ML20039B807
| ML20039B807 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/15/1981 |
| From: | Fazio P, Koch L ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE |
| To: | PRAIRIE ALLIANCE |
| References | |
| ISSUANCES-OL, NUDOCS 8112230579 | |
| Download: ML20039B807 (29) | |
Text
{{#Wiki_filter:_ _ _ _ _ - _ _ _ _ __ - _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ _ d 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-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 PRAIRIE ALLIANCE'S PARTIAL SECOND ROUND OF DISCOVERY Illinois Power Company (" Illinois Power" or "the Company" or "IP") has objected herein to many of Prairie Alliance's interrogatories on one or both of the following grounds:
- 1. The information requested in the interrogatory was provided by Illinois Power in response to Prairie Al-liance's first round discovery requests. Prairie Alliance 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 provided in response to more general first round requests. Further review of documents produced in response to first round discovery requests 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 9112230579 011215"E DRADOCK05000gg -{)$C 3 ,,
e t to first round discovery requests. Prairie Alliance 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 Establishing Discovery Schedule, second round discovery was limited to " clarification of matters raised in the first round." Prairie Alliance'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 pro-vided all or part of the information requested in the inter-rogatory, despite the objection. The information is provided 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 in response to any additional discovery requests. [ General Interrogatory No. 1: Provide the direct answer to the question.] [ General Interrogatory No. 2: Provide docu-ments, including research, studies, calculations, memoranda, correspondence, reports, diagrams, computer codes, and all other records, that were relied upon by IP in answering the question, and also those which served as the basis for the answer.] ANSWER: Illinois Power will make available for inspection at its offices all documents in its possession, custody,
or control that were relied on to answer any interrogatory to which no objection is made. [ General Interrogatory No. 3: Identify by name, title, and qualifications the IP employee that has the expert knowledge required to support the answer to the question.] The Illinois Power employee with knowledge neces-sary to support the answers to Interrogatory Nos. 1 through 19 is John G. Cook. His title is Supervisor - Technical, and his qualifications are set forth in the Answer to General Interrogatory No. 3 under Contention 1 of Prairie Alliance's First Round of Discovery. [ General Interrogatory No. 4: Explain whether IP is presently engaged in or intends to engage in any further research or work which may affect the answer. Identify such research or work.] Illinois Power is continuously engaged in monitor-ing information that may affect the design, construction, or operation of the Clinton Power Station (" CPS" ) . Unless otherwise noted, or unless new information indicates the need for further investigation, Illinois Power does not plan to conduct further research or work which may affect the answers relative to a particular interrogatory. [ General Interrogatory No. 5: State the names, addresses, titles, and quali-fications of the persons IP intends to call as witnesses or experts for the answer and the subject matter which they intend to testify about.]
A 4 ANSWER: Illinois Power has not yet determined which persons it will call as witnesses should a hearing prove necessary. [1. (Regarding contention 1(a) (1)): 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:] OBJECTION: Illinois Power objects to Interrogatory No. 1 and each subparagraph thereof on the grounds that: (1) part of the information requested was provided, to the extent known to Illinois Power, in the Answer to Interrogatory No. 4 of Prairie Alliance's First Round of , Discovery, and (2) the remainder of the information 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. (a) Identify each facility for which actions are proposed.] ANSWER: Offsite emergency response activities will be carried out under the terms of an Emergency Services and Disaster Agency ("ESDA" ) emergency response plan which has not yet been published. Illinois Power does not have the specific information requested. [b) Identify all agencies responsible for termination of activities at such facili-ties.] _4_
l l ApSWER: The primary responsibility rects with ESDA; however, ESDA may call upon the resources of state and local govern-ment in taking emergency action. Such emergency action l may include mobilization of Department of Conservation i personnel and State and local police. [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.] ANSWER: See the Answer to Interrogatory No. 13(8) of Prairie Alliance's First Round of Discovery. In the area of responses to radiological emergencies, ESDA has participated in many full scale emergency plan drills at other nuclear plants in Illinois. Representatives of Illinois Power have observed certain drills. Moreover, full scale exercise of the CPS emergency plan will be held prior to licensing. (d) Specify the numbers and qualifications of local and state personnel expected to be involved in the termination of activities. e) Describe the types of equipment which local and state agencies will have at their disposal for use in the termi-nation of activities.) ANSWER: See the Answer to Interrogatory No. 1(a). [2. (Regarding contention 1(a) (3)): With respect to the severe weather conditions which may be expected in the site vicinity and plume and ingestion EPZ's throughout the year.] OBJECTION: Illinois Power objects to Interrogatory No. 2 and each subparagraph thereof on the grounds that: P
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(1) part of tne information requested was provided, to the extent known to Illinois Power, in the Answer to Interrogatory No. 6 of Prairie Alliance's First Round of Discovery, and (2) the remainder of the information 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. (a) Describe what provisions, if any, have been made to notify the general public in the plume and ingestion EPZ's of an emergency during severe weather conditions which interfere with or cause a breakdown in television and radio broadcasting.] ANSWER: Illinois Power is in the process of procuring an. Emergency Warning System which will meet all rege.latory requirements. (b) Describe what provisions, if any, have been made to insure that offsite per-sonnel needed to augment the onsite staff in the event of an emergency
, will arrite onsite promptly during severe weather conditions such as ice storms or blizzards.] '
ANSWER: Adequate staff is provided onsite to handle im-mediate and short term emergency needs. There is more than adequate time for supplemental personnel to arrive onsite by normal transportion even under adverse weather conditions. [c) Describe what provisions, if any, have been made to insure prompt evacuation
of the general public_within the plume exposure EPZ in the event of a severe weather condition, such as an ice storm or a blizzard.]' ANSWER: See the Answer to Interrogatory No.1(a) . ~ [d) If local and state agencies are respon-sible for any actions or provisions mentioned in parts a-c of this inter-rogatory, describe the methodology used by IP to determine that such agen-cies are capable of making timely, appropriate responses to emergency situations in the event of a severe weather condition such as an ice storm or blizzard.] ANSWER: See the Answer to Interrogatory No.1(c) . ! i [e) Describe the types of equipment which local and state agencies will have at their disposal for use for evacuation in the event of an emergency during an ice storm or blizzard or other severe weather condition.] ANSWER: See the Answer to Interrogatory No.1(a) . , [3. (Regarding contentions 1(d) (2) and 1(d) (3)): With respect to the role of the Illinois Department of Nuclear Safety in the(CPS Emergency Plan: a) Describe the criteria for determining the need for notification and partici-pation of the Department in the event of an emergency.] j ANSWER: The Illinois Department of Nuclear Safety will be notified of all emergencies. 4 [b) Identify the person (s) who developed the criteria, and his/her/their title (s) and qualifications.] 7-l' 6
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d I s ANSWER: John G. Cook, Supervisor-Technical. See the Answer to General Interrogatory No. 3 for qualifications. (c) Identify the titles and qualifications of the person (s) responsible for evalu-
- ating the criteria and determining I
the need for notification and partici-pation of the Department.] ANSWER: The Emergency Coordinator; See Chapter 4 of the CPS Emergency Plan for qualifications. [d) For each level of emergency, state
- . the anticipated time lapse between the occurrence of an emergency and notification of the Department.]
ANSWER: The notification aill occur as soon as possible within the 15 minute period prescribed in 10 C.F.R. Part 50, Appendix E. (e) For each. level of emergency, state the anticipated time lapse between notification of the Department and an appropriate onsite response by the Radiological Assessment Team.] ANSWER: The Radiological. Assessment Team is not normally required. If requested, it would arrive onsite approximately-three hours after receiving notification. i [4. Regarding contentions 1(d) (2) and 1(d) (3):
- With respect to the roles of the Illinois and DeWitt County' Emergency Services and
, Disaster Agencies in the CPS Emergency Plan: i a) State for each agency the criteria for determining the need for notification and participation of the agencies in the event of an emergency.] ANSWER: ESDA will be notified of all emergencies. 1 _. - . _ ~ . . _ - - . . _ . . - . _ _.~.... ,.. _ .. _. _ . _ _. . . .._....--._._....,_._....,._.___-,_-.--_,.....-..-,.m___..., - .
[b) Identif y the person (s) who developed the criteria, and state his/her/their title (s) and qualifications.] ANSWER: John G. Cook, Supervisor-Technical. See the Answer to General Interrogatory No. 3 for qualifications.
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[c) State the title (s) and qualifications of the person (s) responsible for evalu-ating the criteria and determining the need for notification of each agency in the event of an emergency.] ANSWER: The Emergency Coordinator; See Chapter 4 of the CPS Emergency Plan for qualifications. [d) For each level of emergency, state the anticipated time lapse between occurrence of the emergency and noti-fication of each agency.] ANSWER: The notification will occur as soon as possible within the 15 minute period prescribed in 10 C.F.R. Part 50, Appendix E. (e) For each level of emergency, state the anticipated time lapse between notification of each agency and an appropriate response by each agency.] ANSWER: ESDA will begin appropriate response action immedi-ately upon notification that any level of emergency has occurred. [5. (Regarding contentions 1(d) (2) and 1(d) (3)): With respect tc the role of the Chicago Department of Energy and the Argonne labo-ratory in the CPS Emergency Plan. a) State the criteria for determining the need for notification and partici-pation of each in the event of an emer-gency.]
. c ANSWER: Chicago DOE and Argonne National Laboratory will be notified of any site emergency or general emergency.
[b) Identify the person (s) who developed the criteria, and state her/his/their title (s) and qualifications.) ANSWER: John G. Cook, Supervisor-Technical. See the Answer to General Interrogatory No. 3 for qualifications. [c) Identify the person (s) responsible for evaluating the criteria and deter-mining the need for notification of the Department and the Argonne lab in the event of an emergency.] ANSWER: The Emergency Coordinator; See Chapter 4 of the CPS Emergency Plan for qualifications. [d) Describe the circumstances in which IP will request a team of radiation specialists pursuant to the Interagency Radiological Assistance Plan.] ANSWER: Any request for such assistance will come from the Illinois Department of Nuclear Safety. [e) State whether services provided by the Chicago Department and the Argonne laboratory are available on a 24 hour per day basis.] ANSWER: These services are available on a 24 hour 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.] ANSWER: Chicago DOE and Argonne National Laboratory will be notified within 15 minutes of the declaration of a site or a general emergency. (
[g) State the anticipated time lapse between notification and an appropriate onsite or offsite response by radiation spe-cialists pursuant to the Interagency Radiological Assistance Plan.] ANSWER: The time lapse is estimated to be 4 to 5 hours. [6. (Regarding contentions 1(d) (2) and 1(d) (3)): Describe all information, calculations, and methods which IP used in its determination , that state and local agencies responsible for any aspect of the Emergency Plan are capable of making timely and appropriate responses in the event of a radiological emergency. Include, but do not limit your answer to, a detailed description of each such agency's emergency response plans.] ANSWER: See the Answer to Interrogatory No.1(c) . [ Provide copies.of all documents, memoranda, communications, letters of agreement, and other papers describing the actions each such agency will take in the event of a radiological emergency.] OBJECTION: Illinois Power objects to the document request contained in Interrogatory No. 6 on the grounds that all relevant documents in its custody, control, 4-or possession were made available for inspection in response to first round discovery requests. [7. (Regarding contention 1(d) (2)): With respect to CPS No. OAP1890.02N concerning followup messages after initial 3.2 notification of offsite agencies: a) State what methods of disseminating followup messages exist, listing such methods in their perceived order of effectiveness.] ANSWER: See Chapter 8 of the CPS Emergency Plan.
[b) State the criteria for determining which method is the "best available," and state the title (s) and qualifications of the person (s) responsible for deter-mining which method will be utilized.] ANSWER: The best available communication method will be determined by the Emergency Coordinator or his-designee on a case by case basis. The best available method will be the system which provides the optimum combination of availability, clarity, and lack of interference with other communication. See Chapter 4 of the CPS Emergency Plan for qualifications. (c) State why radio transmission is to be avoided in followup messages.] ANSWER: Radio is avoided for follow-up messages so that it can be available for primary notification. For long transmissions the clarity and availability of radio is inferior to telephone. [8. (Regarding contention 1(d) (5)): Describe the methods, if any, by which offsite done projections will be made in the 30-60 minutes following an emergency but prior to the arrival onsite of the Supervisor-Radchem or Supervisor-Radiation Protection. If such methods exist, state the title (s) and qualifications of the person (s) responsible for making such projections.] ANSWER: Prior to arrival onsite of the Supervisor-Radchem or Supervisor-Radiation Protection, the Radiation Protection Shift Supervisor will make the necessary decisions pertaining to radiological conditions following an emergency. These
positions are filled by qualified individuals who will be trained in the interpretation of offsite dose projections. See the Answer to Interrogatory No. l(c) of the State of Illinois' First Set of Interrogatories. The Process Radia-tion Monitoring System (PRMS) and the PRMS Report Gener-ator will be utilized to obtain the necessary information for these dose projections. This equipment is located within the Radiation Protection Office area. [9. (Regarding contention 1(e)): With 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,]
ANSWER: The news media have not been provided with a complete Emergency Plan. At an informal meeting with news media representatives on June 5, 1981, Illinois Power explained the overall requirements of emergency planning and solicited questions and suggestions concerning news media needs. [2) Provision of detailed emergency training for such media,] ANSWER: Illinois Power has offered news media representa-tives informal training on nuclear mctters by providing written materials and conducting press briefings and plant tours. Illinois Power expects to continue and expand these efforts and provide additional materials on the news media's role during-an emergency. The news media will be included in all emergency drills held. [3) Establishment of points of contact for the release of information during an emergency for such media,] ANSWER: Illinois Power has discussed with news media repre-sentatives the establishment of contact points that best fit media needs. These contact points have not yet been formally established. [4) Arrangments for the timely exchange of information between IP and the media.] ANSWER: Illinois Power and news media representatives have discussed informally the development of procedures for exchange of information. [b) For each classification of emergency, state the anticipated frequency of the exchange of information between IP and the media.] ANSWER: The frequency of information exchanges with the media will be more dependent on the occurrence of events than the classification of the emergency. Illinois Power anticipates making the public and the cress immediately aware of any change in status during any emergency. [c) If any plans or agreements have been made, state (by name and type) with l which media such plans or agreements j have been made. Also, state (by name and type) with which media such plans or agreements will be made in the future. l l
l 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.] ANSWER: Formal plans or agreements have not yet been made. Illinois Power is in the process of developing a media plan. [10. (Regarding contention 9): With respect to CPS OAP1890.04N 2.1.2 concerning immediate actions to be taken in the event of an Unusual Event:] a) State under what circumstances it will be inappropriate to make a statement to plant personnel describing the event. b) State the criteria used to make this determination, and the name (s) , title (s) and qualifications of the person (s) making the determina-tion. c) Identify the person who developed the criteria by name, title, and qualifications.] OBJECTION: Illinois Power objects to Interrogatory No. 10 and each subparagraph thereof on the grounds that: (1) the information requested is beyond the scope of Contention 9 as admitted. Contention 9 concerns only the accuracy of the arua radiation monitors and the number and sensitivity of the continuous air monitors. See Illinois Power's Response to Interrogatory Nos. 9.1,
9.2, and 9.3 of Prairie Alliance's First Round of Discovery and the Memorandum in Support of Applicants' Arswer to Prairie Alliance's Motion to Compel Discovery. (2) the information requested is_not necessary for the clarification of any response to first round dis-covery requests under Contention 9 anf Is therefore beyond the scope of second round discovery. ANSWER: Any decision on notification of plant personnel will be made by the Emergency Coordinator on a case by I case basis. See Chapter 4 of the CPS Emergency Plan. [11. (Regarding contention 9): With respect to CPS OAP1890.04N 3.2.4 concerning resto-ration 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.]
OBJECTION: Illinois Power objects to Interrogatory No.11 l and each subparagraph thereof on the grounds that: (1) the information requested is beyond the scope of Contention 9 as admitted, and (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests under Contention 9 and is therefore beyond the scope of second round discovery. ANSWER: The frequency of these activities will be determined on a case by case basis by the Radiological Control and Waste Manager. See Chapter 15 of the CPS Emergency Plan. [12. (Regarding contention 9): With respect to CPS Emergency Plan 12.1.1: a) Identify by name, title, and qualifi-cations each person who will be respon-sible for weighing the projected dose against the benefits to be gained. 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 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 does limits.] OBJECTION: Illinois Power objects to Interrogatory No.12 and each subparagraph thereof on the grounds that: (1) the information requested is beyond the scope of Contention 9 as admitted, and
- (2) the information requested is not necessary for the clarification of any response to first round dis-covery requests under Contention 9 and is therefore beyond l
the scope of second round discovery. ANSWER: The Emergency Coordinator is responsible for im-plementing the EPA Protective Action Guides for exposure to radiation. The guides have predetermined limits for
the amount of radiation which an individual should be allowed to receive for different activities. [13. (Regarding contention 11): With respect to CPS Emergency Plan 12.1.2., state why responsible 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 rem thyroid.] OBJECTION: Illinois Power objects to Interrogatory No. 13 on the grounds that: (1) the information requested is beyond the scope of Contention 11 as admitted, since it concerns neither the estimates used in calculating atmospheric effluents nor the consideration of the effects of low-level releases in the cost-benefit analysis of the Environmental Report, and (2) the information-requested is not necessary for the clarification of any response to first round dis-covery requests under Contention 11 and in therefore beyond the scope of second round discovery. ANSWER: As set forth in the EPA Protective Action Guides, i ' local constraints may make lower dose values impractical l l to use. It is Illinois Power's understanding that the Illinois Department of Nuclear Safety will initiate protec-tive action at 1 Rem whole body exposure or 5 Rem thyroid exposure to the general public.
[14. (Regarding contention 1(d)): With respect to CPS Emergency Plan 12.2.3, describe all 4 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) Describe the methods by which state and local governments will activate the system, c) Describe all information, calculations, methods, etc., which were utilized by IP in determining that state and local government agencies are capable of activating the system.] ANSWER: Illinois Power has committed to providing an Emer-gency Warning System which will be operational prior to fuel load. The DeWitt County ESDA organization will be able to activate the system. See the Answer to Interroga-tory No.1(c) . [15. (Regarding contention ld3, le) With respect to CPS Emergency Plan 12.3 concerning evacu-l ation: I l a) State the criteria utilized by state and local government officials in deter-mining when to evacuate the general public. b) Describe the public evacuation procedure and list locations for relocation centers contained in the state and local govern-ment emergency plans listed at CPS FSAR Emergency Plan 12.3.2.
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c) Provide copies of all state and local ' government emergency pluns described 4 in 12.3.2. . d) Describe all information of any kind, including calculations, methods of - - determination, etc., which were utilized by IP in confirming local-and state governmental capability to carry out an effective and timely evacuation of the general public. ; y
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e) Describe all equipment which local and state governmental agencies have ; at their disposal to effect an evacuation ,J" of persons who own no private means of transportation:] ., s, ANSWER: The details of the state and local emergency plans _ i ' 'l and copies of the plans themselves should be obtained from \q ' ~ r ..
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[16. (Regarding contention Ib): With respect ' to CPS Emergency Plan 14.3.1 concerning * - IP's agreement with John Warner-Hospital, ,3 describe in detail the equipment and staff . 'u s\ available for dealing with radiat' ion inju-ries.] ANSWER: As discussed in the CPS Emergency Plan, Illinois s , Power's radiation medical consultant is Radiation-MAnagemqnt ' s ;y . ., j Corporation (RMC) , which is af filiated with Northwestern ' i University Medical Center. RMC and Northwestern Univer_sity t i Medical Center will provide speci$lty treatment for radiation. -
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ANSWER: 'Se'eithe Answer to Interrog'atory No. 8 of Prairie
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t. i - [19., Provide copies of the following supporting plans: 3 2 ; a) Illinois Plan for Radiological Assist-r ance. t, b) DeWitt County Emergency Response Plan. c) Illinois Comprehensive Disaster Response Plan.] ANSWER: Plans should be obtained from the government agency F responsible for preparing the plan. The state plan is being prepared by Illinois ESDA and' will be made available 2 to the public in the future. The local plan will be prepared by the DeWitt County ESDA organization. Contention No. 6 ( ! [a) Provide documents related to accuracy ' f of indication of water level'using i reference leg differential pressure l monitor, particularly those studies
- concerning calibr ation and possible s ,
instrument failure scenarios, boilout, etc. i'
', [ b) Droduce documents which show how shutdown water level indication information would be interpreted at other than design conditions.
I c) Provide documents relating to application of losse parts monitoring LPM to reactor pressure vessel integrity. t V' Y c' 4 - l s
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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 equipment in additional accident and por~c-accident monitoring devices. f) Provide documents produced by IP as input for formulation of NRC document CR/1580. g) Provide documents produced for NRC control room minireview. h) Provide documents pertaining to display console system and its reliability, and software controlling automated program selection and its reliability.
- 1) Provide reliability studies for computer and microprocessors used in CR, including expected downtime specific dysfunction and repair.
i) Provide documents delineating how NRC commis-sioned research on disturbance analysis DAS will be incorporated into CR software.] OBJECTION: Illinois Power objects to all interrogatories under Contention 6 on the grounds that: (1) many of the documents requested were produced in response to first round discovery requests, and (2) the production of other documents requested is beyond the scope of second round discovery since these documents are not necessary for the clarification of any response to first round discovery requests. l l e .* . ILLINOIS POWER COMPANY By: d P L6ohard J. Fgch' Vice President WGNED AS TO OBJECTIONS : t -
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One of the Attornbys)for Applicants Peter V. Fazio, Jr. Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinios 60606 (312) 876-1000 Dated: December 15, 1981 S J
.,o STATE OF ILLINOIS )
) SS COUNTY OF MACOli )
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 Prairie Alliance's Partial Second Round of Discovery; and that the Answers contained therein are true and correct to the best of his knowledge, information, and belief.
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LeonardJ.foEn* SUBSCRIBED and SWORN to before me this /M day of December, 1981.
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' Notary Public
1 CERTIFICATE OF SERVICL I hereby certify that the original of the foregoing document was served upon the following: Prairie Alliance P. O. Box 2424 Station A Champaign, Illinois 61820 and three conformed copies of the foregoing documents were filed with the following: Secretary of the Commission United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch and that one copy of the foregoing document 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 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 Philip L Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
f Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Rcqulatory Commission Washington, D.C. 20555 i-
- in each case by deposit in the United States Mail, postage prepaid on December 15, 1981.
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l']b% h#"' i One of the Attorneys,for
- Applicants Peter V. Fazio Sheldon A. Zabel William Van Susteren 4 Charles D. Fox IV SCHIFF HARDIN & WAITE
^ 7200 Sears Tower . 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 - 4 4 g
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",1 P9 21 fM 52 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )
ILLINOIS POWER COMPANY, ) SOYLAND POWER COOPERATIVE, INC. ) and WESTERN ILLINOIS POWER ) Docket No. 50-461 OL COOPERATIVE, INC. )
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(Operating License for Clinton ) Power Station, Unit 1) ) NOTICE 9 @, Hugh K. Clark, Esq., Chairman y, P.O. Box 127A j gggIflltjgf A Kennedyville, Maryland 21645 , C Dr. George A. Ferguson Tc Ogg221981.s I eyJ77. A . 9-' t, ., School of Engineering A nc M.i". g-Howard University t_ 2300 Sixth Street, N.W. / ',s 4 \g/g Washington, D.C. 20059 Y 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 Washingotn, D.C. 20555 Philip L. Willman > Assistant Attorney General Environnental Control Division 188 West Randolph Street Suite 2315
.bW3 Chicago, Illinois 60610
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- Atomic Safety and Licensing Board Panel UsS. 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 I today served upon Prairie Alliance, P.O. Box 2424, Station A, Champaign, Illinois 61820, and have filed with the Secretary of the United States Nuclear Regulatory Commission RESPONSE OF ILLINOIS POWER TO PRAIRIE ALLIANCE'S PARTIAL SECOND ROUND OF DISCOVERY in the above captioned matter. A copy of this document is attached hereto and hereby served upon you.
. 1 J ._i+Ah One of the Attorneys \foi Applicants .,
Peter V. Fazio 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 4 m - S
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