ML20039G136

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Supplemental Response to Prairie Alliance First Round of Discovery Per ASLB 811216 Memorandum & Order.Certificate of Svc Encl
ML20039G136
Person / Time
Site: Clinton Constellation icon.png
Issue date: 01/06/1982
From: Geier J
ILLINOIS POWER CO.
To:
PRAIRIE ALLIANCE
References
ISSUANCES-OL, NUDOCS 8201150324
Download: ML20039G136 (14)


Text

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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.

)

)

(Operating License for Clinton

)

Power Station, Unit 1)

)

SUPPLEMENTAL RESPONSE OF ILLINOIS POWER TO PRAIRIE ALLIANCE'S PIRST ROUND OF DISCOVERY Illinois Power Company (" Illinois Power" or "the Company"), pursuant to the Memorandum and Order of the Atonic Safety and Licensing Board of December 16, 1981, hereby supplements its response to Prairie Alliance's First Round of Discovery as follows:

Document Requests Illinois Power responded to a number of Prairie Alliance document requests by stating that relevant documents were available for inspection.

Under the document inspection procedures followed by the parties, Illinois Power asked Prairie Alliance to specify, by contention or interrogatory, which documento it wished to have available at any particular document review session.

After assembling the relevant documents, Illinois Power was able to inform Prairie Alliance of the nature and amount of information available.

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Power has always been willing to provide estimates of the number of relevant documents requested, as well as a.descrip-tion of their contents.

The Company has therefore complied, through informal procedures, with the Board's Order of-December 16, 1981, with respect to Interrogatory Nos. 2, 3, 7, and 8 under Contention 1, and Interrogatory Nos1, 2, 3a, 3c, 3d, 4b, 4c, 6a, 6b, 7, and 8 under Contention 6.

Moreover, Prairie Alliance representatives have already reviewed most of the documents requested.

Other documents s

are identified in the exhibits to Illinois Power's Motion for Protective Order of January 6, 1982.

Contention 1 Off-Site Emergency Response Illinois Power has made available to Prairic Alliance such information as it had as of November 15, 1981, relating to off-site emergency responses.

Additional information will be made available at Prairie Alliance's request as it is received or developed by Illinois Power.

Contention 11

[11.1.

In reference to CPS FSAR 12.3.4.4.2.1 page 12.3-24:

a)

State the highest and lowest anticipat -

ed radiation levels at CPS, the method by which such levels were computed, the the name (s), addrsss (es), and qualifications of the person (s) who made the computations. -

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.(b) State what is meant by the " sufficient margin" mentioned on page 12.3-24 in the second paragraph (c) State the method by which "a sufficient margin" is determined, and the qualifi-cations and job titles of the person (s) who would make such a determination.

(d) Identify and attach any documents or other papers relating to the deter-mination of a sufficient margin.]

' ANSWER:

. Area monitors are located in general access areas of the plant.

The highest anticipated radiation level in these areas is 100 nr/hr.

The upper range of the area monitors extends to 10,000 ar/hr, which is 100 times the highest anticipated radiation level, and provides a large margin.

The lowest anticipated radiation level at Clinton Power Station is expected to be slightly greater than natural background, i.e., 0.01 mr/hr.

The lower limit of detectability for the area monitors is 0.01 mr/hr.

Computation methods for determining plant radiation levels are given in CPS FSAR Chapter 12.

The names, qualification and addresses of the persons who made the computations

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'M Kaiseruddin Ph.D. (Nuclear Engineering)

Shielding Project Engineer l

8 years experience in Nuclear Power Industry l

Address:

Sargent & Lundy 55 E. Monroe Street Chicago, Illinois 60603 1

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A. R. Piggot Electrical Engineer and Certified Health Physicist Supervisor of Shielding & Radiological Safety Section 30' years experience in field of atomic energy l

Address ~

Sargent & Lundy 55 E. Monroe Street Chicago, Illinois 60603

[11.2.

In reference to estimated population doses of ratiation:

(a) State the method by which estimated population doses were calculated.

Include in your answer the name(s) address (es), and qualifications of the person (s) making such calculations.]

ANSWER:

Methods for calculating population exposure for the Environmental Report are documented in the following references:

(a)

D. Nguyen.

Environmental Accident b

Evaluation - The ERRAE Code," NEDO-l 23893, 1979.

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(b)

E.W. Dradley.

" Gamma and Beta Dose L

to Man from Noble Gas Release to the Atmosphere," NEDO-23132, 1979.

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Methods for calculating Chapter 11 and 15 popula-tion exposures are documented in the following references:

(1)

Realistic Accident Dose Consequences (a)

D. Nguyen.

Realistic Accident Analysis.

j The RELAC Code," NEDO-21142, 1978.

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(b)

P.P. Stancavage et al.

Liquid Discharge Doses - LIDSR Code," NEDO-20609-01, 1976.

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(2)

Conservative Accident Dose Consequences P.P. 5tancavage et al.

" Conservative Radiological Accident Evaluation -

The CONACOl Code," NEDO-21143, 1976.

(3)

Normal Operating Effluent Dose Consequences (a)

D. Nguyen.

" Milk Ingestion Dose Code for Routine Releases of Gaseous Effluents for BWR Reactors - ONEAA Computer Code,"

NEDO-21289, 1976.

(b)

E.W. Bradley.

" Gamma and Beta Dose to Man from Noble Gas Release to the Atmosphere," NEDO-23132, 1979.

[11.3.

In reference to CPS FSAR page 1.G-20, Regulatory Guide 1.111, concerning the calculation of atmospheric effluents of routine releases:

a)

Describe in detail the methods used in the calculation of such effluents.

Include in your description the name(s),

address (es), and qualifications of the person (s) who made such calcula-tions.]

ANSWER:

The methods used are documented in the following reports:

(a)

S.M. Grove.

" Atmosphere Dispersion -

CHIQUO2 Function, NEDO-20804B, 1979.

(b)

D. Nguyen et al.

" Radiation Exposure from Airborne Effluents - The REFAE Code," NEDO-25257, 1980.

(c)

D. Nguyen.

" Meteorological Data for Radiological Evaluations - The METOR Computer Code," NEDO-21700, 1978.

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Education and Professional Qualifications of Van-Dat Nguyen Name:

Van-Dat Nguyen Address:

19557 Three Oaks Way Saratoga, California 95070 Posi tion: Engineer, Radiological Engineering Unit, General Electric Company California Professional Engineer (In Nuclear) No. 0403 Education:

M.S. in Cybernetic Systems 1972; San Jose State University M.S. in Meteorology and Air Pollution 1969; San Jose State University M.S. in Mechanical Engineering 1965; Ecole Centrale de Paris, France B.S. in Mechanical Engineering and Meteorology l

1963; College of Engineering, New York Univer-i sity Certificate in Literature 1958; Saigon University, Vietnam Experience:

1972-19 81 - GE Responsible for GE and NRC radiological saf ety and environmental reports.

Developed I

meteorological and environmental codes for i

BWR.

1 1969-1972 - GE Responsible for GE and NRC radiological safety reports and normal operation, of f-site gas dose calculations f rom BWR.

Developed computer codes for meteorological and radio-logical evaluation of gaseous effluents l

from Nuclear power stations.

1976-1969 - GE I

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Advance Design Unit for BWR; developed techni-cal risk evaluation for nuclear power ata-tions.

[11.4.

In reference to CPS FSAR page 1.8-169, Regulatory Guide 8.19, concerning dose assessments:

a)

State whether records of review proce-dures, documentation requirement.s, and identification of principal ALARA related changes resulting from the dose assessment will be included in the assessment.

If not, explain why not in detail.]

ANSWER:

Records of review procedures, documentation re-quirements, and identification of principal ALARA related changes resulting from the dose assessment will not be included in the assessments, as stated in the CPS-FSAR page 1.8 - 169.

These records shall, however, be availble for inspection at Clinton Power Station.

Illinois Power regards ALARA as a continuing program.

As a result, changes r

in plant procedures and minor modifications in hardware are expected to continue as the ALARA program continues.

Hence, there is a continuing revision of documents in order to further reduce the anticipated doses to personnel.

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b)

If the items in ll.4(a) are not to be included in the assessment, state the name (s), address (es), and qualifica-tions of the person (s) who determined that such items should not be included I

in the dose assessment.]

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ANSWER:

The person who determined that such itema should not be included in the dose assessment is Larry S. Brodsky, the Assistant Power Plant Manager of the Clinton Power Station.

His qualifications are set forth in the answer to Interrogatory No. 9.4 of Contention 9 in the Response of Illinois Power to Prairie Alliance's First Round of Discovery.

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ILLINOIS POWER CO.MPANY By:_

' J. D. Geier Manager 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, Illinois 60606 (312) 876-1000 Dated:

January 6, 1982 e

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STATE OF ILLINOIS

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SS COUNTY OF MACON

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J. D. Geier, being duly sworn, deposes and says that he is Manager of Nuclear Station Engineering Department for Illinois Power Company, one of the Applicants in this proceedings that he has read the foregoing Supplemental Response of Illinois Power to Prairie Alliance's First Round cf Discovery, and that the same are true and correct to the best of his knowledge, information, and belief.

V J. D. Geier Manager SUBSCRIBED and SWORN to before me this

/,* day of January, 1982.

8 Mb L/ Fot'ary Public

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$;&Tn OE Jay g CERTIFICATE OF SERVICE vp Dk,?:_ L ling ; c.a i

Iherebycartifythattheoriginalofthe[6hhgoing D

document was served'upon the following:

Prairie Alliance P.O. Box 2424 Station A Champaign, Illinois 61820 and three conformed copies of the foregoing document were filed with the following:

Secretary of the Commission i

United States Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch i

j 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 l

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 l

Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street i

Suite 2315 Chicago, Illinois 60610 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 in each case by deposit in the United States M il, postage a

prepaid on January 6, 1982.

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One of the Attorney or Applicants Peter V. Fazio, Jr.

Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wackcr Drive Chicago, Illinois 60606 (312) 876-1000 l

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00tMETE0 UMac UNITEDSTATESOFAMERb 1 ~8 m 26 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.

)

)

(Operating License for Clinton

)

Power Station, Unit 1)

)

NOTICE To:

Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.

Washington, D.C.

20059 Dr. Oscar H. Paris 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

I 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 Ccmmission SUPPLEMENTAL RESPONSE OF ILLINOIS POWER TO PRAIRIE ALLIANCE'S FIRST ROUND OF DISCOVERY in the above-captioned matter.

A copy of this docum6nt is attached hereto and hereby served upon you.

7

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s.

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 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated:

January 6, 1982 l

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