ML20010B311

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Answers to Applicant First Round of Interrogatories. Certificate of Svc Encl
ML20010B311
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 08/01/1981
From: Lang T
PRAIRIE ALLIANCE
To:
ILLINOIS POWER CO.
Shared Package
ML20010B312 List:
References
ISSUANCES-OL, NUDOCS 8108140348
Download: ML20010B311 (39)
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4 Contention Ib.1

1. Terri Iang Iaw Clerk Iaw Offices of Yoho, Gerstein & Prillaman 311 West University Avenue Champaign, IL 61820 (217) 359-0067
2. Peter Penner Member of Prairie Alliance, Inc.

2113 Sheffield Chicago, IL 60614 (312) 525-2357 3,4,&5. Fbr each allegation made in Contention 1, the following table lists the allegation, the factual basis for such allegation along with 4

documents relied upon by PA, and the requirement (s) violated by IP.

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8108140348 810001 PDR ADOCK 05000461 0 PDR-

Allegation Factual Basis Requirements Violated (found in section) i l 1(a) 'Ihe CPS Bnergency Plan in the FSAR does not discuss or 10 CFR 50.54 Appendix E

, set forth an EPZ. Part III Paragraph 2 i

1(a)1 'Ihe response to this section is wholly identical to and a

contained in our response to applicant interrogatory No.12 answered below.

1(a)2 The response to this section is wholly identical to and contained in our response to applicant interrogatory No. 13 answered below.

1(a)3 'Ihe response to this section is wholly identical to and contained in our response to applicant interrogatory No.14 answered below.

1(b) The CPS FSAR EP Section 4.4. on coordination contains no NLTEG-0654 Rev.1, p.39 concrete arrangments with participating agencies. Agrements No. 9 made with certain medical service organizations are no more than two sentences long and therefore do not contain specificity, concreteness, or adequate assurance that such agreements are meaningful.. Agreermnts do not delineate the authorities, responsibilities, and limits on the actions of support groups.

1(c) 'Ihe CPS FSAR EP section 7.1.1.3 incmpletely describes the NUREG-0654 Rev. 1, p.75-training of local services personnel and does not identify Section 0.1.a the organization or individuals who will (b the training or the training scledule.

No mention is made in the CPS FSAR IPof a radiological orientation 10 CFR 50.54 App. E part F.

program such as is required by 10 CFR 50.54 Appendix E.

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Allegation Factual Basis Requirments Violated (found in section) 1(d) (1) Section 5.5.4 of the CPS FSAR EP does not identify all persons 10 CFR 50.54 Appendix 2 with special qualifications as required by 10 CFR 50.54 App. E Part IV A.5 and does not describe the special qualifications.

1(d) (2) The notification section 5.1.3.5 of the CPS FSAR EP sets forth no 10 CFR 50.54 Appendix E criteria for determining the need for notification and participation p. IV. B of local, state, and government officials.

1(d) (3) Section 5.4 of the CPS FSAR EP contains no analysis of the time NUREG 0654 p. 45 required to effectuate protective measttres in addition to its Par *. E.6 p. 61 part J.8 lack of use of an EPZ.

1(d) (4)+(5) Section 5.2 of the CPS FSAR EP does not identify those parties 10 CFR 50.54 Appendix E responsible for off-site dose projections nor the methods for part IV B.

making th m nor the means by which off-site dose projections will be made.

1(d) (6) Section 7.0 of the CPS FSAR EP contains no mention of yearly 10 CFR 50.54 Appendix E dissminations to the public of mergency planning information, part IV D.2 general information as to the nature and effects of radiation, or a listing of local broadcast stations that will-be asked for disseminating information during an emergency.

1(d) (7) (8) Section 5.1.3.5. of the CPS FSAR EP does not identify appropriate 10 CFR 50.54 Appendix E state and local government officials requiring notification under part IV D.1, IV D.3 accident conditions, nor does it dmonstrcte that state and local officials have the capability to make a public notification decision prosoptly upon being informed of an emergency condition.

1(e) Section 5.4 of the CPG FSAR EP does not contain plans to inplment NUREG-0654 p. 61, parts protective measures for the plume exposure pathway. In addition, J9 and J10 the plan contains no docuentation of the capability of each state and local organization for inpleenting protective measures based upon protective action guides and other criteria.

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Allegation Factual Basis Requirments Violated (found in section) 1(f) 'Ihe CPS FSAR EP contains no doctunentation of the Technical Support NUREG-0696 part I.B.

Center, the Operational Support Center, the Dnergency Operations Facility, 'Ihe Safety Parameter Display Systs, and the Nuclear Data Link whatsoever in any section.

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6. At this time Intervery;sr does rot know, to the extent that this Interrogaory calls for an anser concerning expert testinony, what individuals it intends t.o call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non-expert testimony.
7. Same answer as in 6, above.
8. Same answer as in 6, above.
9. Intervenor does not know at this time.
10. See chart for answers to 3, 4, &5.
11. Intervenor does not know at this time.

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12. Two problens in contention re.1 (a)(1) which we believe nust be considered in the Dnergency Plan (hereafter EP) are as follows:
a. The EP does not include or make references to written agreemnts referring to the concept of operaticns developed between Federal, State, and local agencies and other support organizations having emergency response roles.
b. 'Ita EP does not document either Wal arrangements or special exceptions regarding the notificatica of persons within renote, less accessible portions of the recreational areas adjoining the CPS.

'Ihe reason these problems should be. considered in the EP are, respect-ively:

a. NUREG 0654 (Pav.1) page 32, requires that matters of jurisdiction between governmental units involved in notification activities be clearly resolved, and
b. NUREG 0654 (Rev.1) page 3-3 states that the minimum acceptable design objectives for an EP include the docatation of arrangenents made regarding renote or inaccessible areas.
13. The following list contains special facilities referred to in our contention 1(a) (2) . Exact addresses are not known.
1. John Warner Hospital
2. Crest View Nursing Hane
3. DeWitt County Nursing Hane
4. DeWitt County Mental Health Center
5. DeWitt County Court House
6. Clinton County Club
7. Arrowhead Acres Camp
8. Little Gali]ee Christian Assenbly Church Canp
9. Weldon Springs State Park
10. Clinton High Scnool
11. Clinton Junior High School
12. Douglas Grade School
13. Lincoln Grade School
14. Washington Grade School
15. Wesbster Grade School-
16. Wapella Junior High and High School
17. Wapella Grade Schcol
18. Deland Weldon Grade School
19. Deland Weldon High School

j one major difficulty posed by such facilities is obviously the question

! of notification. Persons in such facilities may be involved in activities which render than unavailable to contact via normal ccumunication channels.

A second major difficulty posed by such facilities is transportation.

Page 4-3 of NUREG 0654 (Rev.1) states clearly that the means of tranamrtation 1

of persons frcan such facilities are highly indivianalized and nust be j described.

Additional difficulties include but are not limited to the provision of ongoing n= dical care to residents of. such facilities and security measures required for the control of persons in these facilities.

j 14. The EP contained in the CPS FSAR fails to utilize the energency planning zone and it fails to <h,==nt evacuation time estimates within the plume

- exposure pathway. Part IV A. of Appendix 4 states that such analysis of evacuation time nust cassider adverse circumstances which "could include flooding, snow, ice, fog, or rain". 'Ihis section further states that "the -

adverse weather frequency used in this analysis shall be severe enough to define the sensitivity of the analysis to the selected events." Without the inclusion by IP of this information, we are unable to specify the exact severity of conditions for which planning is inadequate.

15. The Intervenor 'does not kncy the exact 17 agencies requested in interrogatory
  1. 15, but the Intervenor is aware that IP had made it evident to the NBC that it intended to make arrangements with 17 named agencies, as well as local hospitals and physicians.

The applicant has identified and indicated their. intent to make arrangenents with seventeen named agencies as well as othe2s such as local hospitals and physicians. In_ order to effectively implement their final energency plan, the applicant will establish i agreements with the law enforcement agencies, fire departments, civil defense departments, AEC regional office, medical support organizations, and the health department including the Illinois I

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Department of Public Health. . . ." NUREG-75/013, Safety Evaluation of the CPS Units, 1 and 2, 513.4, p. 13-5 (3/75)

Applicant has only made cursory agreements with seven agencies as found in CPS FSAR Vol. 16, ch. 13.3, Appendix B, p. B.4-B.ll:

1. DeWitt County Bnergency Services & Disaster Agency (B4)
2. Illinois Department of Public Health (BS)
3. John Warner Hospital (B6)
4. DeWitt County Sheriff's Departnent (B7)
5. Illinois Bnergency Services & Disaster Agency (B8)
6. Clinton Amb21ance Service (B9)
7. T11inois Department of Conservation (B10-ll)

More meaningful agreenents need to be made with these seven agencies, and meaningful agreerents need to be established with the other ten agencies IP intended to contact, including fire departments, hospitals, local law enforcement agencies and civil defense departments, ADC regional office, and medical support organizations.

Regarding the description of those terms and canditions which must be included in such ._greenents in order to make then meaningful, we note the following:

1. Scne of the named agencies appear to have no agreement with IP executed whatsoever.
2. Scme agencies which have executed agreenents with IP appear to have executed from letters containing a total of two sentences. One of these sentences is "I ".cok forward to working with you in the future as plans finalize. " Therefore it is obvious.that finalized plans have not been made with these agencies and that the preliminary agreenents lack any substance whatsoever beyond the existing test of the FSAR EP.
16. NRC regulations contained in NUREG-0654 Plar.ning Standards Section J set forth eleven evaluation criteria for protective response activities.

Of these criteria, we contend that the following criteria are not met by the CPS FSAR EP:

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1.  ?.e means and time required to warn or advise onsite individuals are not set forth.
2. The capaba.lity to account for all individuala onsite at the time of the emergency and ascertain the names of missing individuals within thirty minutes is not set forth.
3. There is no documentation of the ability to provide certain protective equipent to individuala arrtving onsite during the emergency.
4. The plan does not set forth time estimates for evacuation within the plume D Z.
5. The plan does not set forth certain protective taeasures for the plume exposure p thway such as maps showing evacuation areas and other information, means for notifying all segments of the transient and resident population, and other measures set forth in NUEG 0654.

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Contention No. 2

1. Terri J. Lang law Clerk Iaw Offices of Yoho, Gerstein & Prillaman 311 West University Avenue Chanpaign, IL 61820 Telephone: (217) 359-0067
2. Reed W. Netznan Assistant Attorney General 500 S. Seccrid Street Springfield, IL. 62706

., Telephone: (217) 782-9031 Bradley T. Turner 1007 S. Oak, #4 Q1anpaign, IL 61820

3. Intervenor objects to this Interrogatory on the grcar.vi that it is overly broad. However, to the extent that. Intervenor is able to answer this Interrogatory, it subnits the following:

I See Answer to Interrogatory No. 17, below. In addition, sae the following 1 NBC Region III Inspection Reports: .

81-07 80-20 L 80-19 80-14 80-15 80-07 79-11 79-01 78-05 78-06 77-11 76-02 In aMition, Intervenor notes Applicant's inexperience in nuclear facility construction, and Applicant's history of schedule slippages, mis-est2mation of tasks, failure to take renedial measures prcmptly, problens in ma2.ntaining its manpower pool, and allowance of continual cost overruns, as documented in' Illinois Ccmnerce Ccmnission proceedings Nos. 79-0071 and 80-0167, the latter prWing initiated by the ICC to study Applicant's management practices.

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4. 10 CFR 50.34(b) and Part 50, Appendix B; Reg. Guides 1.8, Rev. 2; 1.28

, Bev. 2; 1.30, Rev. 0; 1.33, Rev. 2; 1.123, Rev. 1; 1.71, Bev. 0; 1.58, Rev. O.

5. See Answers to Interrogatories NaL3 and 4, above. In addition, reference is made to Chapter 13 of the FSAR and to these parHO11 e portions thereof:

Sections 3.11, 7.1, 7.2, 7.3, 7.4, 7.5, 7.6, 7.7, 8.1, 8.2, 17.1 and 17.2 Subsections 5 3.1.4 and 10.3.6.

6. At this time Intervenor does not know, to the extent that this Interrogatory calls for an answer concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non*W testimony.
7. See Answer to No. 6, abcn.*e.
8. See Answer to No. 6, above.
9. Intervenor does not know at th.ts time.
10. See Answer to No. 5, above.
11. , Intervenor does not kro. at this time..
17. Intervenor objects to this Interrogatory on the ground that it is burdensczne.

To the extent that Intervenor can answer this Interrogatory, it subnits the following.

See the following NRC Region III Inspection Reports:

81-09 80-06 77 80-21 80-08 77-09 80-18 80-04 77-06 80-17 80-03 77-05 80-16 80-02 77-03 80-13 80-01 77-02 80-11 79-12 77-01 80-12 79-01 76-06 80-10 79-06 76-05 80-09 79-08 76-04 79-03

18. See Answer to Ib.17, above.

Contention No. 3

1. Terri J. Lang Law Clerk Law Office of Yoho, Gerstein & Prillaman 311 W. University Avenue Chanpaign, IL 61820 (217) 359-0067
2. Craig Ehrlich Law Offices of Feiwell, Galper & Lasky 33 North IaSalle, 33rd Floor 011cago, IL 60602 (312) 782-4844 Beed W. Neuman Assistant Attorney General-Envirenmental "w ntrol Division 500 S. Second Street Springfield, IL 62706 (217) 782-9031
3. See answer to Interrogatory No. 19, below.
4. 10 GR 50.33(f) and Part 50, Appendix C.
5. Exhibits, tran. scripts, pldings, briefs and other documents associated with Illinois Ca merce Cr - ission p W ings No. 79-0071, 80-0544, and 80-0365.
6. At this time Intervenor does not know, to the extent that this Interrogatory calls for an answ.r concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for au answer concerning non-expert testimony.
7. See Answer to Interrogatory #6, above.
8. See Answer to Interrogatory #6, above.
9. Intervenor does not know at this time what exhibits it intends to introduce.
10. Not. applicable.
11. Not applicable.
19. Intervenor objects to this Interrogatory to the extent that it suggests that criteria utilized by or judgments on the part of Intervenor should sane-how supplant the showing required of Applicant by 10 CFR 50.33(f) and Part 50, Appendix C. In the spirit of full disclosure, however, without waiving this objection, Intervenor subnits the following:

Intervenor subid.ts that many factors underscore the need for Applicant to satisfy the requirements of 10 CFR 50.33(f) and Part 50, Appendix C, including but not limited to the following more such information may _W available as a result of the discovery process):

1. Numerous representations by Applicant to, and findings by, the Illinois ccanerce Comnission to the effect that Applicant's present and forecasted financial condition is deteriorating and worse that average ccupared t.o other "AA" utilities, that Applicant is finding it increasingly difficult to raise capital e.h ly, that the attractiveness of Applicant's market instruments has declined significantly, and ttat Applicant is faced with the prospect of its securities being downgraded, making future financing more difficult and costly.
2. The fact that CPS Unit 1 may soon represent more than 50%

of Applicant's total capitalization, placing an extraordinary burden on the project and ccmpany as a whole.

3. Applicant's substantial requests for rate relief frce the Illinois Ccom,.rce Cn nission, largely to cover Carstruction Work in Progress outlays, are totally independent of funding needs to operate and shut dcun and safely maintain CPS, thus casting doubt on the future ability of Applicant to generate funds internally.

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Contention No. 4

1. Terri J. Iang Law Clerk Iaw Offices of Yoho, Gerstein & Frillaman 311 West thiversity Avenue Chan1paign, IL 61820 (217) 359-0067
2. Joanne J. Schwart Library Clerk II University of Illinois Main Library 1408 West Gregory, Ibcm 12 Urbana, IL 61801 (217) 333-1997
3. The Intervenor objects to this Interrogatory on the ground that it is overly broad. However, to the. extent that Intervenor is able to answer this Interrogatory, it states as follows:

The factual bases for the allegations that IP has not developed ard dmonstrated an adequate security plan which ccznplies with 10 CFR 73.55 are as follows:

a. In the GS-FSAR, p.l'.8-25, applicant states that the security system is not considered safety-related,
b. In the GS-FSAR p.1.8-25, applicant states that electronic conponents were not purchased under a quality assuratice program.
c. In the CPS-ESAR p.1.8-25, applicant states that thi CPS security system sets forth only general requirements for security,
d. In the CPS-EEAR p.1.8-25, applicant inplies that the CPS security plan deviates frcm formal regulations.
e. In the CPS-FSAR p.1.8-25, dated 1973, applicant states that it is only the intent of the plan u meet updated requ.1.roments for security l Pl an as they are delineated in 10 CFa 73.55; since that time there has j been nothing further mentioned concerning efforts to update the security plan.

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The Intervenor cannot answer this Interrogatory fully until the Intervenor has access to a copy of the security plan. The Intervenor hereby requests access to the security plan for the G S.

4. The requirements violated by IP are as follows:

a) 10 GR 73.55(a? ; applicant's physical security system should have ac its objective the protection of public safety.

b) 10 GR 73.55 introduction; applicant shall ocxnply with federal regulations pertaining to security systems.

c) Regulatory Guide 1.17.

5. The Intervenor relies upon the GS-FSAR p 1.8-25 to support contention
  1. 4. The Intervenor will also rely on the security plan for GS; at this time, no specific parts of the security plan can be identified because the Intervenor does not now have access to the security plan. Once it does, this Interrogatory will be answered fully. The intervenor also relies upon 10 GR 73.55 generally, and in par +1cilar parts (a); and also Regulatory Guide 1.17.
6. At this time Intervenor does not know, to the extent that the Interrogatory calls for an answer concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogvary to the extent that it calls for an answer concerning non-expert testimony.
7. Same answer as in 6, above.
8. Same answer as in 6, above.
9. Intervenor does not know at this time.
10. G S-FSAR p. 1.8-25. The GS security plan.
11. Intervenor does not know att this time.

1 Contention No. 5

1. Terri J. Lang Law Clerk Law office of Yoho, Gerstein & Prillaman 311 W. University Avenue Chapaign, IL 61820 (217) 359-0067
2. Bradley T. Turner 1007 S. Oak, #4 Chapaign, IL 61820 Gary D. Sanders 2017 Philo Road, #1 Urbana, IL 61801 (217) 384-0852 Gregory C. Minor MiB Technical Association 1723 Hamilton Avenue Suite K San Jose, CA 95125 (408) 266-2716 Philip L. Willman Assisthnt Attorney General Envi s mr.ntal Control Division 188 W. Randolph Street, Suite 2315 Chicago, IL 60601 (312) 793-2491
3. Intervenor objects to this Interrogatory on the ground that it is overly broad. However, to the extent that Invervenor is able to answer this Interrogatory, it states as follows:

(a) The BWR at the CPS is susceptible to the consequences of an A' INS event, as the NRC staff has recognized in hu EG 0460.

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! (b) IE Inspection Reports show that IP has not cmplied with NRC requirements concerning welding procedures.

(c) The analysis in the FSAR of an A' INS event is insufficient to meet the NRC Staff recumrMations in NUREG 0460.

4. 10 C.F.R. Part 50, Appendix A, Criterion 29; NUREG 0460.
5. Volumw I-IV, NUREG 0460.

IE Insp e don Report No. 50-461/78-05.

IE Inspection Report No. 50-461/78-06.

IE Inspection Report No. 50-461/79-06.

IE Inspection Report No. 50-461/80-08.

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Final Deficiency Report (7/18/80).

IE Information Notice 81-11.

IE Bulletin No. 80-14.

IE Bulletin No. 80-17.

Supplements 1-5 of IE Bulletin No. 80-17 IE Inspection Report No. 50-461/80-14.

IE Information Notice No. 81-11.

IE Inspection Report No. 50-461/81-07.

6. At this time Intervenor does not know, to the extent that this Interrogatory mila for an answer concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non-expert testinony.
7. Same answer as in 6, above.
8. Same answer as in 6, above.
9. Intervenor does not know at this time.
10. FSAR, Sections 15.8.2 through 15.8.8, page 15.8-1; Appendix 15A, page 15A.6-29.
11. Intervenor does not know at this time.

20 BWRS are especially vulnerable to AWS, when cxxtpared to PWRs, as recognized by the NBC Staff in NUREG 0460. The control rc;d system is not diverse and is therefore subject to cxamen node or cczmon cause failures.

Morever, the standby liquid control system has a small capacity, is non-redundant and is manually initiated.

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( 21. Volumes I-IV of NUREG 0460 show that BWRS are more vulnerable to AWS than PWRs. There i.s no usurance of verification of welding repairs.

22. AWS testing and analysis is part of the NPC rendations in NUREG 0460.

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23. Intervenor is aware of.the following incidents:

Hatch Unit 1, as described in IE Bulletin No. 80-14; Bru,1swick Unit 1, as described in IE Bulletin 80-14; Browns, Ferry Unit No. 3, as described in IE Bulletin 80-17; Dresden Unit No. 3, as described in Supplement No. 2; IE Bulletin No. 80-17; Duane Arnold, as described in Supplement No. 2, IE Bulletin No. 80-17; MLllstone Unit 1, as described in Supplement No. 2, IE Bulletin No. 80-17; Pilgrim Nuclear Power Station, as described in IE Information Notice No. 81-11; and t- Failure of the scram relays at the KAHL BWR in N - ny. There nay be other incidents of which Intervenor is currently unaware. However, Intervenor states that its concern is not whether an A' INS incident has occurred at other BWR units, but rather whether it mja occur at the TS Unit 1 or 2.

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Contention No. 6

1. Terri J. Larq M w Clerk Law Offices of Yoho, Gerstein & Prillaman 311 W. University Avenue Chanpaign, IL 61820 Telephone: (217) 359-0067
2. Paul F. Mueth 612 West Elm Urbana, IL 61801 Telephone: (217) 367-0622 f
3. See answer to No. 24, below,
4. See answer to No. 24, below.
5. Pelevant sections of the FSAR (see answer to No. 24, below); Instrumentation and Control System Meeting Sumary, Dockets #50-461/462,1/7-8/81; hTREGs.
6. At this t.une Intervenor doeqhot know, to the extent that this Interrogatory calls for an answer concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non-expert testimony.
7. See Answer to No. 6, above.
8. See Answer to No. 6, above.
9. Intervenor does not know at this t2me.
10. See Answer to No. 24, below.
11. Intervenor does not know at this t.ime.
24. The NUREG cites and letters and other references with scme clarification and explanation but the call to produce a statment by statemert analysis of IP's unfulfilled regulatory regturements is praature and untimely as the infantion requisite for such a cmplete study has not been made available by IP as yet. Further information via discoverf process is forthccming.
a. The water lcvel nonitoring is insufficient vis a vir NTREG 0660 II K.3, 23, II K.3., 2F, NUREG 0737 II K.3; 27 cent *al water level nonitoring to ccr.non reference log.
b. ICC monitoring is inadequate vis a vis NUREGs 0678 Rec. 21.1.3.b 69 II.F.2., 0737 IIF2 and Denton letter to O.L. applicants, 10/30/79.
c. Direct indication of SRV positions or qualifled reliable indirect indicaticns is called for by NUREGs 0578, Rec. 2.1.3.a 0660, II.D.3, 0694

' Part C, 0737 II.D.3, ocmnission, order and menorandum, 5/23/80,

d. SPDS hety Paranuter Display Syster)is provided for by NUREGS 0660 I.D.2. 0696, 0737 I.D.2. See #26 interrogatory rr.sponse, related D737 II.F.2 Clarification 10 a-d.
e. Instrumentation of monitoring accident conditions are called for NUREGs 0578 Rec. 2.1.8.b, 0660 II.F.3. 0737 II.F.1; other references are Reg. Guide 1.97 rev.2 to 3, ANSI N13.1-1969 February, 1969, Eisenhut letter to all OIS Septernber 13, 1979, Denton letter to all OLS, October 30, 1979.
f. Not applicable.
g. Carparative evaluation of the retraction of human factar and efficiency of operations is mandated vis a vis NUREGS 0660 I.D.1 0737 1.D.l.
h. Not directly applicable-sane substantive analysis of CPS Control panels offered in answer #29. Documentation requirenent. Sama for all 10 CFR 50.34(b) .
i. See h above for answer.
j. See h above for answer.

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25. NUREGs 0660 II.F.2., 0737 II,F.2., and 0696 require all BWPs to include:

incore and core exit thermoccuples with wide range reading; a core map display; and capability to record this data. Further, enclosure 3 of NUREG 0737 requires operators to be trained in interpretations of these resul'.s as preparation to mitigate core damage in cases of loss of ecolant accident.

IP stated that water level monitors are sufficient, without explaining furt.w.r, at the meeting held January 7 - January 8,1981, concerning instrumentation and control systens. It seems that IP presumes that water level ntnitoring, along with neutron monitoring, are adequate enough to mcnitor core turperature.

This ignores abrm hul occurrences, such as possible coolant flow blockages, due to fuel rod warpage, foreign body obstruction, etc.

Since detailed observation of tertperatures would produce outline of -

core map isanorphic to neutron flux core map, possible " percolation" of heat measurement on neutron flux core map could be incorporated; otherwise additional CRT prow.cun might be qualified.

We are awaiting furth_r information on this issue, at which time this interrogatory will be a:swered more fully.

26. The feature of the required Safety Parameter Display System which is j not provided for in the main control rocm at CPS is one locus for displaying l

all safety parameters called for in NUREG 0737 I.D.l.

l Clarification 8). The locus should be hard-wired with diverse style annunciators for ease of cperator obse m tion. This console should ideally be placed at the l center of the standby information panel, large enough to be fully viemd by the entire control roan. Alternatively it could be hung fran the ceiling, l with 2, 3, or 4 sides, depending on placement in the control roan. Audio 1

alarms, capable of indicating the approach of safety parameters to redlines, t

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4 should augment the system. IP made no reference to a Safety Parameter Display System at the meeting concerning instrtmentation and control systems at CPS, held January 7 - January 8, 1981. (See Instrinnentation and Con.rol System Meeting Sumary, Dockets #50-461/462, dated January 7 - January 8, 1981.

We are a'eiting further information concerning the generic selution of this issue, at which time this interrogatory will be answered nore fully.

27. IP meting sumary of 1/7-8/81 states that specificatior.s for de'/ ices designed to sample past accident conditions would be fornulated as of 2/81; also at that time reccreendations for additionti accident nonitoring would be made. The first round of disa/ery should inform u of NR OWNERS DiI GPLE intentions concerning this instrumentation.

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28. The lessons Isarned Report, NUREG 0585, called for direct or reliable indirect indications of SRV status. N re than a year later with the r

release of FSAR Amendment 1, IP suppests status could be inferred fmn l I

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RFV pressure. (p. 7.5-8). Subsequently acoustic monitoring is to l

, be implemnted; this is in use at only one other plant, Peach Bottan, i and we have no reliability t'sts e of this prototypical system fran the 7SAR.

Other concerns regarding instrumentation are the lack of stops to monitor inadequate care cooling and possible damage to the structure of the core. See amendment. A related problen is the absence of qualified RPV water level monitors and the lack of a camon reference level for the various ranges of water level mcnitoring. Wreover, the absence of a systen for checking the status of containment isolation valves without disconnecting indicators is a design error of iu w i.ance.

Problens of control that have not been adequately addressed are, f

7 among others, that of the sequencing of openings of isolation valves, the timing of the autanated action of the low pressure injection system, and techniques for minimizing the possibility of thermal shock to the RPV by the high prescure care spray.

Another basic concera is the almost canplete reliance on GE, San Jose, for the prototypical Nuclenet CR, and its lack of input to formulation of NUREG 0700. An astonishing detail of the Nuclenet panels, which we would prefer to be a mistake of description rather than of substance, is the consistent referral throughout de FSAR and January 7-8 Meeting Summary to the annunciator lights as lamps; this, presumably, y ._ _, . _ . . . -_ _ ..,._ , .. _ , _ _ . . . - , ,, ,..m 7 ,, ,

k means the primitive incandescent. The more reasonable design choices are neon or light emitting diodes.

The absence in FSAR and any other IP document of analysis and eval-uation of "and" (nulti-failure) event sequences is a glaring lack of fulfilhnent of post-IMI requirements. 2 has done sane study of these conbinatory accident scenarios, but if the evaluation is done per the new multi-failure methods, the event frequency categories should be modified.

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29. The Principal Plant Console, as illustrated in the FSAR figure 7.5-3 does not include hardwire annucinators as to the status of the various actnponents of the ECCS.

information The Principal Plant Console does not give hardwireb as to the status of of SFNs (failurehannunciators of SRV's to reclose after challenge is the most probable cause of maal1 break IOCA) . Qualified RPV Water Iavel Monitor information should 'be hardwired to the Principal Plant Console.

These, at least, should be included in main ope:Jator's innw14 ate proximity.

Further information is fortheming via the discovery process.

Discrepancies exist in the FSAR. Figure 7.5-3; Illustration of Principal Plant Console does not provide ccrrplete definition of the front control panel.

There is a missing page alluded to in fine print of diagram legend but which is not 'allwlul' to in the diagram identification, as is usual form.

Another error is the relegation of the RWCU Reator Water Clean Up systs to the Standby Information Panel by the text but its inclusion in the Principal Plant Console on diagram 7.5-3.

Information available frcm IP's Instrumentation and Control Meeting Sumary room (1/7-8/81) provides only a " typical arrangement of operations control console"; Nuclenent Control Pocm at CPS is prototypical. The I5CU is not included on PPC in this diagram; instead a site for plant calculations is included without definition.

Prestmably this being placed close to recirculation control may have to do with load following manipulation; this active use of operator attention for calculations (which instead sinuld probably be automated with oversight by supervisor) is unacceptable.

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

^

l The namenclature for instruments in the sumary does not correspond to NBC acronyms. This is another point of uncertainity that needs to be cleared up.

bbre information about design criteria on the human engineering problems associated with a control rom of these extraordinary emplexities has been requested through the discovery process. S e e considerations we have at this time are:

1. The lack of diversity of annunciators
2. Thesize of control rocm
3. CRT fatigue on main operator
4. Radiation frm the battery of ten color CRrs
5. Iack of softwareassistance in DCS (display console systen) in

.: choosing displays for operator. (This should be routed by devices that

, are monitoring SP, in conjunction with the audio cueing systen to prevent reactor frm approaching dangerous states)

Is so much of the workability of the CPS control rocm depends on the DCS, intervenors need to see the software studies concering sytes downtime and turnover intervals between downtime and repair.

Further information concerning this contention is forthemung via the discovery process, at which time this interrogatory will be answered more fully.

30. The requirenent for the inclusion in the FSAR of documentation of design modifications due to the various new criteria formulated by NRR following the accident at Three Mile Island is contained in 10 CFR 550.34(b) (1) & (2).

Specifically, as the design of the control rocm has been finalized and installation due 7/81 (this according to January 7&8 Meeting Surtmary) documentaion of criteria used in design choices is pertinent and timely.

FSAR at this time does not include full details of the design itself.

(See answer to No. 29, above, for FSAR discrepancies) .

NBC criteria for evaluation of control recans vis a vis human engineering were not to be released until 7/81. Nuclenet designers would hence not have had those available to aid in their work.

The FSAR is a fundamental d m e nt in ensuring that the C?S is and can be maintained as a safe, reliable source of electric power for the people in its service.

A concern we have beyond the lack of documentation of post 'IMI Action Plan requirenents is the erosion of the FSAR per se. A case in point is the deletion of Figure's 3.6-14,15, Postulated Break Iocations and Restraint Iccaticns in Piping of Recirculation and Residual Heat Raroval

. Systens, respectively.

l These Diagrams were to have been supplied "the sunmer of 1980" but

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they have been deleted without ever having been produced.

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Contention No. 7

1. Terri. J. Lang Law Clerk Law Offices of Yoho, Gerstein & Prillaman 311 West University Avenue Ch @ gn, IL 61820 T21ephone: (217) 359-0067 2 .- William Snow 506 E. White, #11 Chanpaign, IL 61820 Telephone: (217) 351-7383
3. The Intervenor objects to this Interrogatory on the ground that it is overly broad. However, to the extent that Intervenor is able to answer this Interrogatory, it states that as for Contention 7(a), the Intervenor will not oppose a motion to sumarily dispose of Contention 7(a), due to information recently discovered. As for Contention 7(b), the factual bases for the allegations that IP has not hardened the CPS containrnent to account for the impact of existing and possibly increased civilian aircraft traffic in the site vicinity are as follows:
a. IP has not taken into account federal vector pathways V233, V173, and V434, all of which are in the site vicinity;
b. IP has not taken into account the projected increase in air traffic in the site vicinity.
4. As for Contention 7(a), see answer to Interrogatory 3 above. As for Contention 7(b); 10 CFR 550. Appendix A, Criterion 4: Environnental arel Missile Design Bases.
5. As for Contention 7(a), see answer to Interrogatory 3 above. As for Contention 7(b); FSAR 3.1.2.1.4; FAA Aviation Forecasts, F. 780-81.
6. At this time Intervenor does not knca,. to the extent that this Interrogatory calls for an answer concerning e.w testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning nonW testinony.
7. See answer to Interrogatory #6, above.
8. See answer to Interrogatory 46, above.
9. Intermnar does not know at this time.
10. FSAR 3.1.2.1.4
11. Intervenor does not know at this time.
31. See answer to Interrogatory #3 above.
32. See answer to Interrogatory #3 above.
33. See answer to Interrogatory #3 above.

2 34. h three federal vector pathways that should have been taken in'to account are V233, V173, and V434. These should be taken into account because of their close proximity to the CPS site. This interrogatory will be answered more fully once documents arrive.via the discovery process.

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. n Contention No. 8

1. Terri J. Lang Iaw Clerk Law Offices of Yoho, Gerstein & Prillaman 311 W. University Avenue Champaign, IL 61820 (217) 359-0067
2. Wil1iam M. Snow 506 E. White, #11 Cb=naign, IL 61820 (217) 351-7383 Gregory C. Minor MHB Technical Association 1723 Hamilton Avenue Suita K San Jose, CA 95125 (408) 266-2716 Philip L. Willman Assistant Attorney General Environmental Control Division 188 W. Randolph Street, Suite 2315 Chicago, IL 60601 (312) 793-2491
3. Intervenor objects to this Interrogatory on the ground that it is overly broad. However, to the extent that Intervenor is able to answer thi-7.nterrogatory, it states that the factual bases are founds in the FSAR, pages 1.8-52, 5.2-47 and 5.2-48.
4. (a) 10 C.F.R. Part 50, Appendix A, Criteria 13 and 30; and Regulatory Guide 1.45.

(b) 10 ^..F.R. Part 50, Appendix A, Criterion 14; and Regulatory Guide 1.45.

5. The FSAR and Regulatory Guide 1.45, with further d<v,wntation anticipated as a result of the discovery process.
6. At this time Intervenor does not know, to the extent that this Interrogatory calls for an answer concerning expert testimony, what individuals it intends to calls as witnesses. Interver.or objects to this Interrogatory to the extent that it calls for an answer concerning non-expert testirony.
7. See Answer to Interrogatory #6, above.
8. See Answer to Interrogatory #6, above.

.1

9. Intervenor does not know at this time. 9
10. The FSAR, Sections 5.2.5, 7.6.1.4, 7.6.2.4.,~and page 1.8-52.
11. Intervenor does not know at this time.

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Contention No. 9

1. Terri J. Lang law Clerk Law Offices of Yoho, Gerstein & Prillaman 311 West Urtiversity Avenue Chanpaign, IL 61820 Telephone: (217) 359-0067
2. Oscar F. Hernandez 702 S. McCullough Urbana, IL 61801 Telephone: (217) 344-2361 Terri J. Lang Law Clerk Law Offices of Yoho, Gerstein & Prillaman 311 West University Avenue Chanpaign, IL 61820 Telephone: (217) 359-0067
3. Intervenor objects to this Interrogatory on the ground that it is overly broad. However, to the extent that intervenor is able to answer this interrogatory it subnits in general, FSAR ch. 12; specifically, sections:

12.2.2; 12.2.2.1; 12.2.2.2; 12.2.2.3; 12.2.2.4; 12.3.4; 12.3.4.1; 12.3.4.2; 12.3.4.2.1; 12.3.4.2.3.2; 12.3.4.2.4; 12.4.1.3; 12.4.3.7. Further inforniation is ccming via discovery process.

4. 10 CFR S20 in general; specifically, sections: 20.1; 20.4; 20.5; 20.101; 20.102; 20.103; 20.105; 20.203, 20.401; Appendix B. Further infonnation is caning via discovery process. NUREG-0713 Vol 1; NUREG-0602/ EPA-600/8-79-019;

. NUREi/CR-1498; NURB3/CR-1497; NUREG/CR-0010; NUREG-0475.

6. At this time Intervenor does not know, to the extent that this Interrogatory calls for an answer concerning expert testimony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non-expert testimony.
7. See Answer to No. 6, above.
8. See Answer to Ib. 6, above.
9. Intervenor does not know at this tune.
10. See Answer to No. 3
35. Intervenor needs inforniation forthccming via the discovery process to fully answer this Interrogatory; however, Intervenor subnits that recent studies have shown that the effects of low-level radiation are much nore significant than had previously been thought. See No Nukes-everyone's guide

to nuclear power, (South End Press,1979) by Anna Gyorgy arxi friends, pp 78-98; and Honicker v. Hendrie, A lawsuit to end atnnic power (1978 '1he Book Publishing Ca@any) pp 7-9; 36.

36. See answer to No. 35.
37. See answer to No. 35.

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Contention No. 10 1

l

1. Terri J. lang Law Clerk Law Offices of Yoho, Gerstein & Prillaman 311 W. University Avenue Champaign, IL 61820 (217) 359-0067
2. Bradley T. Turner 1007 S. Oak, #4 Champaign, IL 61820 Gregory C. Minor MHB Technical Association 1723 Hamilton Avenue Suite K San Jose, CA 95125 (408) 266-2716 Philip L. Willman Assistant Attorney General Environ:nental Control Division 188 W. Randolph Street, Suite 2315 Chicago, IL 60601
3. The FSAR contains no assurance that the ECCS has been verified in a full scale reactor test.
4. 10 C.F.R. 550.46; 10 C.F.R. Part 50, Appendix A; 10 C.F.R. Part 50, Appendix A, Criteria 37; and NUREG 0630
5. The FSAR, with further du' = ntation anticipated as a result of the discovery process.
6. Intervenor does not know at this time, to the extent that this Interrogatory calls for an answer concerning expert tesdmony, what individuals it intends to call ac witnesses. Intervenor objects to this Interrogatory to the extent it calls for an answer concerning non-expert testinony.
7. See answer to Interrogatory #6, above.
8. See answer to Interrogatory 16, above.
9. Intervenor does not know at this time.
10. FSAR, Section 613. Intervenor is unable to give a core specific answer at this time, but will furnish it when available.

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

11. See answer to Interrogatory #6, above.
38. The ECCS nust be verified in a full scale reactor test, at full pressure i

and tarperature and/or under worst-case accident conditions.

39. 10 C.F.R. Part #0, Appendix A,Section II, paragraph 5. Ebr an explanation, 4

Intervenor refers to NUREG 0630.

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, 3 Contention No. 11

1. Terri J. Lang Iaw Clerk Iaw Offices of Yoho, Gerstein & Prillaman 311 W. University Avenue Champaign, IL 61820 (217) 359-0067
2. Oscar F. Hernandez 702 S. McCullough Urbana, IL 61801 (217) 344-2361 Joanne J. Schwart Library Clerk II University of Illinois Main Library 1408 West Gregory, Rocm 12 Urbana, IL 61801

{217) 333-1997

3. Intervanor objects to this Interrogatory on the ground that it is overly broad. However, to the extent that intervenor is able to answer this interrogatory it submits FSAR 12.4.2.3, and Tables 11.3-8; 12.4-7; 1.2.2.1.3; 2.3.4.2; 2.3.2.1.5; 2.3.2.2; Tables 11.5-2;'11.3-8; and 12.4-7.
4. l') CFR S20 generally, and specifically parts .105 & .106, and Appendix B.

Also 45 FR 40.101-40.104 (6/13/80); Also NUREG-0602; NUREG/CR-0010; hTREG-0016; NUREG/0133.

5. See answer to Nos. 3 & 4; also ER 55.2.4.4.
6. At this time Intervenor does not know, to the extent that this Interrogatory calls for an answer concerning expert testinony, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatory to the extent that it calls for an answer concerning non-expert tectinony.
7. See Answer to No. 6, above.
8. See Answer to m. 6, abo <e.
9. Intervenor does not know at this time.
10. See answer to No. 3, above.
11. Intervenor does not know at this t.une.
40. Further information is forthccming via discovery process; however intervenor submits at this time 45 FR-40.101-40.104 (6/13/80) .

i -

Contention No. 12

1. Terri J. Lang Law Clerk Law Offices of Yoho, Gerstein & Prillaman 311 W. University Avenue Champaign, IL 61820 (217) 359-0067
2. Gregory C. Minor MHB Technical Association 1723 Hamiltcm Avenue Suite K

! San Jose, CA 95125 (408) 266-2716 Philip L. Willman Assista:'t Attorney General Enviromental Control Division 188 W. Randolph Street, Suite 2315 t

Chicago, IL 60601

3. Intervenor objects to this Interrogatory on the ground that it is overly bread. However, to the extent Intervenor is able to answer this Interrogatory,

, it states as follows:

(a) The FSAR contains no provision for praoperational testing of the functional capability of the spent fuel transfer systen.

(b) The design of the spent fuel transfer systen is the first of its k2nd and is improven.

(c) The FSAR contains no assurance that occupational exposure frcIn the spent fuel transfer systen will be maintained at the ALAPA level.

4. 10 C.F.R. S20. 1 et seq.;

10 C.F.R. Part 50, Appendix A, Criteria 61, 63 and 64; cnd Regulatory Guide 8.8. *

5. The FSAR, with further documentation anticipated as a result of the discovery process.
6. Intervenor does not know at this time, to the extent that this Interrogatory calls for an answer concerning e.W testimorrf, what individuals it intends to call as witnesses. Intervenor objects to this Interrogatorf to the extent thr.t it calls for an answer concerning non-expert testimony.

1

7. See answer to Interrogatory #6, above.

I

8. See answer to Interrogatory #6, above.
9. Intervenor does not know at this time.
10. FSAR, Section 12.3.1.9.1, page 12.3-7; Sections 3.1.2.6.2, 3.1.2.6.4, and 3.1.2.6.5.
11. See answer to Interrogatory #6, above.

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. m I, TERRI JOAN LANG, hereby swear that the answers to Applicant's Interrogatories enclosed herein are true and correct to my knowledge and belief.

1 tb y . $p / (

Terri Joan Lang - j e

Representative of Prairie Alliance, INC.

Subscribed and sworn to on the '$h day of hdB u>E , 19 .

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No m q 7ublic g' h J

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9 LunuICATIm OF SERVICE I certify that I caused an original and two copies of the foreg' ag dmwnt to be served on the following:

Secretary of the Cm miasion United States Nuclear Regulatory Cmmiasion Washington, D.C. 20555 Attn: Docketing and Servicing Brsrd.

and that I caused one copy of the foregoing document to be served upon each of the following:

Hugh K. Clark, Esq. Chairman Dr. George A. Ferguson P.O. Box 127A School of Engirmering Kennedyville, Maryland 21645 Howard University 2300 Sixth Street, N.W.

Washington, D.C. 20059 Dr. Oscar H. Paris Atadc Safety & Licensing Board Richard J. Goodard, Esq.

U.S. Nuclear Pegulatory Cmmission Office of the Executive Iegal Washington, D.C. 20555 Director U. S. Nuclear Regulatory Camission Washington, D.C. 20555 Atmic S.tfety & Licensing Appeal Board Panel Peter V. Fazio, Jr., Esq.

U.S. Nuclear Pegulatory rmmiasicn Schiff, Hardin & Waite Washington, D. C. 20555 7200 Sears Tower 233 South Wacker Drive Chicago, IL 60606 in each case by deposit in the United States Mail, postage prepaid on the

/* day of 8vc, :/_ ,1981.

1 ,

if f Terri Iang, Pepresentative for Prairie' Alliance, Inc.

- ,

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