procedures deviating from the Regula-tory Guide.] ANSWER: Illinois Power objects to Interrogatory 9.10 on the grounds that the information sought is beyond the scope of the admitted contention, and is therefore irrele-vant. The information requested in Interrogatory No. 9.10 relates to the use of pressure gauges instead of transmitters at instrument readout locations. The information requested does not relate to the accuracy of the ARMS or the number or sensitivity of CAMS. Contention 11 [ General Interrogatory No. 3: Identify by name, I title, and qualifications the IP employee that has the expert knowledge required to support the answer to the question.]
)
O ANSWER: The Illinois Power employee with knowledge neces-O sary to support the answers to interrogatories submitted under this contention is Larry S. Brodsky, his title is Assistant Power Plant Manager, and his qualifications are () set forth in the answer to Interrogatory No. 9.4 of Conten-tion 9. [ General Interrogatory No. 4: Explain whether O IP is presently engaged in or intends to engage in any further research or work which may affect the answer. Identify such research or work.] ANSWER: Illinois Power is continuously engaged in moni-O toring information that may affect the design, construction, or operation of the CPS. Unless new information indicates the need for further investigation, Illinois Power does
)
not plan to conduct further research or work which may affect the answers to interrogatories submitted under this g contention. [11.1. In reference to CPS FSAR 12.3.4.4.2.1 page 12.3-24: (a) State the highest and lowest anticipat-g' ed radiation levels at CPS, the method by which such levels were computed , and the name (s) , address (es) , and qualifications of the persen(s) . who made the computations. O State what is meant by the " sufficient (b) margin" mentioned on page 12.3-24 in the second paragraph. (c) State the method by which "a suffi-cient margin" is determined, and z) O
. . - . . _ - - . --- . - - . , , , , - - - - c -- , , - - - . -- . - - - ., . ,
iO 1 l the qualifications and job titles
- of the person (s) who would make iO such a determination.
(d) Identify and attach any documents or other papers relating to the determination of a suf ficient isorgin.] I C) ANSWER: Illinois Power objects to Interrogatory No.11.1
- on the grounds that the information requested is beyond j the' scope of the admitted contention, and is therefore O irrelevant. The issues raised under Contention 11 concern i
the effects of low-level radiation releases from the CPS. i ! Interrogatory No. 11.1 requests information concerning O occupational radiation exposures at the CPS site. Although Contention 9 relates to occupational radiation exposures, I the information requested in Interrogatory 11.1 is also
) beyond the scope of Contention 9 for the reasons set forth in the Answer to Interrogatory Nos. 9.1-9.3.
t + [11.2. In reference to estimated population l C) doses of radiation: (a) State the method by which estimated population doses were calculated. Include in your answer the name (s) , t address (es) , and qualifications lO of-the person (s) making such calcula-tions.] i ANSWER: Illinois Power objects to Interrogatory No. ll.2(a) n the grounds that the information requested is beyond f0
*~
j the scope of the admitted contention, and is therefore
; irrelevant. Prairie Alliance Revised Contention 15 contained i
() 1 five subparagraphs relating to low-level radiation releases. i i .h
. . . . . . . . _ . _ _ . . _ . _ . . . ~ . , . . _ . . . . - _ _ . _ , _ . , _ _ . . . . . - . - _ . _ . , _ , _ _ . _ _ _ _ . . . - . . . , . . . . . . _ _ _ _ , , _ . . _ _ . _ _ _ . . _ . _ . . .
9 : 1 Three of these subparagraphs were admitted; the first ad-O dressed the consideration of releases from CPS Unit 2 in estimating population doses, the second addressed the validi-ty of estimates used in calculating atmospheric effluents, 8 rnd the third addressed the consideration of the ef fects of low-level releases in the cost-benefit analysis of the Environmental Report. 3 Interrogatory No. ll.2(a) requests general informa-tion concerning the calculation of estimated population doses. It is not limited to information concerning anticipat-ed releases from CPS Unit 2, and it therefore exceeds the scope of the admitted contention. [ll.2(b) State whether gaseous effluents from 3 Clinton Unit 2 were considered in the above calculation. If not, state the reasons why Clinton Unit 2 should not be used in such calculations.] 3 ANSWER: Gaseous effluents from Clinton Unit 2 were not presented in the FSAR. However, if Clinton Unit 2 doses were conc dered, the radiological consequences would be similar to those estimated for Unit 1. 3 [11.3. In reference to CPS FSAR page 1.8-20, Regulatory Guide 1.111, concerning the calculation of atmospheric effluents of routine releases: h (a) Describe in detail the methods :tsed in the calculation of such effluents. Include in your description the name (s) , address (es) , and qt'alifica- ) tions of the person (s) who made such calculations.
)
l 4 ANSWER: Illinois Power objects to Interrogatory No. ll.3(a) l O on the grounds that the information requested is beyond l the scope of the admitted contention, and is therefore irrelevant. Interrogatory No. ll.3 (a) requests general 8 information concerning the calculation of atmospheric efflu-ents. It is not limited to information concerning the validity of estimates used in such calculations, and it
- 2) therefore exceeds the scope of the admitted contention.
[ll.3(b) State why " conservative estimates con-sidered here are unnecessary" (CPS FSAR Page 1.8-20). g (c) State the name (s) , address (es) , and qualifications of the person (s) who decided that conservative estimates were unnecessary.] ) ANSWER: Regulatory Guide 1.111, Position C.3.a., allows the actual half-lives of the radionuclides to be used, thereby precluding the need for estimates. D [11.4. In reference to CPS FSAR page 1.8-169, Regulatory Guide 8.19, concerning dose assessments: ) (a) Stata whether records of review procedures, documentation requirel ments, and identification of principal ALARA related changes resulting from the does assessment will be included in the assessment. If ) not, explain why not in detail. (b) If the items in ll.4 (a) are not to be included in the assessment, state the name (s) , address (es ) , and qualifications of the person (s) who determined that such items should )
)
l O , not be included in the dose assess-ment.] , ANSWER: Illinois Power objects to Interrogatory No. 11.4 on the grounds that the information requested is beyond the scope of the admitted contention, and is therefore e irrelevant. Interrogatory No. 11.4 requests information concerning occupational dose assessments, not the effects of low-level radiation releases. Although Contention 9 relates to ocupational radiation exposures, the information requested in Interrogatory 11.4 is also beyond the scope of Contention 9 for the reasons set forth in the Answers to Interrogatory Mc3. 9.1-9.3. [11.5. In reference to the release of radionu-clides frem Clinton Units 1 and 2: D (a) State whether there would be any residual low level radiation resulting from the release of radionuclides. (b) State whether such residual radiation ) was assessed and factored into the N.E.P.A. cost-benefit analysis. If so, state the method by which such residual radiation was so as-sessed and factored, and the reasons why such assessment and factoring ) should be adequate under N.E.P.A. If not, explain why such residual radiation should not be properly included in a N.E.P.A. cost-benefit analysis.] ) ANSWER: Effluent releases from normal operation will result in a slight increase in the general background levels of radiation near the site. This increase has not been )
)
O predicted for the CPS site because the amount of increase D depends on a complex interrelationship of such variables as deposition velocity, vegetaticn cover, isotopic decay, release height, and meteorological conditions. It should D be noted, however, that Unit I will be operating under the design dose objectives set forth in 10 C.F.R. Part 50, Appendix I. These objectives are 5 mr/yr whole body, 15
- mr/yr beta skin, and 15 mr/yr from iodine and particulate fission products. The maximum offsite dose is therefore approximately equal to 10% of that from natural background 3 sources.
The effects of residual low level radiation have been assessed as discussed in CPS-ER (OLS) Section 5.2. 3 No dollar value has been assigned to these effects because this is not required by NRC Regulatory Guide 4.2, Rev. 2. 3 J ) 9 O
. . --_ _ _ _ _ ____ _ _. _- ._ . ~,
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10 i iO ILLINOIS POWER COMPANY l By:,
// Leonard J.goch j
i Vice President !O IGNED AS TO OBJECTIONS: l
-+ '
Peter V. Fssib ,Qr). One of the Attorneys for- {O Applicants. i 4 i lO i 1 1 i !O l 1 l
- O 1
i ! Sheldon A. Zabei ! William Van Susteren ' j Charles D. Fox IV 'O SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive j Chicago, Illinois 60606 ! (312).876-1000 !O ' Dated: July 27, 1981. -
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3 STATE OF ILLINOIS ) D ) SS COUNTY OF MACON ) LEONARD J. KOCH, being duly sworn, deposes and J says that he is Vice-President of Illinois Power Company, one of the Applicants in the proceeding; that he has read the foregoing Response of Illinois Power to Prairie Alliance's 3 First Round of Discovery, and that the Answers contained therein are true and correct to the best of his knowledge, f information, and belief. O A Leonard J. yioch
.)
SUBSCRIBED and SWORN to before me thic a.a4 day of July, 1981.
)
Y hu . , ,, ? 7h b0
// Notary Public ..)
O 0 s O
O CERTIFICATE OF SERVICE O I hereby certify that the original of the foregoing document was served upon the following: C) Prairie Alliance P. O. Box 2424 Station A Champaign, Illinois 61820 and three conformed copies of the foregoing document were filed with the following: i Secretary of the Commission United States Nuclear Regulatory Commission j Washington, D.C. 20555 O Attention: Docketing and Service Branch and that one copy of the foregoing document was served upon each of the following: -g Hugh K. Clark, Esq., Chairman P. O. Box 127A Kennedyville, Maryland 21645
$) Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.
Washington, D.C. 20059 C) Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director I) United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General
, Environmental Control Division J 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission J Washington, D.C. 20555
) Atomic Safety and Licensing D Appeal Board Panel U.S. Nuclear Regulatory Ccatmission Washington, D.C. 20555 in each case by deposit in the United States Mail, postage D prepaid on July 27, 1981. D D N 4 N' Fe,ter V. Fazio,%Tr. V One of the Attorneys for Applicants SCHTFF HARDIN & WAITE 7260 Sears Tower ) 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 1 w
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