ML20041C060
| ML20041C060 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/19/1982 |
| From: | Koch L ILLINOIS POWER CO. |
| To: | ILLINOIS, STATE OF |
| Shared Package | |
| ML20041C061 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8202260110 | |
| Download: ML20041C060 (6) | |
Text
.-N UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN YHE MATTER OF
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ILLINOIS POWER COMPANY,
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SOYLAND POWER COOPERATIVE,INC.
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and WESTERN ILLINOIS POWER
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Docket No. 50-461 OL COOPERATIVE, INC.
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(Operating License fw Clinton
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Power Station, Unit 1)
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RESPONSE OF ILLINOIS POWER TO THE JTATE OF ILLINOIS' ADDITIONAL SECOND ROUND INTERROGATORIES TO APPLICANTS B11nois Power Company ("D11nois Power" w "the Company"),
on behalf of itself, Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative,Inc. (" Applicants"), hereby responds to the State of Illinois' ("Blinois") Additional Second Round Interrogatwies to Applicants as follows:
A. General
[GeneralInterrogatwy No.1: Identify all persons who have assisted in any way in the preparation of each -
answer to each interrogatwy below and describe the substance of each person's assistance.]
ANSWER: All infwmation supplied on Contention 2 was prepared under the supervision and direction of Allan J. Budnick, Director-Quality Assur-ance. All infwmation supplied on Contention 5 was prepared under the supervision and direction of Julius D. Geler, Manager - Nuclear Station Engineering Department.
9503 8202260110 820219 9 <>Jll PDR ADOCK 05000461 G
[ General Interrogatory No. 2: Identify all documents that were relied upon to provide an answer to each interrogatwy below, and describe the substance of each document so used.]
ANSWER: No documents were relied upon to provide an answer to any of these interrogatories.
[ General Interrogatory No. 3: Identify all persons whom IP plans to call to testify as to each contention, and state the quell-fications of each person so identified.]
ANSWER: Illinois Power has not yet determined which persons it will call as witnesses should a hearing prove necessary.
[GeneralInterrogatory No. 4: Describe for each interrogatory any additional research or wwk, if any, that IP plans to do that will affect the answer.]
ANSWER: Unless otherwise noted, or unless new infwmation indicates the need for further investigation, Illinois Power does not plan to conduct further research or wwk which may affect the answer relative to a partie-ular interrogatory.
B. Contention 2
[5.
With respect to the answer given toInterrogatory 3.d in IP's Supplemental Response to Illinois' First Set of Interrogatories, speelfically under the heading of "Baldwin Associates Quality Control Employees",
please state:
a) whether, toIP's knowle%e, 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 fw CPS-1, and if so state the name and most cunent ad&ess of each such employee.
b) whether any of the 3 discharges based upon "insubwdination" involved w resulted from expressed criticisms, or refusal to follow speci-fled procedures on professional grounds, of the QC program fw CPS-1, and if so state the name and most current ad&ess of each such employee.
c) whether any of the 15 employees transferred to other BA departments were moved as a result of criticism, dissatisfaction re disagree-ment with the QC program for CPaF., and if so state the name and most current address of each such employee.]
ANSWER: To the best of Illinois Power's knowle%e, none.
[6.
With respect to the answer given in Interrogatory 3.d in IP's Supplemental Response to Illinois' First Set of Interrogatories, specifically under the heading of " Illinois Power Quality Assurance Employees",
please state whether, to IP's knowledge, any of the f armer employees included in the categwy " resigned-to accept new position", did so as a result of dissatis-faction or disagreement with the QC program for CPS-1, and if so state the name and most current address of each such employee.]
ANSWER: To the best of Illinois Power's knowledge, none.
[ 7.
With respect to the answer given toInterrogatory 3.d in IP's Supplemental Response to Illinois' First Set of Interrcgatories, 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 w terminated and the number of QA em-ployees transferred or terminated shown in Exhibit K, attached in answer to Interrogatory 3 in IP's initial Answers to Illinois' First Set of Interrogatories.]
ANSWER: The information presented in Exhibit K was correct. The answer to Interrogatory No. 3.d should have read as follows: -
D11nois Power Quality Assurance Employees Reason for Termination Number of Employees Resigned - to accept new position 9
Transferred - to another IPC Dept.
7 Resigned - Husband transferred 1
Resigned - return to school 1
C. Contention 5
[ 8.
Sthte whether IP has made the minor modifications at CPS-1 that render SCRAM reliability (/ reactor ficient to meet the NRC Staff safety goal of 10-year.]
ANSWER: The original design of the CPS-Unit 1 scram system has been modified to increase reliability. The probability of occurrence of an ATWS
-6 event at CPS Unit 1 is of the order of magnitude of 10 per 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 modifi-cation (s).]
ANSWER: See answer toInterrogatory No. 8. 1-...
ILLINOIS POWER COMPANY
- j 2
K4(
%g Leonard J. KogK ' )
Vice President Peter V. Fazio, Jr.
Sheldon A. ZabeL William Van Sttd, eren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 DATED: February 19, 1982 i
I i
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STATE OF ILLINOIS
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SS COUNTY OF MACON
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Leonard J. Koch, being duly sworn, deposes and says that he is Vice President of Illinois Power Company, one of the Applicants in this proceeding; that he has read the foreg.yag Response of Blinois Power to the State of Blinois' Additional Second Round Interrogatories to Appll-cants, and that the same are true and correct to the best of his knowledge, information, and belief.
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' Leonard J. Kf6fi Vice Presiddht SUBSCRIBED and SgORN to before me this 19 day of ';6A2,,o 77,1982.
, / a)h.
rh,j Notary Public
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