ML20033A983
| ML20033A983 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/18/1981 |
| From: | William P ILLINOIS, STATE OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8111300248 | |
| Download: ML20033A983 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00tKETED U%RC IN THE MATTER OF
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81 NOV 23 Ali 50 ILLINOIS POWER COMPANY,
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SOYLAND POWER COOPERATIVE, INC.
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and WESTERN ILLINOIS POWER
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Z OF MCRETARY COOPERATIVE, INC.
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Docket Nos. 50-461 OL
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50-462 OL (Operatirg Licenses for Clinton
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D Power Station, Units 1 and 2)
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9 MOTION TO REQUIRE NRC
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THE STATE OF ILLINOIS'
-4 STAFF TO ANSWER INTERROGATOKIES Ej
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m The State of Illinois (Illinois), by its attor Tyrone C. Fahner, Attorney General of the State of Illinois,.hereby moves the presiding officer in the above captioned proceeding to requir.e the Nuclear Regulatory Commission (NRC) Staff to answer interrogatories, pursuant to Section 2.720 (h) (2) (ii) of the NRC Rules of Practice.
In support of this motion Illinois states as follows:
1.
On November 16, 1981, pursuant to a discovery schedule agreed to by the parties, Illinois filed and served interrogatories to be answered by the NRC Staff.
2.
Illinois believes that answers to these interrogatories are necessary to a proper decision in the proceeding.
Each inter-rogatory propounded to the NRC Staff is related to a contention that is before the Atomic Safety and Licensing Board in this proceeding.
Illinois has asked a series of interrogatories requesting NRC to state its position on various aspects of the Quality Assurance and Quality Control construction program of the Clinton Power Station, Unit 1 (CPS-1), which is at issue in NEE $A I
Contention 2.
Illinois has also asked a series of interrogatories requesting NRC to state its position on the operating capability and predicted performance of the CPS-1 Emergency Core Cooling System, which are issues found in Contention 10.
Finally, there are a series of interrogatories on the NRC Staff's position with respect to the operating capability and radiation protection measures of the spent fuel transfer tube, the subject of Contention 12.
Without answers to these interrogatories Illinois does not know what the NRC Staff's position is on each of these contentions.
3.
Illinois believes that the answers to these inter-rogatories are not reasonably obtainable from any other source.
The NRC ' staff has not yet issued its Safety Evaluation Report (SER) 'for CPS-1.
Moreover, the SER is not expected to be issued until after the close of discovery on the presently admitted contentions, January 15, 1982.
The answers are also not available from any other source of information available to Illinois, such as the Public Document Room.
WHEREFORE, Illinois moves the presiding officer of the Board to require the NRC Staff to answer interrogatories, filed by Illinois on November 16, 1981, upon a finding that answers to 4
the interrogatories are necessary to a proper decision in the proceeding and that answers to the interrogatories are not reasonably obtainable from any other source, pursuant to Section 2.720 (h) (2) (ii) of the NRC Rules of Practice.
Respectfully submitted,
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TYRONE C. FAHNER Attorney General State of Illinois O'-
BY:
PHILIP L( WILLMAN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315
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Chicago, Illinois 60601 (312) 793-2491 DATED:
November 18, 1981 i
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-f UNITED STATES OF AMEDICA NUCIEAR REGI'LATORY COM'ilSSION IN THE I1ATTER OF
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ILLINOIS POWER COMPANY,
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(l SOYLAND POWER COOPERATIVE,'INC.)
and NESTERN ILLINOIS POWER
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COOPERATIVE, INC.
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Docket Nos. 50-461 OL (Operating Licenses-for Clinton) 50-462 OL Power Station, ' Units 1 and 2)
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NOTICE
'O:
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 Dr. Oscar H.
Paris Automic Safety and Licensing Board
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U.S.
Nuclear Regulatorf Commission Washington, D.C.
20555 i
' Richard J. Goddard Office of the Executive Legal Director United. States Nuclear Regulatory Ccmmission I.'a s hington,
D.C.
20555 e
Peter V.
Fazio, Jr.
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Schiff, Hardin, & Waite 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 l
Prairie Alliance P.O. Box 2424 Station A l
Champaign, Illinois 61820 i
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Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 e
Atomic Safety and Licensing Appeal Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 I
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PLEASE TAKE NOTICE that today I have caused to be filed with the Secretary, United States Nuclear Regulatory Commission, Washington, D.C.
20555, Attentien:
Chief, Docketing and Service Section, one original and two conformed copies of the State of Illinois' Motion to Require NRC Staff to Answer Interrogator' es.
Copies of these documents are attached and served upon you.
Respectfully submitted, TYRONE C. FAHNER Attorney General State of Illinois i
BY:
PHILIP L.fWILLMAN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED:
November 18, 1981 r
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS POWER COMPANY,
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SOYLAND POWER COOPERATIVE, INC.
)
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
)
Docket Nos. 50-461 OL
)
50-461 OL (Operating Licenses for Clinton
)
Power Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that I served copies of the State of Illinois' Motion to Require NRC Staff to Answer Interrogatories on the persons on the attached Notice by causing them to be deposited in the United States mail, first class, postage prepaid, on this 18th day of November, 1981.
PHILIP L.
WILLMAN c
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