ML20039B554
| ML20039B554 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/15/1981 |
| From: | Fazio P, Koch L ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE |
| To: | ILLINOIS, STATE OF |
| Shared Package | |
| ML20039B555 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112230230 | |
| Download: ML20039B554 (60) | |
Text
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
IN THE MATTER OF
)
ILLINOIS POWER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC.
)
Docket No. 50-461 OL and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
)
(Operating License for Clinton
)
Power Station, Unit 1)
)
RESPONSE OF ILLINOIS POWER TO THE STATE OF ILLINOIS' SECOND SET OF INTERROGATORIES TO APPLICANTS Illinois Power Company
(" Illinois Power" or "the Company" or "IP"), on behalf of itself, Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. (collectively
" Applicants"), has objected herein to many of the State of Illinois' ("the State") interrogatories on one or both of the following grounds:
1.
The information requested in the interrogatory was provided by Illinois Power in response to the State's First Set of Interrogatories and First Request for Production of Documents.
The State has attempted to circumvent the deadline of November 15, 1981, for the close of first round discovery by formulating specific requests for documents or other information previously made available in response to more general first round requests.
Illinois Power has fully cooperated with the State in scheduling document l
l
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review sessions and in providing access to its files.
The State was given an index to Illinois Power files relating to first round interrogatories and document requests under Contention 2, and attorneys for the State were given unrestricted access to these files.
They spent several days reviewing documents related to Contentions 2, 3 and 5.
Illinois Power also stood ready to produce documents from its files relating to Contentions 10 and 12, but the State never scheduled a session for review of those documents.
Further review of documents contained in files made available in the first round of discovery is now foreclosed by the Board's order of October 29, 1981, approving the parties' Joint Motion for Establishing Discovery Schedule of October 13, 1981.
2.
The information requested in the interrogatory is not necessary for the clarification of any response to first round discovery requests.
The State has attempted in second round discovery to broaden the scope of first round discovery instead of clarifying information it received in the first round.
Under the Joint Motion for Establisning Discovery Schedule, second round discovery was " limited to clarification of matters raised in the first round."
The State's requests for information that could have been made in the first round are therefore beyond the scope of second round discovery.
In many cases, however, Illinois Power has provided all or part of the information requested in the interrogatory subject to the objection.
The information is provided
.i in 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 to any additional discovery requests.
1
[ General Interrogatory No. 1:
Identify all persons who have assisted in any way in the preparation of each answer to each interrogatory below and describe the substance of each person's assist-ance.]
l ANSWER:
This interrogatory is separately answered herein for each contention.
[ General Interrogatory No. 2:
Identify all documents that were relied upon to provide an answer to each interrogatory below, and describe the sub-stance of each document so used.]
ANSWER:
Any documents in Applicants' possession, custody, 1
or control, that were relied on to answer any interrogatory to which no objection is made, will be available for inspec-4 tion at the offices of Illinois Power.
[ General Interrogatory No. 3:
Identify all persons whom IP plans to call to testify as to each conten-tion, and state the qualifications of each person i
so identified.]
ANSWER:
Illinois Power has not yet determined which persons it will call as witnesses should a hearing prove necessary.
l
[ General Interrcgatory No. 4:
Describe for each inter-rogatory any additional research or work, if any, that IP plans to do that will' affect the answer.]
i i
ANSWER:
Illinois Power is continuously engaged in monitor-ing information that may affect the design, construction or operation of CPS.
Unless otherwise noted, or unless new information indicates the need for further investigation, Illinois Power does not plan to conduct further research i
or work which may affect the answers relative to a particular interrogatory.
Contention 2
[ General Interrogatory No. 1:
Identify all persons who have assisted in any way in the preparation of each answer to each interrogatory below and describe the substance of each person's assist-ance.]
ANSWER:
Illinois Power has objected to each of the State's interrogatories under Contention 2.
All information supplied subject to objection was prepared under the supervision and direction of Allen J. Budnick, Director-Quality Assurance.
[5.
Identify the persons who were, but are no longer, employed on the inspection staff of Baldwin Associ-ates' (BA) Department of Quality Control (<QC ),
For each person so identified state:
a) his qualifications for the position; b) his performance in the position; c) the time period of his employment in the position; d) the substance of any complaints made by him to IP, BA, or NRC about QA/QC program; and e) the reason for termination of employment.]
_4_
OBJECTION:
Illinois Power objects to Interrogatory No. 5 4
and each subparagraph thereof on the grounds that the informa-tion requested is not necessary for the clarification of any response to first round discovery requests and is there-fore beyond the scope of second round discovery.
Illinois Power further objects to subparagraph (e) of Interrogatory No. 5 on the grounds set forth in its response to Interrogatory No. 3d of the State's First Set of Interrogatories and in the Answer of Applicants in Opposition to Illinois' Motion to Compel Answers.
ANSWER:
The information furnished by Illinois Power in response to Interrogatory No. 3c of the State's First Set of Interrogatories, relating to Illinois Power's QA and QC employees, is set forth in the attached Exhibit A with respect to Baldwin Associate's QC employees.
[6.
State how many persons are now employed on the QC inspection staff.]
OBJECTION:
Illinois Power objects to Interrogatory No. 6 and each subparagraph thereof on the grounds that the informa-tion requested is not necessary for the clarification of any response to first round discovery requests and is there-fore beyond the scope of second round discovery.
ANSWER:
Eighty-one individuals are presently employed on the Baldwin Associates' QC inspection staff.
l l
(a)
State how many of that number are undergoing training to meet the requirements for the position.
Describe what training they are receiving.]
ANSWER:
Four individuals are undergoing training.
The general training description for QC personnel is as follows:
CLASSROOM TRAINING All Quality Control personnel during training are required to attend specific training sessions as defined by the Training Coordinator and Senior Discipline Engineer.
In-cluded in these training sessions are instructions to refer-ence the latest revisions to all applicable documents.
An outline of each training session is presented to all new employees for guidance during the training period.
Classroom training varies for each individual according to the area the new employee is being trained for.
The training sessions are arranged to supplement on-the-job training the new employee will receive in the field, and with mandatory reading of procedures, codes and standards.
A classroom attendance record is kept on each individual to document total man-hours in training.
A personnel package of records for each individual to be certified, is estab-lished and maintained throughout his or her duration of employment.
ON-THE-JOB TRAINING It is mandatory for each individual during the training period to accumulate a minimum number of hours performing tests, examinations and inspections.
This on-the-job train-ing is documented to provide minimum requirements for each individual on actual firsthand experience performing quality functions.
Training schedules are devised on a week-to-week basis, to judge progress and determine evaluation of performance during the training period.
To coincide with the on-the-job training, there are mandatory reading lists.
Both generic and specific reading lists accompany the field experience to provide guidance, proficiency and evaluate the capabili-ties of the individual during training.
_g.
[7.
State how many persons are now employed in the BA QC Department.]
OBJECTION:
Illinois Power objects to Interrogatory No. 7 and each subparagraph thereof on the grounds that the informa-tion requested is not necessary to the clarification of any response to first round discovery requests and is there-fore beyond the scope of second round discovery.
ANSWER:
Ninety-three individuals are presently employed in Baldwin Associates' QC Department.
[a)
State how many of that number are undergoing training to meet the requirements for the position.
Describe the positions for which they are receiving training and the type of training involved.]
ANSWER:
Four individuals are undergoing training.
See the Answer to Interrogatory No. 6(a) for a general training description for Q.C. personnel.
[8.
Identify those persons who were, but are no longer, employed on the inspection staff of BA's piping department.
For each person so identified state:
a) his qualifications for the position; b) his performance in the position; c) the time period of his employment in the position; d) the substance of any complaints he made to IP, BA, or NRC about the QA/QC program; and e) the reason for termination of employment.]
OBJECTION:
Illinois Power objects to Interrogatory No. 8 and each subparagraph thereof on the grounds that the infor-mation requested is not necessary for the clarification of any response to first round discovery requests and is therefore beyond the scope of second round discovery.
Illinois Power further objects to subparagraph (e) of Inter-rogatory No. 8 on the grounds set forth in its response to Interrogatory No. 3 (d) of the State's First Set of Inter-rogatories and in the Answer of Applicants in Opposition l
l to Illinois' Motion to Compel Answers.
ANSWER:
Inspection activities at CPS are performed by Baldwin Associates Quality Control Department.
Baldwin l
Associates Piping Department does not have an inspection staff.
See the Answer to Interrogatory No. 5.
[9.
Identify those persons who are now employed on the inspection staff of BA's Piping Department.
For each person so identified state:]
a) his duties and responsibilities; b) his qualifications for the position; and c) the substance of any complaints he has made to IP, BA, or NRC about the QA/QC program.]
OBJECTIONS:
Illinois Power objects to Interrogatory No. 9 and each subparagraph thereof on the grounds that the infor-mation requested is not necessary for the clarification of any responle to first round discovery requests and is
,aerefore beyond the scope of second round discovery.
ANSWER:
Inspection activities at CPS are performed by Baldwin Associates Quality Control Department.
Baldwin Associates Piping Department does not have an inspection staff.
The information furnished by Illinois Power in response to Interrogatory No. 3c of the State's First Set of Interrogatories, relating to Illinois Power's QA and QC employees, is set forth in the attached Exhibit B with respect to Baldwin Associates QC employees responsible for mechanical inspections.
[10. Identify each person who is now employed in the BA small bore design group. For each person so identified state:
a) his duties and responsibilities; b) his qualifications for the position; and c) the substance of any complaints he has made to IP, BA or NRC about the QA/QC program.]
OBJECTION:
Illinois Power objects to Interrogatory No.10 and each subparagraph thereof on the grounds that the infor-mation requested is not necessary for the clarification of any response to first round discovery requests and is therefore beyond the scope of second round discovery.
[11. Describe the current QA system for the documen-tation of procurement and specification regnirements, a)
Describe the changes if any, that IP has made in this system since the issu-ance of IE Inspection Report 50-461/81-05.
b)
Identify all those persons who are responsible for the changes, if any, that IP has made in this system.
c)
Identify all those persons who are responsible for the management, operation and implementation of this system.]
1 OBJECTIONS:
Illinois Power objects to Interrogatory No.11 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round disco-very requests and is therefore beyond the scope of second round discovery.
Requests for information concerning Inspection Report 50-461/81-05 are not in clarification of any first round discovery response because the inspection report is a public docunent which was available to the State on April 21, 1981.
Illinois Power responded to the inspection i
report in a letter dated June ll, 1981, from Leonard J. Koch, Vice President, to Mr. James G. Keppler, Office of Inspection and Enforcement, Region III.
This response was also a l
public document available to the State before submission l
of first round discovery requests.
Any requests for infor-mation concerning the inspection report or Illinois Power's response thereto could have been made in the first round of discovery.
ANSWER:
Specification requirements that must be met for procured items are passed on to suppliers through procurement documents such as purchase orders, specifications, and contracts.
These procurement documents are reviewed to _-
l ensure that appropriate requirements are included.
The procurement documents generally require the supplier to submit various types of documentation in conjunction with the item.
This documentation may include such things as procedures to be used by the manufacturer, drawings and 4
other design documents, performance test reports, qualifi-cation reports, material test reports, certificates of compliance or conformance, and instruction manuals.
The procurement documents generally specify where the supplier is to send the specific document and who reviews it for acceptability or approval.
When items are received, they i
are inspected for compliance with procurement document and specification requirements.
The documentation submitted by the supplier that attests to the quality of the manufac-tured items is also reviewed for compliance to procurement and specification requirements.
[12. Describe the current s; stem of using travelers to detail installation and inspection requirements.
a)
Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05.
)
b)
Identify all those persons who are responsible for the changes, if any, that IP has made in this system.
j c)
Identify all those persons who are responsible for the management, operation and implementa-tion of this system.]
4,
1
~J 1
OBJECTION:
Illinois Power objects to Interrogatory No.12 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory Nos. 4 and 5 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery and is therefore 'beyond the scope of second round discovery.
ANSWER:
" Travelers" used in fabrication and installation include provisions for operation sequence, reporting results of completion of specific operations, and check points for fabrication and installation.
Travelers also include spaces for initials or stamps of Baldwin Associates construc-tion and inspection personnel and the Authorized Nuclear Inspector for ASME Code Work.
[13. State the basis for IP's conclusion that the requirement that vendors acquire written authoriza-tion from IP, prior to shipment, to substitute a certificate of compliance for missing documenta-tion is unrealistic.]
OBJECTION:
Illinois Power objects to Interrogatory No.13 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery requests and is therefore beyond the scope of second round discovery. _
[14. Describe the QA system of document accountability and control that IP believes assures compliance with requirements for issuance of materials and equipment for installation or use at CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 14 on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery and is therefore beyond the scope of second round discovery,
[15. State what IP believes is the purpose of Procedures BA 2.20 and BA 2.3, and describe what procedures IP uses to meet this purpose.]
OBJECTION:
Illinois Power objects to Interrogatory No.15 on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round disco-very and is therefore beyond the scope of second round discovery.
[16. Describe the system IP is using to inspect safety-related pipe hangers. --_ _.
a)
Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection 50-461/81-05.
b)
State the average maximum time span between hangar installation and QC inspection.
c)
State whether this system requires documenta-tion of who installed the hangar components and when installation was completed.
d)
Identify all those persons who were responsi-ble for the changes, if any, that IP has made in this system.
e)
Identify all those persons who are responsible for the management, operation and implementa-tion of this system.]
OBJECTION:
Illinois Power objects to Interrogatory No.16 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery.
[17. Describe IP's system to ensure that welders are familiar with welding procedures and parameters, a)
Describe the changes, if any, that IP has made in this system since the issuance of IE Jrspection Report 50-461/81-05.
b)
Idta' fy all those persons who were responsi-ble
.;r changes, if any, that IP made in this system.
c)
Identify all those persons who are responsible e
for the management, operation and implementa-tion of this system.]
OBJECTION:
Illinois Power objects to Interrogatory No. 17 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory Nos. 4 and 5 of the State' First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery.
ANSWER:
All welders are tested and certified to weld procedure specifications in accordance with project proce-dures.
After certification, each welder is issued a copy of the " Welding Procedure Specification Handbook" (JV-49 3 )
which is controlled in accordance with Project Document Control Procedures.
Furthermore, specific weld procedures are available and controlled at various document control centers.
(18. Describe the record and document control system that IP uses to correlate IP audit findings to the necessary corrective actions.
.a)
Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05.
b)
Identify all those persons who are responsible for tne changes, if any, that IP has made in this system.
c)
Identify all those persons who are responsible for the management, operation and implementa-tion of this system.]
OBJECTION:
Illinois Power objects to Interrogatory No.18 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery.
ANSWER:
The method used to correlate corrective actions to Audit Findings is to document the corrective action taken on the respective audit finding form.
Furthermore, the Audit Team Leader's evaluation of corrective action and the verification of corrective action is documented on the audit finding form.
Upon completion of these actions and formal close-out of the audit finding by the Director-Quality Assurance, the audit findings are filed in the Clinton Power Station Document Records Center.
[19. Describe the system that IP uses to control the time taken between the completion and QA/QC inspec-tion of work.
a)
Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05....
b)
Identify all those persons who are responsible for the changes, if any, that IP has made in this system.
c)
Identify all those persons who are responsible for the management, operation and implementa-tion of this system.]
OBJECTION:
Illinois Power objects to Interrogatory No.19 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery and is therefore beyond the scope of second round discovery.
ANSWER:
Traveler systems identify and provide for sequencing of operations during fabrication and installation.
Certain operations are required to be completed and inspected prior to proceeding with other operations.
These are identi-fled as hold points.
Final inspections are accomplished following the completion of all work activities.
Construc-tion personnel are required to notify quality control person-nel for inspection as required by the procedures and travelers.
[ 20. State to what extent, if any, construction cost overruns or project delays at CPS-1 have been the result of:
a)
NRC regulatory changes; b)
NRC policy changes in the field;.
c)
BA design errors, miscalculations, oversights, underestimations, or delays; d)
Sargent and Lundy (S & L) design errors, miscalculations, oversights, underestimations, or delays; e)
General Electric (GE) design errors, miscalcu-lations, oversights, underestimations and/or delays; and f)
IP design errors, miscalculations, oversights, underestimations and/or delays.]
OBJECTION:
Illinois Power objects to Interrogatory No. 20 and each subparagraph thereof on the grounds that:
(1) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery, and (2) the request is too vague to allow formulation of a response.
[ 21. Identif y all NRC documents, known to IP, specifi-cally calling into question the judgment, experi-ence, capability or commitment to quality of IP regarding the construction or proposed operation of CPS-1.]
[22. Identify all S & L, BA, or GE documents, known to IP, specifically calling into question the judgment, experience, capability or commitment to quality of IP regarding the construction or proposed operation of CPS-1.]
[23. State whether IP has any knowledge of any IP, BA or S&L employee resigning his position or otherwise being terminated on account of disagree-i ment or dissatisfaction with the quality of con-struction or engineering work, or management I.
decisions or policies relating to the construction or proposed operation of CPS-1 and, if so, identify documents or otherwise provide details pertaining to any such occurrances.]
[24. State whether IP has any knowledge of any IP, BA or S&L employee lodging a complaint with IP concerning disagreement or dissatisfaction with the quality of construction or engineering work, or decisions or policies relating to the construc-tion or proposed operation of CPS-1, which com-plaint did not result in the resignation or termina-tion of that employee, and, if so, identify docu-ments or otherwise provide details pertaining to any such occurrances.]
OBJECTION:
Illinois Power objects to Interrogatory Nos. 21-24 on the grounds that:
(1) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery, and (2) the requests are too vague to allow formula-tion of a response.
Contention 3
[ General Interrogatory No. 1:
Identify all persons who have assisted in any way in the preparation of each answer to each interrogatory below and describe the substance of each person's assistance.]
ANSWER:
Robert L. McPherron, Supervisor-Planning.
[25. State whether IP has done an independent study of the tasks and costs involved in decommissioning CPS-1, and if not, whether IP plans to do so, and when.]._.
ANSWER:
Illinois Power has initiated an independent review by Whitman Requardt and Associates of the expected costs involved in decommissioning Unit 1.
[26. Why is immediate dismantlement the " assumed method" for decommissioning CPS-l?]
ANSWER:
The immediate disma"',lement method of decommission-ing has been used for planning purposes because:
1)
It is estimated to be less costly than the passive storage with deferred dismantlement method.
2)
It allows unrestricted use of the site after shutdown and decommissioning is completed.
[27. State whether IP has studied or commissioned any studies of alternatives to the immediate dismantlement method of decommissioning CPS-1 and, if so, summarize the results of those studies in terms of the tasks and costs involved.]
ANSWER:
IP has studied for planning purposes the passive safe storage with deferred dismantlement method of decommis-sioning.
The estimated costs of decommissioning CPS Unit 1 using this method in 1978 constant dollars are:
1)
Preparation for safe storage - $12.6 million.
2)
Annual continuing care - $80,000 per year 3)
Deferred dismantlement - $37 million (Dis-mantled 10 to 30 years af ter shutdown)
[28. State what plans, if any, IP has for use of CPS-1 site after decommissioning.].
\\
OBJECTIONS:
Illinois Power objects to Interrogatory No. 28 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery requests.
ANSWER:
IP has no specific plans at this time for use of the site after decommissioning.
[29. State whether IP has made plans or provisions for funding the costs involved in decommissioning CPS-1, and, if so, specify those plans or provi-sions.]
OBJECTIONS:
Illinois Power objects to Interrogatory No. 29 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
Illinois Power has made no specific plans for funding the costs involved in decommissioning CPS-1.
[30. To what extent, if any, have the costs of decommis-sioning CPS-1 been included in any of IP's rate requests to the Illinois Commerce Commission to date?]
OBJECTION:
Illinois Power objects to Interrogatory No. 30 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
1 ANSWER:
Decommissioning costs have not been included in rate requests to the Illinois Commerce Commission.
[31. Specify what plans or provisions IP has made, if any, to finance any further construction cost increases, not already accounted for, that may occur at CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 31 on the grounds that the information requested is not neces-sary for the clarification of any response to firct round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
Illinois Power's credit standing and reputation in the financial community will enable it to use the most advantageous financing available, whether short, intermediate, or long term; public or private, domestic or foreign, to meet any unforseen contingencies.
[32. Specify what plans or provisions IP has made, if any, to finance the decommissioning of CPS-1, once in operation, in the event of a major (TMI-2) accident.]
OBJECTION:
Illinois Power objects to Interrogatory No. 32 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
See the Answer to Interrogatory No. 31.
In addi-tion, Illinois Power has or will have insurance coverage as follows:
1.
Physical Damage Coverage to Plant and Equipment, including Decontamination Coverage.
Illinois Power will have in effect the maximum insurance coverage available when nuclear fuel arrives at the plant site.
Currently,
$450 million is the maximum coverage available.
- However, j
it is anticipated that by the end of 1981 one and possibly two additional insurance programs will be offering additional limits to bring total coverage available up to $1 billion.
2.
Extra Expense Coverage.
Illinois Power will purchase the maximum insurance available to cover the increased
]
cost of purchasing replacement power in the event of direct physical loss or radioactive contamination to the plant.
Currently, the maximum coverage available provides for a limit of $2.3 million per week for 52 weeks and $1.15 million per week for the next 52 weeks, for a maximum cover-age of $179.4 million.
The coverage would not be effective until after the first 26 weeks of an outage.
3.
Liability Coverage After Nuclear Fuel is Loaded in Reactor.
Illinois Power will purchase the maximum insurance coverage available, which is currently $160 million.
[33. Specify what plans or provisions IP has made, if any, to finance repairs and/or decommissioning of CPS-1 once in operation, in the event of an
, l l
y
.y m -
-r
accident or malfunction causing the shutdown of CPS-1 for six months or more, or permanently.]
OBJECTION:
Illinois Power objects to Interrogatory No. 33 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
See the Answer to Interrogatory No. 32.
[34. State the assumed capacity factors for each of the first ten (10) years of operation of CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 34 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
Contention 10
[ General Interrogatory No. 1:
Identify all persons who have assisted in any way in the preparation of each answer to each interrogatory below and describe the substance of each person's assistance.]
ANSWER:
The Answers to all interrogatories relating to Contention 10 were prepared under the supervision and direc-tion of Julius Geier, Manager - Nuclear Station Engineering.
[ 35. Describe in detail how IP plans to test the pres-sure differential of the low pressure core spray (LPCS) of the ECCS during operation of CPS-1]
I.
OBJECTION:
Illinois Power objects to Interrogatory No. 35 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
As a condition of its operating license, Illinois Power is required to demonstrate the ability of the Low Pressure Core Spray (LPCS) system to deliver rated perform-ance while the remainder of the plant is performing normally.
A full-flow test line allows the LPCS to take suction from the suppression pool and return flow to the pool without affecting other plant operations.
A throttle valve in the test line allows the plant operator to control pump flow and discharge pressure.
Installed instruments provide pump flow and pressure data.
[36. Describe in detail how IP plans to test the flow rate of the LPCS of the ECCS during operation of CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 36 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWEP.:
See the Answer to Interrogatory No. 35. \\
l
[37. Describe in detail how IP plans to test the pres-sure differential of the high-pressure core spray (HPCS) of the ECCS during operation of CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 37 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
The High Pressure Core Spray (HPCS) pump is tested in the same manner as the LPCS pump except that the suction source is usually the condensate storage tank.
Flow returns to the condensate storage tank via a full flow test line which contains two throttle valves in series.
The same general procedure is followed, and the same type of data is taken.
The HPCS data are compared with the technical specification to verify that the pump meets or exceeds its functional requirements.
[38. Describe in detail how IP plans to test the flow rate of the HPCS of the ECCS during operation of CPS-1.]
OBJECTION:
Illinois Power objects to Interrogatory No. 38 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
See the Answer to Interrogatory No. 37.,
[39. Has IP or its suppliers tested or measured the core spray sparger of the ECCS to determine the nozzle angles and individual bundle flows?
If so, describe the method of testing or measurement used and the results.
If not, state whether any test or measurement will be performed, when it will be performed, and what method of test or measurement will be used.]
OBJECTION:
Illinois Power objects to Interrogatory No. 39 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
General Electric has tested the core spray design applicable in establishing nozzle functional criteria.
These tests have determined spray characteristics of single nozzles and interaction affects of multiple nozzle operation in both steam and air environments.
These tests have been used to determine a set of nozzle configuration criteria capable of yielding acceptable flow rates to each fuel bundle for a particular core size.
[40. Explain the basis for IP's conclusion that the worst single failure / break type combination is 2
the HPCS line break of approximately 0.02 feet and the failure of the LPCS diesel generator that powers one LPCS pump and one low-pressure coolant injection (LPCI) pump.]
[41. Explain the basis for IP's conclusion that the worst single failure / break type combination, referred to above in Interrogatory 40, will,'ield the highest peak cladding temperature of approxi-mately 2085* F of all cases affected by LPCI diversion at 10 minutes.]
J l -
[42. Docs a change in the reduction factors for averag-ing cladding strain affect this conclusion?
Explain what affect a change in this factor will have.]
[43. Does a change in the reduction factor of 2.8 for fuel bundle interior rods affect this conclusion?
Explain what affect a change in this factor will have.]
[44. Does a change in the reduction factor of 4.1 for fuel bundle peripheral rods affect this conclusion?
Explain what affect a change in this factor will have.]
OBJECTION:
Illinois Power objects to Interrogatory Nos. 40-44 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
[45. State the basis for IP's conclusion that the GE model is conservative in comparison to the models described in NUREG 0620 within the range applicable to BWRs.
a)
Describe specifically what range is applicable to BWRs.
b)
Identify all documents of communication between IP and NRC regarding the GE model.
c)
Identify all documents of communication between IP and GE regarding the GE model.]
OBJECTION:
Illinois Power objects to Interrogatory No. 45 and each subpart thereof on the grounds that the information requested was provided in the response to Interrogatory No. 46.d of the State's First Set of Interrogatories.
. l 1
[46. Describe the additional sensitivity studies GE has agreed with NRC to perform.
a)
State whether these studies were completed by the end of July 1981, and if not, when they are scheduled for completion.
b)
Describe what action IP plans to take in response to the results of these studies.
OBJECTION:
Illinois Power objects to Interrogatory No. 46 on the grounds that the information requested was provided in response to Interrogatory No. 46.d of the State's First Set of Interrogatories.
ANSWER:
The studies were completed in October, 1981.
No actions are required in response to the results of these studies.
[47. State whether IP or its suppliers inspected or examined the core spray spargers prior to instal-lation at CPS-1 for the purpose of identifying any cracking.
If so, described the methods and results of this examination or inspection.]
OBJECTION:
Illinois Power objects to Interrogatory No. 47 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
The core spray spargers are examined during and after fabrication in accordance with GE specifications and a Product Quality Certification is issued.
Upon receipt I
of the core spray spargers, which are now part of the top guide assembly, visual inspection of the shipping crate.
and contents is made by the Clinton Power Station constructor to verify that there was no damage during shipment.
The Clinton Power Station constructor then issues a General Receiving Report.
The above two documents verify the condi-tion of the contents prior to installation at Clinton Power Station 1.
[48. State whether IP intends to inspect or examine the core spray spargers during operation of COS-1 for the purpose of identifying any cracking.
If so, describe this method of inspection or examination.]
OBJECTION:
Illinois Power objects to Interrogatory No. 48 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
Illinois Power intends to inspect or examine the core spray spargers during operation of Clinton Power Station 1 for the purpose of identifying any cracking in accordance with its regular inspection program.
[49. Describe in detail how the operation of the ECCS has been verified for worst-case, design-basis accident conditions.
a)
State whether this verification has been achieved by actual, operational tests, and if not, why not.
b)
Identify all documents used in support of IP's answer.].
OBJECTIONS:
Illinois Power objects to Interrogatory No. 49 and each subparagraph thereof on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 46.d of the State's First Set of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery.
ANSWER:
The performance of the ECCS during a loss of coolant accident (LOCA) including the worst case, design basis accident is determined through the application of a series of evaluation models.
These evaluation models have been design verified and are approved by the NRC.
During the course of model development, the physical pheno-mena affecting the ECCS performance have been extensively studied in a series of tests.
The results of these tests have been used to verify the accuracy and conservatisms in the evaluation models.
In addition, overall integrated system tests using the two loop test apparatus (TLTA) have been performed in order to demonstrate the ability of the ECCS to adequately cool the core even under worst-case, design basis accident conditions.
[50. Describe in detail how the operation of the ECCS has been verified for worst-case, anticipated transient without scram conditions. -..
A
[a)
State whether this verification has been achieved by actual, operational tests, and, if not, why not.]
b)
Identify all documents used in support of IP's answer.]
OBJECTIONS:
Illinois Power objects to Interrogatory No. 50 on the grounds that:
(1) the information requested was provided in response to Interrogatory No. 46.d of the State's First Set ~of Interrogatories, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests and is therefore beyond the scope of second round discovery.
[51. Describe the classification of the automatic depressurization system (ADS).
In addition, state whether:
a)
The ADS is safety-grade; b)
The ADS is classified as important to safety; and c)
The relief valves and their controls and instruments, which are used in conjunction with ADS, are classifies as safety-grade.]
OBJECTION:
Illinois Power objects to Interrogatory No. 51 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery, l
l l
l,
1
e e
contention 12
[ General Interrogatory No. 1:
Identify all persons who have assisted in any way in the preparation i
of each answer to each interrogatory below and describe the substance of each person's assistance.]
ANSWER:
The answers to all interrogatories were prepared under the supervision of Larry S. Brodsky, the Assistant Plant Manager of the Clinton Power Station.
[52. Describe the assumptions IP made and the calcula-tions IP performed to conclude that the dose rate exposure at the operator location due to the movement of a fuel assemblies is a few millirem per hour (mrem /hr ). ]
ANSWER:
The assumptions made were as follows:
(1) Fuel 4
bundle in the core for 1,000 days of full power, (2) Fuel transfer taking place 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reactor shutdown from full power operation.
The calculations were performed us,ing the shielding computer code ISOSHLD (FSAR 12.3.5-4).
(a)
What specific value (in mrem /hr) does IP mean when it states that dose rate exposure is a few mrem /hr?]
ANSWER:
The sp:cific dose value is variable between 0.5 and 5 mrem /hr. depending upon the fuel bundle and its loca-tion.
[b)
What total dose does IP expect during a vacst case transfer?]
ANSWER:
The total dose to an operator during the " worst case transfer" of a fuel bundle is estimated to be less than 1 mrem...
l (c)
Identify all documents IP used to answer this interrogatory.]
ANSWER:
The document used in these evaluations was the ISOSHLD code.
[53. Describe the assumptions IP made and the calcula-tions IP performed to determine that the dose rates in the accessible areas of the drywell, in the vicinity of the refueling pool bellows, will not exceed 16 mrem /hr.
a)
Identify all documents IP used to answer this interrogatory.]
I OBJECTION:
Illinois Power objects to Interrogatory No. 53
)
on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
[54. Describe the assumptions IP made and the calcula-tions IP performed to conclude that the contact dose rate on the shielding surrounding the fuel transfer tube is a few mrem /hr.]
ANSWER:
The assumptions made were the same as those listed in the Answer to Interrogatory No. 52.
The calculations were performed using the shielding computer codes ISOSHLD 3
AND G (FSAR References 12.3.5-4, 6).
(a)
What specific value (in mrem /hr) does IP mean when it states that dose rate exposure is a few mrem /hr?]
ANSWER:
The specific dose value varies between 0.5 and 5 mrem /hr. in the accessible area.
l l
}
\\
[b)
What total dose does IP expect during a worst case transfer?]
ANSWER:
The total dose to an operator is estimated to be less than 0.5 mrem during a " worst case" transfer of a fuel bundle.
[c)
Identify all documents IP used to answer this interrogatory.]
ANSWER:
The documents used in the evaluations were the ISOSHLD and G computer codes.
[55. Describe the administrative controls IP will provide to restrict access to the spent fuel transfer system.
a)
Identify all documents that describe these administrative controls.]
OBJECTION:
Illinois Power objects to Interrogatory No. 53 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
CPS 10P3702.01 CONTAINMENT / FUEL BUILDING FUEL TRANSFER is the controlling procedure which describes the necessary prerequisites prior to startup of the Inclined Fuel Transfer System (IFTS).
Prerequisites include verification that IFTS maintenance areas are clear of personnel and that shield accesses to these areas are installed and locked, and that keys are under the control of Radiation Protection personnel.
{
' l
CPS 10P3702.015 ensores that surveillance require-ments are completed on the transfer system using a dummy load.
This verifies the operability of all protective interlocks and system operation prior to transfer of spent fuel.
Maintenance in the area of the spent fuel transfer tube will be performed under the provisions of a Radiation Work Permit (RWP) per CPS No. OAP1024.02N RADIATION WORK PERMIT.
This ensures that all necessary precautions and i
prerequisites are addressed and that all such maintenance is performed under the cognizance of Radiation Protection personnel and the Shif t or Assistant Shif t Supervisor.
[56. Explain how the interlocking mechanisms of the spent fuel transfer system works when either one of the hatches is opened during the transfer of a spent fuel load in the carriage from the containment building to the spent fuel storage tank.]
ANSWER:
Once fuel is in transit through the tube, the access hatches cannot be opened.
[57. What action does IP plan to take in the event that a spent fuel load becomes stuck in the tube during transfer?]
ANSWER:
See the Answer to Interrogatory No. 52(b) of the State's First Set of Interrogatories.
Illinois Power will take the necessary steps to correct the malfunction or remove the fuel by manual means.,
[a)
What maximum dose rate and total exposure to personnel has IP calculated will occur during such an event?]
ANSWER:
The maximum dose rate which would exist during such an event is 5 mrem /hr.
Exposure will be minimized by limiting the time spent by any individual in the area of the spent fuel transfer tube.
[58. What action does IP plan to take in the event of an equipment malfunction during transfer of a spent fuel load in the tube?]
ANSWER:
Equipment would be repaired in accordance with standard operating and repair procedures.
Manual operation is possible if automatic operation fails.
[a)
What maximum dose rate and total exposure to personnel has IP calculated will occur during such an event?]
ANSWER:
See the Answer to Interrogatory No. 57 (a).
[59. What other measures does IP plan to take, besides the posting of signs and the use of interlocking mechanisms, to limit access to the spent fuel transfer system during operation?]
OBJECTION:
Illinois Power objects to Interrogatory No. 59 on the grounds that the information requested is not neces-sary for the clarification of any response to first round discovery and is therefore beyond the scope of second round discovery.
ANSWER:
See the Answer to Interrogatory No. 55(a).
i l.
STATE OF ILLINOIS
)
) SS COUNTY OF MACON
)
LEONARD J. KOCH, being duly sworn, deposes and says that he is Vice-President of Illinois Power Company, one of the Applicants in the proceeding; that he has read the foregoing Responses of Illinois Power Company to the State of Illinois' Secor.J Set of Interrogatories, and that the same are true and correct to the best of his knowledge, J
information, and belief.
~
Leonard J. Koch SUBSCRIBED and SWORN to before me this day of December, 1981.
Notary Public i
t i
i i
ILLINOIS POWER COMPANY B
2' M Lsohard J. J65h Vice President SIGNED AS TO OBJECTIONS:
i One of the Att6rneys for
{
Applicants I
Peter V. Fazio, Jr.
Sheldon A. Zabel i.
William Van Susteren i
Charles D.
Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower i
233 South Wacker Drive 4
Chicago, Illinois 60606 (312) 876-1000 Dated:
December 15, 1981 I
l l
l E
i l
STATE OF ILLINOIS
}
) SS COUNTY OF MACON
)
LEONARD J. KOCH, being duly sworn, deposes and says that he is Vice-President of Illinois Power Company, one of the Applicants in the proceeding; that he has read the foregoing Responses of Illinois Power Company to the State of Illinois' Second Set of Interrogatories, and that the same are true and correct to the best of his knowledge, information, and belief.
V Leonard J o'ch SUBSCRIBED and SWORN to before me this /Je* day of December, 1981.
Ytds h wwau A Notary Public t
0
4 EXHIBITS 4
9 l
EXHIBIT A
4
EXHIBIT A Former Quality Control Employees of Baldwin Associates Full Name Address Total BA Occupation or Position Level Certified Employment Randy J. Beeker II Certified 59 Months 802 Tyler 5/4/77 -
Monticello, Il.
4/24/81 Vendor Surveillance Chris Blenstraub II Certified 12 Months 2313 Anchor Dr.
7/2/79 Bloomington, Il.
7/11/80 Riping / Mech. Inspt.
John Bremm I
Certified 4 Months 158 Lori Lynn 2/11/81 Decatur, II.
5/27/81 Material Control Inspect.
Wayne Broadman II Certified 8 Months 102 S. Monroe 1/7/81 Clinton, II.
8/11/81 Electrical Inspector Robby G.
Brown I
Certified 3 Months 217 Sorrento Dr.
6/15/81 Terre Haute, Ind.
9/11/81 Riping / Mechanical Dennis Bell II Certified 11 Months R.
R.
5 Box 385 6/28/78 Dunnellon, Fla.
5/15/79 Civil /Struc. Inspect.
Eric Bergamyer II Certified 12 Months R. F. D..
6 8/16/76 Bloomington, Il.
9/2/77 C/S
1 Full Name Address Total DA Occupation or Position Level Certified Employment G.
B.
Brown III Certified 34 Months CQ P. O. Box 306 Still employed Clinton, Il.
7/9/75 C/S 5/3/78 Tracy L. Browning N/H Not Cert.
7 Days 1311 Hersey Road 11/16/81 Apt. (8 11/23/81 Bloomington, Il.
Electrical TA Dave Cordy II Certified 16 Months CQ 307 Westbrook Dr.
5/5/80 Mahomer, II.
9/16/81 Electrical Engr.
Randy Callison I
Certified 15 Months R.
R.
42 7/23/76 Farmer City, Il.
10/31/77 C/S Joe Cavato II Certified 23 Months 4030 Buckincham Dr.
8/2/76
- Decatur, I'.
7/5/78 Material Control l
Gary Conner II Certified 7 Months Striegel Ct.
4/5/77 Normal, 11.
10/31/77 Vendor Surveillance Frederick Creamer I
Certified 43 Months P.
O.
Boc 871 II 7/27/77 Clinton, II.
1/3/78 P/M II 10/29/79 Electrical I 2/11/81
i Full Name Address Total BA Occupation of Position Level Certified Employment Daniel Cummings None No Cert. ?
Summer Help 50 Park Lane 5/25/78 Clinton, II.
9/5/78 Summer Help Myles Denny II Certified 18 Months 03 E. Washington 3/17/79 Clinton, II.
1/21/81 N/P Michael P.
Evans II Certified 29 Months 515 E. Washington 6/15/77 Clinton, IL.
12/31/80 P/M Donald " Scott" Foster II Certified 5 Months 6 Hillcrest 10/6/80 Clinton, II.
2/27/81 Electrical Douglas Fuller I
Certified 3 Months Rt. #7 1/29/81 Kinney, 11.
3/3/81 Electrical Larry Gasaway I
Certified 4 Months 518 S.
Isabella 1/14/81 Clinton, II.
5/19/81 Electrical Morgan Gassmun, Jr.
II Certified 5 Months RR. 52, Box 437 1/5/81 Clinton, II.
P/M Inspector 6/16/81 Cli f ford Gordon None Not Cert.
1 Month 139-15 28th Road 4/20/81 Flushing, N.Y.
5/29/81 l
i
Full Name Address Total BA Occupation of Position Level Certified Employment Joe Guynn II Certified 6 Months P.O.
Box 46 3/3/81 Cisco, Il.
9/8/81 P/M James liall None Not Cert.
1 Month 44 Woodward St.
6/1/81 Farmer City, Il.
7/20/81 Electrical Ron lialverson II Certified 30 Months 605 S.
Center 6/29/78 Clinton, II.
12/8/80 P/M i
James Hannah II Certified 1 Month 5173 Lake Road 4/13/81 Geneva, Ohio 5/1/81 Vender Surveillance Robert Hilton I
Certified 8 Months Apt. #1 10/22/80 Park Motel 5/29/81 Clinton, II.
Electrical James lleyen I
Certified 5 Ponths 1542 Adams Dr.
5/26/80 Decatur, 11.
9/16/80 Electrical Joe Ilindmane II Certified 24 Months Box 322 10/19/77 109 S.
East 1/9/81 Clinton, Il.
P/M Coordinator
Full Name Address Total BA Occupation of Position Level Certified Employment John Hinthorn T
Certified 6 Months 1919 E.
Clay Linated II 1/26/81 Decatur, II.
7/3/81 Electrical George S.
Hake, Jr.
II Certified 3 Months 708 Albert Rill Road 7/10/78 Westminister, Md.
10/3/78 Electrical Randy Hake I
Certified 28 Months 18 E. Julia 6/20/79 Clinton, II.
11/3/81 P/M John Hook I
Certified 16 Months 40 S.
Catherine 5/16/77 La Grange, II.
9/21/78 Concrete /Ribar Fred Hauseholder II Certified 60 Months 07 W.
Clark 1/5/76 Apt. 302 1/30/81 Champaign, II.
Civil / Structural Jerry Jennings I
Certified 5 Months P.O.
Box 122 5/28/81 Niantic, II.
10/27/81 Electrical John Johnson II Certified 31 Months 1222 Searle Dr.
8/23/78 Normal, Il 2/27/81 Civil / Structural
Full Name Address Total BA Occupation of Position Level Certified Employment Larry Johnson I
Certified 28 Months 60 W.
Hickory Point Rd.
S/9/77 Dacatur, Il.
9/21/79 Electrical John Paul Jones II certified 45 Months RR 31 5/24/76 2/13/81 Vendor Surveillance Clement G.
Kamphaus None Not Cert.
1 Day 003 Weaver Drive 1/26/81 Urbana, II.
Alan W.
Koca II.
Certified 27 Months Rt. 1 County Lane Ct.
8/3/77 Heyworth, II.
11/5/79 P/M Richard A.
Kramer II Certified 17 Months 664 Burginer Dr.
11/17/77 Decatur, Il.
1/27/78 Receiving Inspection Thomas E.
La Baw None Not Cert.
1 Month 269 N.
Ash 3/9/81 4/24/81 Gerald R.
Lane II Certified 14 Months 247 N. Wood St.
11/2/78 1/14/81 Electrical Ken C.
Lapsly II Certified 9 Months 5 01 II. East 16th 10/8/76 Stuart, Fla.
7/22/77 C/S
Full Name Address Total BA Occupation of Position Level Certified Employment-David Laurindine Not. Cert.
2 Months 22o St. Denis 3/31/81 O.
La 70122 6/30/81 W.
Layfield III Certified 2 Months RR. #2 11/13/78 Farmer City, Il.
1/24/79 Sr. OA Elect.
Richy Ledbetter None Not Cert.
1 Day 1912 Trent Street 4/3/80 Winston Salem, NC Charles "Robbie" Lord, Jr.
II Certified 31 Months 76 S.
East St.
6/28/78 Clinton, I1.
5/8/81 Receiving / Mat. Cont.
Clifford Libby, Jr.
III Certified 26 Months Folly Pond Road 6/19/74 Beverly, Mass.
8/27/76 Mat'l Control Calvin Lunny II Certified 30 Months P.O.
Box 993 10/26/76 Bay City, Texas 4/13/79 P/M Alan W.
Lynch I
Certified 10 Months 112 S. Ja-kson 8/13/80 Clinton, Il.
6/12/81 P/M Richard McCullough II Certified 13 Months 522 W.
Green St.
7/9/79 Champaign, Il.
2/27/81 C/S
_ _.._ _~
Full Name Address Total BA Occupation df Position Level Certified Employment Tim McGuire II Certified 24 Months Mt. Vernon, II.
1/4/80 Electrical 12/20/81 Peter McKinna II Certified 30 Months 1706 E. Washington 5/8/78 Clinton, II.
11/21/80 P/M Martin Mirritt II Certified 25 Months Box 390, RR. #2 4/5/77 Clinton, II.
3/20/78 P/M 9/17/79 9/19/80 Thomas G. Moran II Certified Still 42 Hodgcon Ave.
Employed Pittsburg, Pa.
1/23/76 P/M 11/77 Tim Morrow II Certified 46 Months RR. 94 3/27/77 Mahomet, II.
11/18/80 P/M Andrew Nielsen II Certified 28 Months 21 Willowdale 2/16/76 St. Joseph, Il.
6/2/78 C/S Malcolm Norton I
Certified 6 Months OSB N.
Dianne Lane 5/18/81 Nahomet, II.
11/9/81 C/S
Full Nama Address Total BA Occupation of Position Level Certified Employment William O'Brien III Certified 7 Months WYE Motel 8/18/80 Clinton, Il 3/17/81 P/M Donald Patterson I
Certified 27 Months RR. 41 9/15/76 Clintnn, Il.
12/15/78 C1cril Scott Piepenbunk I
Certified 7 Months Box 30, RR. #1 1/15/81 Waynesville, Il.
7/24/81 Electrical Richard Pinca I
Certified 24 Months 15 N.
Quincy 9/19/77 Clinton, II.
9/7/79 Electrical Mark Porter I
Certified 2 Months 63 Country Club Road 8/24/81 Urbana, II.
10/16/81 Electrical C. M.
Powers III Certified 15 Months 109 Washington St.
8/30/76 Shreveport, La.
12/15/77 Mat'l Larry Prather I
Certified 6 Months 24 W.
Prairie Ave.
II (Limited) 6/11/79 Apt. 96 1/7/81 Decatur, Il.
Elect & Civil
Full Name Address Total BA Occupation of Position Level Certified Employment Harry Reilong II Certified 23 Months 617 E, Washington 4/5/78 Clinton, II.
10/22/80 Calibration Larry Richardson III Certified 31 Months 705 S.
Country Club Road 7/23/75 Decatur, II.
2/24/78 Calibration Ray J.
Roberts II Certified 22 Months 152 B.
Granedon St.
10/13/76 St. Purce, Fla.
1/3/78 Civil Walter Shanks II Certified 2 Months Rt.
4, Box 674 3/2/81 Ouka, Miss.
5/7/81 Civil Gary Sharar I
Certified 19 Months 905 Marquis St, 4/4/77 Clinton, Maryland 11/28/78 Mat'1 Control Larry Shaw II Certified 4 Months Rt.
4, Box 601-2 5/7/79 Lake of Woods Apts.
9/25/79 Nahomet, II.
P/M William Shinnoman II Certified 18 Months 235 Illinois Box 38 1/23/80 De Lan, II.
6/30/61 Elect.
i e
Full Name Address Total BA Occupation of Position Level Certified Employment J.
Silverstone II Certified 7 Months 421 E. Washington 5/9/80 Clinton, II.
12/12/80 P/M John Shelley I
Certified 12 Months 610 E.
Main St.
11/12/80 Decatur, Il.
10/20/81 Mat'l Control Howard Skoog II Certified 5 Months 03 E.
Union 4/12/78 Nahomet, Il.
10/1/79 Civil Kuft Sommer II Certified 24 Months 04 Schottsdale St.
4/4/77 Winter Park, Fla.
3/27/79 Civil Charles Staffold II Certified 42 Months 8 N.
Mulberry St.
5/10/76 Clinton, Il.
1/6/81 Civil Douglas Stephens II certified 12 Months 07 E.
High Street 7/21/80 Farmer City, Il.
6/1/81 Vendor Surveillance Gary Sutton II Certified 31 Months R.
5th Ave, Apt. #4 3/8/76 Crystal River, Fla.
11/6/79 Civil
~
Full Name Address Total BA Occupation of Position Level Certified Employment Martin R.
Telley III Certified 10/18/74 P.O.
Box 306 1/14/77 Clinton, II.
Fred L.
Thompson I
Certified 2 Months 95 Loma Drive 6/17/80 Forsight, II.
8/8/80 Elect.
Tim Walker III Certified 47 Months 313 Anchor Drive 4/5/77 Bloomington, II.
8/15/80 P/M Harold Washington II Certified 5 Months 609 E. Clark, Apt. 35 1/5/81 Champaign, Il.
6/2/81 Electrical Michael Watkins I
Certified 5 Months RR. #2 2/18/81 Clinton, Il.
7/3/81 Electrical Steve Wilber I
Certified 5 Months 5 N. Adams 2/4/81 P.O. Box 561 7/30/81 Cerro Gordo, II.
Electrical R.
C. Wilson III Certified 35 Months 204 W.
18th Terrace 8/18/75 Russellville, Ark.
7/26/78 Electrical
Full Name Address Total BA Occupation of Position Level Certified Employment Clarence Winfrey III Certified 59 Months 2311 Galen St. #4c 5/24/76 Champaign, II.
Civil 4/7/81 Don Woatten I
Certified 6 Months 2817 Tracy, Apt. #12 4/27/81 Bloomington, II.
Electrical 10/30/81 Charles Zalewski II Certified 42 Months 522 W. Green St.
6/2/76 Champaign, Il.
Civil 2/27/81 Merle L. Fumwalt II certified 3 Months 62 W.
Virginia, Apt 8 Peoria, II.
5/16/79 Civil 8/17/79 Robert Buch III certified 21 Months 3220 Vining Dr.
Decatur, Il.
7/2/74 OC C/S 4/1/76 John Linchen III Certified 70 Months 413 N. Monroe Clinton, II.
10/1/76 OC Mgr.
1/15/81 Wendy Oldinburs II Certified 20 Months 850 Cleveland Ave.
Apt. #325 10/17/77 St. Joseph, Mich.
4/13/79 Doc. Coord.
Full Name Address Total BA Occupation of Position Level Certified Employment G.
Paidchech III Certified 12 Months 239 Field Court 4/20/74 Decatur, II.
8/30/76 OC Mgr.
Piath II Certified 42 Months 809 White 9/28/77 Clinton, Il.
1/7/81 Doc. Coord.
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EXHIBIT B
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Exhibit B Present Fnployees of Baldain Associates' Quality Cbntrol Departnent Besponsible For Mechanical Inspection DUTIES /
SUBSTANCE OF NAME ADDRESS RESPONSIBILITIES QUALIFICATIONS ANY COMPLAINTS R. Cartpbell Baldwin Associates Sr. Piping / Mechanical Certified Invel III tb written P.O. Box 306 Engineer ANSI 45.2.6 cmplaints received Clinton, IL 61727 W. Stokes Same as Above Piping / Mechanical Certified Invel II No written Quality Control Engineer ANSI 45.2.6 ccmplaints received L. Clark Same as Above Piping / Mechanical Certified IA: vel II No written Inspector ANSI 45.2.6 cmplaints received II. Batthauer Same as Above Piping / Mechanical Certified IcVel II No written Inspection Supervisor ANSI 45.2.6 complaints received B. Weaver Same as Above Piping />Lhical Certified IEvel II No written Lead Inspector ANSI 45.2.6 cmplaints received D. Perkins Same as Above Piping / Mechanical Certified Invel II No written Irad Inspector ANSI 45.2.6 complaints received V. Mehta Same as Above Piping /Mt.d unical Certified Invel II No written Inspector ANSI 45.2.6 cmplaints received M. Cook Same as Above Piping / Mechanical Certified Invel II No written Inspector ANSI 45.2.6 complaints received R. Dnerson Same as Above Piping / Mechanical Certified Imel I lb written Inspector ANSI 45.2.6 cmplaints received C. Wade Same as Above Piping / Mechanical Certified Level I lb written Inspector ANSI 45.2.6 omplaints received J. Eaton Same as Above Piping /Mt h ical Certified IcVel I No written ANSI 45.2.6 cutplaints received L. Schaffert same as Above In training for In Training Ib written Piping / Mechanical cunplaints received Inspector
DUTIES /
SUBSTANCE OF NAME ADDRESS RESPONSIBILITIES QUALIFICATIONS ANY COMPLAINTS J. Culunber Baldwin Associates In Training for In Training No written P.O. Box 306 PipingAsochanical ca plaints received Clinton, IL 61727 Inspector Certified Invel II Currently Certified ANSI 45.2.6 Material Control Inspector M. Stone Same as Above Piping / Mechanical Certified Irvel II No written Inspector ANSI 45.2.6 ccrplaints received G. Fbntgcznery Same as Above Piping / Mechanical Certified Invel I No written Inspector ANSI 45.2.6 crmplaints received C. Itale F.ze as Above Piping /Machanical Certified Invel I No written Inspector ANSI 45.2.6 ctmplaints received G. Ekiss Same as Above Storage and Maintenance Certified Invel I No written ANSI 45.2.6 ccnplaints received J. Golden Same as Above Piping / Mechanical Certified Level II No written Inspector ANSI 45.2.6 cutplaints received R. Maples Same as Above PipingAlechanical Certified Level II No written Inspector ANSI 45.2.6 complaints received K. Rcmes Same as Above PipingAlechanical Certified Level II No written Inspector ANSI 45.2.6 ocuplaints received R. Jackson Same as Above PipingAsechanical Certified Invel I tb written j
Inspector ANSI 45.2.6 cunplaints received K. Frey Same as Above PipingAlechanical Certified Invel I tb written Inspector ANSI 45.2.6 ctmplaints received I. Padget Same as Above Calibration Certified Level II No written Inspector ANSI 45.2.6 complaints receimi R. Sullivan Same as Above Calibration Certified Invel II No written Inspector ANSI 45.2.6 amplaints received
DUTIE3/
SUBSTANCE OF NAME ADDRESS RESPONSIBILITIES QUALIFICATIONS ANY COMPLAINTS S. May Baldwin Associates Piping /Mect.aical Certified Level II No written P.O. Box 306 Inspector ANSI 45.2.6 conplaints received Clinton, IL 61727 J. Bogers Same as Above Piping /Meclunical Certified Invol I No written Inspector ANSI 45.2.6 cmplaints receivtx1 l
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