ML20033B969
| ML20033B969 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/16/1981 |
| From: | Willman P ILLINOIS, STATE OF |
| To: | ILLINOIS POWER CO. |
| Shared Package | |
| ML20033B965 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112020526 | |
| Download: ML20033B969 (8) | |
Text
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
. ILLINOIS POWER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC.-)
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
Docket Nos. 50-461 OL
).
50-462 OL (Operating Licenses for'Clinton )
Power Station, Units 1 and 2)
)
THE STATE OF ILLINOIS' SECOND REQUEST.FOR PRODUCTION OF. DOCUMENTS BY APPLICANTS The State of Illinois (Illinois) hereby requests that applicants, Illinois Power Company, Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. (collectively, IP) produce the documents listed below, pursuant to Section 2.741 of the Nuclear Regulatory Commission (NRC) Rules of Practice. -
Illinois requests that IP produce said documents, for inspection and copying, at the Office of the Attorney General for the State o
of Illinois, 500 South Second Street, Springfield, Illinois, by December 15, 1981, or at such time and place as Illinois and a.
IP may agree.
I.
Definitions 1.
" CPS-1" refers to the Clinton Pcwer Station, Unit 1.
2.
" Document" means the original and non-conforming copies of written, printed, typed or graphic material of any i
kind or character, including, but not limited to, correspondence, letters, telegrams, memoranda, notes,
)
8112O20526 811116 PDR ADOCK 05000461
}
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records, minutes, contracts, agreements, records, studies, pamphlets, books,_ articles, treatises, records or notations of personal conversations or conferences, inter-office communications, micro-film, bulletins, circulars, blue prints, plans, drawings, photograpns, teletype messages, invoices, tape recordings, and work-sheets, together with all copies of said documents by whatever means made, in the custody, care, possession or control of any officer, director, employee, agent, consultant, attorney or representative of IP.
Identification of copies of the original is necessary if there is material in the original or any copy that is not in other copies of the original.
3.
" Person" means an individual, agent, partnership, firm, company, consultant, corporation, association, political sub-division, governmental agency, or any other legal entity, or its legal representative, agent or assign.
II.
Documents Requested 1.
Nll documents IP has itemized in each answer to Illinois' second set of interrogatories.
2.
NEDO 20566 and any supplements thereto.
3.
A letter to NRC from General Electric Company (GE),
entitled "GE Fuel Clad Swelling and Rupture Model,"
dated May 15, 1981.
l 4.
All Baldwin Associates' (BA) Quality Control (QC) or l
Quality Assurance (QA) audit reports, including, but -
not limited to:
a)
I-134, dated January 10-16, 1980; b)
I-137,' dated February 16 and,17, 1980; c)
I-150, dated-June 17-23, 1980; and d) report dated August 7, 1980.
5.
A Corrective Action Request, No. 049, dated February 29, 1980.
6.
A report of-QA review of documentation system, dated September 1980.
7.
A letter from IP Supervisor, Construction QA, to BA Manager, Quality and Technical Services, on the documentation system,
~
dated October 23, 1980.
8.
A letter to IP management from the IP Director of QA, transmitting a special QA report, and the QA report.
i 9.
All documents related to N.3C's Systematic Assessment of License Performance Review of IP and CPS-1, particularly
(
a report dated November 12, 1980.
10.
A memorandum from BA Resident Engineer to BA Senior Piping Engineer on employment policy, dated February 17, 1981.
11.
A report by Theodore Ba_ry and Associates, comparing CPS-1 construction cost overruns and delays to the nuclear industry..
12.
All documents related to meetings held between IP and NRC.
13.
All documents related to meetings held between IP and GE.
14.
All documents related to meetings held between IP and BA.
15.
All documents related to meetings held between IP and Sargent and Lundy.
16.
All documents related to IP's Commitment Control Program.
17.
All documents related to IP's NRC Regulatory Guide Compliance Program.
Respectfully submitted, TYRONE C. FAHNER Attorney General State of Illinois BY:
M PHILIP L.' WILLMAN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 l
DATED:
November 16, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS PONER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC.)
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
)
Docket Nos. 50-461 OL (Operating Licenses for Clinton) 50-462 OL Power Station, Units 1 and 2)
)
MOTICE TO:
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 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Richard J. Goddard Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C.
20555 Pet 6r V.
Fazio, Jr.
Schiff, Hardin, & Waite 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 Prairie Alliance P.O.
Box 2424 Station A Champaign, Illinois 61820 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555
PLEASE TAKE NOTICE that today I have caused to be filed with the Secretary, United States Nuclear Regulatory Commission, Wash-
- ington, D.C. 20555,' Attention:
Chief, pocketing and Service Sec-tion, one original and two conformed copies of the State of Illinois' Second Set of Interrogatories and Request for Production of Documents to Applicants.
Copies of these documents are attached and served upon you.
Respectfully submitted, TYRONE C.
FAHNER Attorney General State of Illinois BY:
PifILIP Ll WILL!iAN Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED:
November 16, 1981 1
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS POWER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC. )
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
)
Docket Nos. 50-461 OL
)
50-462 OL (Operating Licenses for Clinton )
Power Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that I served c6 pies of the State of Illinois' Second 5:t of Interrogatories and Request for Production of Documents to Applicants on the persons on the attached Notice by causing them to be deposited in the United States mail, first class, postage prepaid, on this 16th day of November, 1981.
b.
/
hHILIP L.
WILLMAN s