ML20032E421
| ML20032E421 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/13/1981 |
| From: | Bacon C PRAIRIE ALLIANCE |
| To: | ILLINOIS POWER CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8111200541 | |
| Download: ML20032E421 (13) | |
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.. ; 2. SERV!CE ILLINOIS POWER COMPANY et al.
DocketANold 50-461 OL (Clinton Power Station Unit 1)
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PRAIRIE ALLIANCE'S PARTIAL SECOND ROUND 0? DISCOVERY TO ILLINOIS POWER COMPANY, et al.
Pursuant to 10 CFR 2.740(b) of the Nuclear Regulatory Commissior's regulatilans, Prairie Alliance requests that Illinois Power Company (IP) answer the attached interrogatories fully, to the best of their knowledge, in writing, and under oath, and that the answers be signed by the person (s),
j naking them.
In addition, pursuant to 10 CFR 2.741, Prairie Alliance requests that IP produce and permit Prairie Alliance to inspect and copy de signated docu=ents in possession, custody or control of IP.
I Each quest'on shall be answered as follows :
1.
Provide the direct answer to the question.
2.
Provide documents, including research, studies, calculations, memoranda, correspondence, reports, diagrams, computer codes, and all other r-cords, that were relied upon by IP in answering the question, and also those which served as the basis for the answer.
3 Identify by name, title, and qualifications the IP employee that has the expert knowldege required to support the answer to the question.
I 4.
Explain whether IP is presently engaged in or intends to engage in any further research cr work which may affect the answer. Idahify j
i such research or work. b SO Ps,o s 8111200541 811113 PDR ADOCK 05000461 G
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State the names, addresses, titles, and qualifications.of the persons IP intends to call as witnesses or experte for the answer and the subject matter which they intend 'to testify about.
6.
Provide the computer codes, in machine readable source code, of any computer models or simulations vant to the question asked.
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e INTERROCATORIES 1.
(Regarding contention 1(a M1)): With respect to the actions proposed by local and state agencies to effect termination of activities at outdoor recreational facilities other than at Clinton Lake s a) Identify each facility for which actions are proposed.
b) Identify all egencies responsible for termination of activities at such facilities.
c) Describe the methods by which IP has ascertained that such local and state agencies have the capacity to take appropriate action in the event of a radiological emergency.
d) Specify the nunbers and qualifications of local and state personnel expected to be involved in the termination of activities, e) Lescribe the types of equipment which local and state agencies will have at their disposal for use in the termination of activities.
2.
(Regarding contention 1(a)(3)): With respect to the severeweather conditions which may be expected in the site vicinity and plune and ingestion EPZ's throughout the year, a) Describe what provisinna if any, nave been made to notify the general public in the plume and ingestion EPZ's of an emergency during severe weather conditions wh$ ch interfere with or cause a breakdewn in television and radio broadcasting.
b) Deccrite what provisions, if any, have been made to insure that offsite personnel needed to augment the onsite staff in the event of an energency will arrive onsite promptly during severe weather conditions such as ice storns or blizzards.
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s c) Describe wnat provisions, if any, have been made to insure prorrpt evacuation of the general public within the plume exposure EPZ in the event of a severe weather condition, such as an ice storn er a bliznard.
d) If local and state agencies are responsible for any actions or r
provisions mentioned in parts a-c of this interrogatory, describe the methodology used by IP to determine that such agencies are capable of making timely, appropriate responses to energency situatiers in the event of a severe weather condition such as an ice storm or blizzard.
e) Describe the types of equipment which local and state agencies will have at their disposal for use for evacuation in the e>cnt of an energency during an ice storn or blizzard or other severe weather co ndition.
3 (Regardin6 contentions 1(d)(2) and 1(d)(3)): With respect to the role of the Illinois Department of Nuclear Safety in the CPS Energency Plan:
a) Describe the criteria for determining the need for notification and participation of the Department in the event of an energency, b) Identify the person (s) who developm' the criteria, and his/her/their title (s ) and qualifications.
c) Identify the titles and qualifications of the person (s) responsible for evaluating the criteria and deternining the need for notification j
and participation of the Department.
d) For each level of energency, state the anticipated time lapse l
between the occurrence of an energency rd notification of the Department.
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e) For each lesel of energency, state the anticipated time lapse between no+1fication of the Department and an appropriate onsite f
response by the Radiological Assessnont Tean.
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4.
(Regarding contentions 1(d)(2) and 1(d)(3)): With respect to the roles of the Illinois and DeWitt Cot..Ly ">tergency Services and Disaster Agencies in the CPS Energency Plant a) State for each agency the criteria for determining the need for notification and participation of the agencies in the event of an energency.
b) Identify the person (s) who developed the criteria, and state his/her/their title (s) and qualifications.
c) State the title (s) and qualifications of the person (s) responsible for evaluating the criteria and determining the need for notification of each agency in the event of an energency.
d) For each level of energency, state the anticipated time lapse between occurrence of the energency and notification of each agency.
e) For each level of energency, state the anticipated time lapse between notification of each agency and an appropriate response by each agency.
5 (Regarding contentions 1(d)(2) and 1(d)(3)): W4.th respect to tPc role of the Chicago Department cf Energy and the Argonne laboratory in tra CPS Energency Plan, a) State the criteria for deternining the need for notification and participation of each in the event of an energency.
b) Identify the person (s) who developed the criteria, and state her/his/their title (s) and qualifications.
c) Identify the person (s) responsible for evaluating the criteria and deternining the need for notification of the Departnent and the Argonne lab in the event of an energe rey. !
5 d) Describe the circumstances in which IP will request a team of radiation specialists pursuant to the Interagency Radiological Assistance Plan.
e) State whether services provided by the Chicago Department and the Argonne laborttory are available on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis.
f) State the anticipated time lapse between the occurrence of an emergency and notification of the Chicago Department of Energy and the Argonne laboratory.
g) State the anticipated time lapse between notification and an apprcpriate onsite or offsite response by radiation specialists pursuant to the Interagency Radiological Assistance Plan, d
(Fegarding contentions 1(d)(2) and 1(d)(3)): Describe all inforn' tion, calculations, and nethods wb ch IP used in its determination that state and local agencies responsible for any aspect of the Emergency Plan are capable of making time'_y and appropriate responses in the event of a radiological emergency. Include, but do not limit your answer to, a detailed description of each q eh agency's emergency response plans. Provide copies of all docu.nents, memorands, communi-cations, letters of agreement, and other papers describing the actions each such agency will take in the eve rt of a radiological emergency.
7 (Fegariing contention 1(d)(2))': With respect to CPS No. 0AP1890.02N 3 2 concerning followup messages after initial notification of offsite agsreies; a) State what ne'. hods of disseminating followup messages exist, listing-such methods in their perceived order of effectiveness. /
7 b) State the criteria '
determining which method is the "best available," and state tne title (s) and qualifications of the person (s) reqponsible for det-mining which method will be utilized.
c) State why racio transmission is to be arvoided in followup messages.
8.
(Regarding contention 1(d)(5)): Describe the methods, if any, by which offsite done projections will be made in the 30-60 minut(s following an emergency but prior to the arrival onsite of the Supervisor -
Rad Chem or Supervisor - Radia tion Protection. If such methods exist, state the title (s) and qualifica' ion ~" the person (s) responsible for taking such projectiors.
9 (Regarding contention 1(e)): '41th respect to CPS Emergency Plan 9 3:
a) State whether or not IP has made any plans or agreements to date with any news media concerning:
- 1) Provision of complete emergency plans to such media,
- 2) Provision of detailed emergency training for such media,
- 3) Establishment of points of contact for the release of information during an emergency for such media,
- 4) Arrangements for the timely exchange of information between IP and the media,
b) For each classification of emergency, state the anticipated frequency of the exchange of infornation between IP and the media.
c) If any plans or agreements have been made, state (by name and type )
with which media such plans or agreenents have been made, Also, state (by name and type) with which media such plans or agreements will te made in the future. t -
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9 d) Briefly describe and attach copies of each plan or agreement reached with each media source to date.
e) If no such plans have been made, state when, if ever, IP plans to make such plans or agreements. If none will ever be made, state why not.
10.
(R=garding contention 9): With respect to CPS 0AP1890.04N 2.1.2 concerning immediate actions to be taken in the event of an Unusual Events a) State under wbst circumstances it will be inappropriate to make a statenent to plant personnel describing the event.
b) State the crit ria used to make this determination, and the name(s), title (s) and qualifications of the person (s) making the detarmination.
c) Identify the person who developed the criteria by name, title, and qualifications.
11.
(Regarding contention 9): With respect to CPS OAP1890.0/4N 3 2.h concerning restoration activities :
a) State how the frequency of monitoring and decontamination is to be determined.
b) Identify by name(s), title (s), and qualifications the person (s) responsible for such determinations.
12.
(Regarding contention I-With respect to CPS Emergency Plan 12.1.1:
a) Identify by name, title, and qualifications each person who will be responsible for weighing the projected dose against the benefits to be gainec.
12.
b) State the criteria for determining when the benefits to be gained will exceed the dangers of high dosage.
c) Describe the circumstances in which volunteers will be utilized, and and the circumstances in which volunteers will not be used. For situations in which volunteers will not be used, describe the personnel who will be required to accept greater than normal dose limits.
13 (Regarding contention 11): With respect to CPS Emergency Plan 12.1.2.,
state why responsibic officials are not required to initiate protective actions when the projected exposure to the general public equals or exceeds 1 rem whole body or 5 ren thyroid.
14.
(Regarding contention 1(d)): With respect tc CPS E.nergency Plan 12.2 3, describe all administrative and physical means which are available to promptly notify the public within the plume exposure EPZ of an abnormal or emergency condition.
a) Describe the types of equipment and identify the personnel which will be utilized in any notification of the public.
b) Eescribe the methods by which state and local governments will activate the system.
c) Eescribe all information, calculations, methcds, etc., which were i
utilzed by IP in determining that state and local government agencies are capable of activating the system.
15 (Regarding contention 1d3,le)With respect to CPS Emergency Plan 12 3 concerning evacuation:
_a_
15 a) State the criteria utilized by state and local government officials in determining when to evacuate the general public.
b) Describe the public evacuation procedures and list locations for relocation centers contair.ed in the state and local government emergency plans listed at CPS FSAR Dnergency Plan 12 3 2, c) Provide copies of all state and local government energency plans described in 12 3 2.
d) Describe all infornation of any kind, including calculations, nethods of determination, etc., which were utilized by IP in confirning local and state governmental capability to carry out an effective and timely evacuation of the general public.
c) Descri'ce all equipment which local and state governmental agencies have at their disposal to effect an evacuation of persons who own no private means of trany Mation.
- 16. (Regardin6 contention Ib ): With respect to CPS Emergency Plan 14 31 ccncerning IP's agreement with John Warner Hospital, describe in detail the equipment and staff available for dealing with radiation injuries.
17 (Regarding contentio n Ic ): With respect to CPS Energency Plan 17.2, describe in detail the site specific ener ;ency response training for all offsite emergency response organizations. Provide copies of such training plsns.
18.
(Regarding contention Ic ): With respect to CPS Emergency Plan 17 3, describe in detail the sp ^1alized training which shall be provided in the following areas :
- 18. a) Directors and coordinators of response organizations.
b) Personnel responsible for accident assessment.
c) Radiological monitoring teams.
d) Police, security, and fire fighting personnel, e) Repair and damage control teams.
f) First Aid and rescue personnel.
g) Local support ESDA personnel.
h) Medical support personnel.
- 1) IPC headquarters support personnel.
19 Provide copies of the following supporting plans :
a) Illinois Plan for Radiological Assistance.
b) DeWitt County Emergency Response Plan.
c) Illinois Comprehensive Disaster Response Plan.
Second Round Interrogatories Pertaining to Contention #6 a) Provide documents related to accuracy of indication of uater level using reference leg differential pressure monitor, particularly those studies concerning calibration and possible instrument failure sce-narios, boilout, etc..
b) Produce documents which show how shutdown water level indication information wouldlbe interpreted at other than design conditions.
c) Provide documents relating to application of losse parts monitoring LPM to reactor pressure vessel integrity.
d) Provide information on the extent of IP's involvement in the various BWR group and subcommittee meetings. Include lists of personnel attending, monies pledged and other pertinent details, e) Produce documents and studies used in justifying non-safety grade equip-ment in additional accident and post-accident monitoring devices.
f) Provide documents produced by IP as input for formulation of NRC docu-ment CR/1580.
g) Provide documents produced for NRC control room minireview.
h) Provide documents pertaining to display console system and its reli-ability, and software controlling automated program selection and its reliability.
- 1) Provide reliability studies for computer and microprocessors used in CR, including expected downtime and time between specific dysfunction and re-pair.
j) Provida documents delineating how NRC commissioned research on distur-bance analysis DAS will be incorporated into CR software.
(12) l
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a-I Qa<nndTICN OF SERVICE I certify that I caused an original and two copies of the foregoing dmwnt to be served on the following:
Secretary of the Cmnission United States Nuclear Pegulatory Ca mission Washington, D.C.
20555 Attn: Docketing and Servicing Branch.
and that I caused one copy of the foregoing docunent to be served upon each of the following:
Hugh K. Clark, Esq. Chairman Dr. George A. Ferguson a
P.O. Box 127A School of Engineering Ke. W ile, Maryland 21645 Howard University 2300 Sixth Street, N.W.
Washington, D.C.
20059 D:. Oscar H. Paris At mic Safety & Licensing Board Richard J. Goodard, Esq.
I U.S. Nuclear Regulatory Camission Office of the Executive Iagal Washington, D.C.
20555 Director U. S. Nuclear Regulatory Cmmission Washington, D.C.
20555
' Atcmic Safety & Licensing Appeal Board Panel Peter V. Fazio, Jr., Esq.
U.S. Nuclear Regulatory Cmmission Schiff, Hardin & Waite Washington, D. C.
20555 7200 Sears Tower 233 South Wacker Drive Q1icago, IL 60606 I
in each case by deposit in the United States Mail, postage prepaid cn the l
/3 dayofdhWde41981.
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%'V Charles Bacon Representative for Prairie Alliance i
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