ML20040C008
| ML20040C008 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 01/21/1982 |
| From: | Neuman R ILLINOIS, STATE OF |
| To: | ILLINOIS POWER CO. |
| Shared Package | |
| ML20040C009 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8201270162 | |
| Download: ML20040C008 (7) | |
Text
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MTgo-OCCKETED im~ :'or il UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
'o2 JG 25 R2M7 IN THE MATTER OF
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ILLIN0IS POWER COMPANY,
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j' S0YLAND POWER COOPERATIVE, INC.)
and' WESTERN ILLIN0IS POWER
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COOPERATIVE, INC.
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Docket'No. 50-461 OL
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e.
g (0perating License for Clinton )
Power Station, Unit 1)
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S' A
RECElVED C
THE STATE OF ILLIN0IS' ADDITIONAL SECOND JA Es num,N2 61S62a ;7 ROUND INTERR0GATORIES TO APPLICANTS ftemseemY '/O 1,
EC The State of Illinois (Illinois) hereby propo'
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4 its additional second round Interrogatories to applicants, Ill1nois Power Company, Soyland Power Cooperative, Inc. and Western Illinois Power Cooperative, Inc. (collectively, IP),
pursuant to Section 2.470b of the Nuclear Regulatory Com-mission (NRC) Rules cf Practice.
Each interrogatory must l
be answered fully in writing, under oath or affirmation, and
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must include all relevant information known to IP.
Each answer must clearly indicate the interrogatory to which it responds.
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Pursuant.to Section 2.740(e) of the NRC Rules of Practice IP i ty$ci3 must supplement responses to interrogatories under certain 3
circumstances when new or different information becomes f
available.
If IP cannot answer one or more of the inter-4 rogatories in full, after exercising due diligence, state so and answer to the extent possible, specifying the in-ability to answer the unanswered portions.
Answers to these CKo!hhokjy PDR
interrogatories must be served upon Illinois by no later than February 22, 1982.
I.
Definitions and Instructions 1.
"And" or "or" is construed conjunctively and disjunctively so as to allow for broad answers to each interrogatory.
2.
" CPS-1" refers to the Clinton Power Station, Unit 1.
3.
" Document" means the original and non-conforming copies of written, printed, typed or graphic material of any kind or character, including, but not limited to, correspondence, letters, telegrams, memoranda, notes, records, minutes, contracts, agreements, records, studies, pamphlets, books, articles, treatises, records or notations of personal conversations or conferences, inter-office communicat;ons, micro-film, bulletins, circulars, blue prints, plans, drawings, photo-graphs, teletype messages, invoices, tape re-cordings, and work-sheets, together with all copies of said documents by whatever means made, in the custody, care, possession or control of any officer, director, employee, agent, con-i sultant, attorney or representative of IP.
Identification of copies of the original is necessary if there is material in the original or any copy that is not in other copies or the original.
4.
" Identify", when used with respect to a document, means to state its date, author, addressee, type of document, present loca-tion and custodian, and brief description of its contents.
If any such document was, but is no longer, in IP's custody, control, or possession state what disposition was made of it.
5.
" Identify", when used with respect to a person, means to state his or her full name, business or home address, and occupation or position.
6.
" Person" means an individual, agent, partnership, firm, company, consultant, corporation, association, political sub-division, governmental agency, or any other legal entity, or its legal representative, agent or assign.
7.
If IP refuses ~to answer any interrogatory, or any 8
part of any interrogatory, because it claims an alleged privilege, IP shall identify, to the extent consistent with its claim, the information or document claimed to be privi-leged and state the reason for IP's claim.
II.
Interrogatories A.
General 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.
2.
Identify all documents that were relied upon to provide an answer to each interrogatory below, and describe the substance of each document so used.
3.
Identify all persons whom IP plans to call to testify as to each contention, and state the qualifications of each person so identified.
4.
Describe for each interrogatory any additional research or work, if any, that IP plans to do 1
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that will affect the answer.
i B.
Contention 2 5.
With respect to the answer given to Interrogatory i
'3.d in IP's Supplemental-Response to Illinois' First Set of Interrogatories, specifically under the heading of "Baldwin Associates Quality Control Employees", please state:
T a) whether, to IP's knowledge, any of the 70 former employees included
- in the category " resigned-to accept new position" did so as a result of dissatisfaction or disagreement with the QC program for CPS-1, and if so state the name and most current ad-dress of each such employee.
b) whether any of the 3 discharges based upon " insubordination" involved or re-sulted from expressed criticisms, or refusal to follow specified procedures on professional grounds, of the QC pro-gram for CPS-1, and if so state the name and most current address ~of each such employee.
c) whether any of the 15. employees transfer-red to other BA departments were moved as a result of criticism, dissatisf action or disagreement with the QC program for CPS-1, and if so state the name and most cur-rent address of each such employee.
6.
With respect to the answer given to Interrogatory 3.d in IP's' Supplemental Response to IllinoisFirst-1 Set of' Interrogatories, specifically under the head-ing of "Ill.inois Power Quality Assurance Employees", 4 e
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please state whether, to IP's knowledge, any of the 9 former employees included in the ca tegory " resigned-to accept new posi tion",
did so as a result of dissatisfaction or disagreement with the QC program for CPS-1, and if so state the name and most current address of each such employee.
7.
With respect to the answer given to Interrog-atory 3.d in IP's Supplemental Response to Illinois' First Sct of Interrogatories, specifically under the heading of " Illinois Power Quality Assurance Employees", please clarify the apparent discrepancy between the number of employees given therein who were either transferred or terminated and the number of QA employees transferred or terminated shown in Exhibit K, attached in answer to Inter-rogatory 3 in IP's initial Answers to Illinois' First Set of Interrogatories.
C.
Contention 5 8.
State whether IP has made the minor modifications at CPS-1 that render SCRAM reliability sufficient to meet the NRC Staff safety goal of 10-6/ reactor-year.
9.
If the answer to Interrogatory 8 above is negative, then state:
a) which minor modification (s) IP has not made; and b) whether and when IP plans to make such modification (s).
Respectfully submitted, LL)
(b h Etv46 Reed W.
Neuman Assistant Attorney General Environmental Control Division Southern Region 500 South Second Street Springfield, IL 62706 (217) 782-9031 DATED:
January 21, 1982
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