ML20039C246

Answer Opposing Applicant Motion for Summary Disposition of Prairie Alliance Contention 5.Statement of Matl Fact as to Which There Is Genuine Issue to Be Heard & Certificate of Svc Encl

ML20039C246
Person / Time
Site:	Clinton
Issue date:	12/21/1981
From:	Bacon C PRAIRIE ALLIANCE
To:	NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8112290109
Download: ML20039C246 (5)

Text

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d C0'EETEC s :t ii UNITED STATES OF 70! ERICA' NUCLEAR FIG.LL'VRY CO'OiISSION, g 3 A9 03 cr"fi -U IN THE MATTER OF ) #  %

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, INC., )

and WESTERN ILLINOIS POWER ) O Docket No. Gli p COOPERATIVE, INC. )

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(Operating License for Clinton ) f/ R:. . _

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Power Station, Unit 1) ) ~

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ANSWER OF PRAIRIE ALLIANCE to APPLICANT'S MOTION FOR

SUMMARY

DISPOSITIONS _ _ , _ . _ .

of PRAIRIE ALLIANCE CONTENTION 5 .

Prairie Alliance ("PA"), by its represen,tive, pur-suant to'10 C.F.R. S 2.749, hereby moves this Board to denv Applicant's motion for Summary Disposition of Prairie Alliance Contention 5. In support of this answer PA states as follcws.

1. In its Memorandum and Order of May 29, 1981, the Atomic Safety and Licensing Board admitted Contention 5 (originally numbered Revised Contention 6), which states as follows:-

The CPS is especia}lv vulnerable to ct.*.icipated transients without scram (ATWS) due to fael"v welds during construction which have cused " burn throuch /

suck back" on a number of control rod drive tubes.

These defects have not been adeguatelv analyzed or repaired. The CPS should not be licensed to operate until IP has comaleted an ATWS analysis for (1) re-dundancy, (2) systens interaction, (3) loss of coolant accident, and (4) incidents such as those experienced in other GE boiling water reactors.

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2. . This Contention calls into question the vulnera-bility of the Clinton Power Station to ATWS defects and

_ failure of IP to complete a comprehensive ATWS analysis for (1) redundancy, (2) systems interaction, (3) loss of coolant accident, and (4) incidents such as those experienced in other GE boiling water reactors.

3. The Board admitted the last sentence of Conten-tion 5, and it still stands. IP must complete an ATWS analysis

. for the above-mentioned four points in Paragraph 2.

WHEREFORE, Prairie Alliance requests that the Board deny the Applicant's motion for Summary Disposition of PA Contention 5.

t Respectfully submitted,

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A Representative of Prairie Alliance Dated: December 21, 1981

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF )

ILLINOIS POWER COMPANY )

SOYLAND PONER COOPERATIVE, INC., )

and WESTERN ILLINOIS POWER )

COOPERATIVE, INC. Docket No. 50-461 OL

)

)

(Operating License for Clinton )

Power Station, Unit 1) )

STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE TO BE HEARD REGARDING PA CONTENTION 5

1. Applicant has not completed an ATWS analysis for (1) redundancy, (2) systems interaction, (3) loss of coolant accident, and (4) incidents such as those experi-enced in other GE boiling water reactors.

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UNITED STATES OF A'4 ERICA NUCLEAR REGULATORf COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

ILLINDIS POWER COMPANY, et al. Docket Nos. 50-461 OL

)

(Clinton Power Station, Unit 1) )

)

CERTIFICATE OF SERVICE I hereby certify that the ANSWER OF PRAIRIE ALLIANCE-T0 APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF PRIARIE ALLIANCE CONTENTION 5 in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an. asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 21st day of December 1981. .

Hugh K. Clark, Esq. , Chairman Peter V. Fazio, Jr. , Esq.

Administrative Judge Schiff, Hardin & Waite P.O. Box 127A 7200 Sears Tower Kennedyville, Maryland 21645 233 South Wacker Drive Dr. George A. Ferguson Administrative Judge Philip L. Willman, Esq.

School of Engineering Assistant Attorney General Howard University Environmental Control Division 2300 Sixth Street, N.W. 188 West Randolph Street, Suite 2315 Washington, D.C. 20059

, Chicago, Illinois 60501 l Dr. Oscar H. Paris

• Mr. Herbert H. Livermore Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Clinton Nuclear Pcwer Station U.S. Nuclear Regulatory Commission RR 3, Box 229A Washington, D.C. 20555 Clinton, Illinois 61727 Prairie Alliance Jeff Urish, Vice President P.O. Box 2424 Bloomington-Normal Prairie Alliance Station A 730 Wilkins Champaign, Illinois 61820 Normal, Illinois 61761

Reed fleuman, Esq. Gary fi. Wright Assistant Attorney General Illinois Department of'fluclear Safety 500 South Second Street 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62701 Springfield, Illinois 62704 Atomic Safety and Licensing Atomic Safety and Licensing Board Panel

• Appeal Board Panel

• U.S. Nuclear Regulatory Commission U.S. fiuclear Reculatory Commission Washington, D.C. 20555 Washington, D.C! 20555 Docketing and Service Section*

Office of the Secretary U.S. fiuclear Regulatory Commission Washington, D.C. 20555 f/ "f M A Representative of Prairie Alliance

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