ML20039B560
| ML20039B560 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/15/1981 |
| From: | Fazio P ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE |
| To: | ILLINOIS, STATE OF |
| Shared Package | |
| ML20039B555 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8112230234 | |
| Download: ML20039B560 (8) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
)
ILLINOIS POWER COMPANY, i
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 REQUEST FOR PRODUCTION OF DOCUMENTS BY APPLICANTS Illinois Power Company (" Illinois Power" or "the Company" or "IP"), on behalf of itself, Soyland Power Coopera-tive, Inc., and Western Illinois Power Cooperative, Inc.
(col-lectively " Applicants"), responds as follows to the State of Illinois' ("the State") Second Request for Production of Documents by Applicants:
[1.
All documents IP has itemized in each answer to Illinois' second set of inter-rogatories.]
ANSWER:
Any document in Applicants' possession, custody, or control itemized in an answer to an interrogatory to which no objection is made will be available for inspection at the offices of Illinois Power.
[2.
NEDO 20566 and any supplements thereto.]
[3.
A letter to NRC from General Electric i
1 Company (GE), entitled "GE Fuel Clad Swelling and Rupture Model," dated May 15,1981.]
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1 8112230234 811215 DRADOCK05000g
OBJECTION:
Illinois Power objects to Document Request Nos. 2 and 3 on the grounds that the documents requested were produced in the first round of discovery in response to Interrogatory No. 46.d of the State's First Set of Interro-gatories and in response to the State's First Request for Production of Documents.
[4.
All Baldwin Associates' (BA) Quality Control (QC) or 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.]
OgJECTIOM:
Illinois Power objects to Document Request Nos. 4 through 8 on the grounds that the documents requested were provided in response to Interrogatory No. 4 of the State's First Set of Interrogatories and in response to the State's First Request for the Production of Documents. -
t i
[9.
All documents related to NRC's Systematic Assessment of License Performance Review of IP and CPS-1, particularly a report i
dated November 12, 1980.]
OBJECTION:
Illinois Power objects to Document Request i
No. 9 on the grounds that (1) many of the documents requested were provided in response to Interrogatory Nos. 4 and 5 of the State's First Set of Interrogatories and in response to the State's First Request for the Production of Documents, and (2) the production of other documents requested 4
is beyond the scope of second round discovery since these
)
documents are not necessary for the clarification of any I
response to first round discovery requests.
[10.
A memorandum from BA Resident Engineer to BA Senior Piping Engineer on employ-ment policy dated February 17, 1981.]
OBJECTION:
Illinois P0wer objects to Document Request No. 10 on the grounds chat the document requested was pro-vided in response to Interrogatory Ns. 5 of the State's First' Set of Interrogatories and in response to the State's 4
First Request for the Production of Documents.
i,
[11.
A report by Theodore Barry and Associates, comparing CPS-1 construction cost over-runs and delays to the nuclear industry.]
OBJECTION:
Illinois Power objects to Document Request No.11 on the grotands that all documents relating to matters raised in the request were provided in response to Interroga-i tory No. 5 of the State's First Set of Interrogatories i
e l
and in response to the State's First Request for Production of Documents.
These documents are part of the public record in Illinois Power's 1979 rate case, Illinois Commerce Com-mission Docket No. 79-0071.
[12.
All documents related to meetings held between IP and NRC.]
t
[13.
All documents related to meetings held j
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 Regu-latory Guide Compliance Program.]
)
OBJECTION:
Illinois Power objects to Document Request Nos. 12 through 17 on the grounds that:
(1) many of the documents requested were provided in response to Interrogatory Nos. 4 and 5 of the State's First Set of Interrogatories and in response to the State's First Request for Production of Documents, and (2) the production of other documents requested is beyond the scope of second round discovery since these l
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e documents are not necessary for the clarification of any response to first round discovery requests.
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)
t One of the Attorneys for Applicants Peter V. Fazio, Jr.
Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower i
233 Soutl. Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated:
December 15, 1981 I
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e CERTIFICATE OF SERVICE
~
I hereby certify that the original of each of the foregoing documents was served upon the following:
Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 that three conformed copies of each of the foregoing documents were filed with the follo3ing:
Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Docketing and Service Branch and that one copy of each of the foregoing documents was served upon each of the following:
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 Prairie Alliance P. O.
Box 2424 Station A Champaign, Illinois 61820 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C.
20555
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'T 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 Regulatoly Commission Washington, D.C.
20555 in each case by deposit in the United States Mail, postage prepaid on December 15, 1981.
One of the Attorneys >for Peter V. Fazio Sheldon A.
Zabel William Van Susteren Charles D. Fox IV SCHIFF RARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60006 (312) 876-1000 t
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' 3r g053 UNITED STATES OF ANOhI NUCLEAR REGULATORY COMMISSION
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IN THE MATTER OF
)
ILLINOIS POWER COMPANY,
)
SOYLAND POWER COOPERATIVE, INC.
)
Docket No. 50-461 OL and WES7'ERN ILIINOIS POWER
)
COOPERATIVE, II,1C.
)
)
(Operating License for Clinton
)
Power Station, Unit 1)
)
NOTICE o
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To:
RECE!VED hW Hugh K. Clark, Esq., Chairman DEC 221981% y P. O. Box 127A ts La rmugg,,[' -
Kennedyville, Maryland 21645 cy,
'**1gann Dr. George A. Ferguson s'd';w M,&
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School of Engineering 1
Howard. University 2300 Sixth Street, N.W.
Washington, D.C.
20059 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Prairie Alliance 50}
P. O. Box 2424 9
Station A y
Champaign, Illinois 61820 Atomic Safety and Licensing Board Panel f[
l U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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Atomic Safety and Licensing i
Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 PLEASE TAKE NOTICE that I have today served upon Philip L. Willman, Assistant Attorney General, Environmental Control Division, 188 West Randolph Street, Suite 2315, Chicago, Illinois 60610, and have filed with the Secretary of the United States Nuclear Regulatory Commission RESPONSE OF ILLINOIS POWER TO THE STATE OF ILLINOIS' SECOND SET OF INTERROGATORIES TO APPLICANTS and RESPONSE OF ILLINOIS POWER TO THE STATE OF lLLINOIS' SECOND REQUEST BY APPLICANTS FOR PRODUCTION OF DOCUMENTS in the above captioned matter.
A copy of these documents is attached hereto and hereby served upon you.
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f k/12h One of the Attornbys for.
Peter F. Fazio Applicr nte a
Sheldon A.
Zabel William Van Susteren Charles D.
Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated:
December 15, 1981
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