ML20042A265
| ML20042A265 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/16/1982 |
| From: | Koch L ILLINOIS POWER CO. |
| To: | ILLINOIS, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8203230262 | |
| Download: ML20042A265 (39) | |
Text
4 f 8 UNITED STATES OF AMERICA NUCLEAR RSGULATORY COMMISSION IN THE MATTER OF )
ILLINOIS POWER COMPANY, )
SOYLAND POWER COOPERATIVE , INC.)
and WESTERN ILLINOIS POWER ) Docket No. 50-461 OL COOPE RATIVE , INC. )
)
(Operating License for Clinton )
Power Station, Unit 1) )
SUPPLEMENTAL RESPONSE OF ILLINOIS POWER TO THE STATE OF ILLINOIS '
SECOND SET OF INTERROGATORIES Illinois Power Company (" Illinois Power" or "the Company"), on behalf of itself, Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. ("Appli-cants"), pursuant to the Order of the Atomic Safety and Licensing Board of February 16, 1982, hereby supplements its response to the State of Illinois' ("the State") Second Set of Interrogatories as follows:
[ General Interrogatory No. 1: Identify all persons who have assisted in any way in the preparation of each answer to each inter-rogatory below and describe the substance of each person's assistance.]
ANSWER: This general interrogatory is separately answered herein for each contention.
[ General Interrogatory No. 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.]
9 03 8203230262 820316 %
ANSWER: This general interrogatory is separately answered herein for each specific interrogatory to which it applies.
[ General Interrogatory No. 3: Identify all persons whom IP plans to call to testify as to each contention, and state the qualifi-cations of each person so identified.]
ANSWER: Illinois Power has not yet deterr.ined which persons it will call as witnesses should a hearing prove necessary.
[ General Interrogatory No. 4: Describe for each interrogatory any additional research or work, if any, that IP plans to do that will affect the answer.]
ANSWER: Illinois Power is continuously engaged in monitoring information that may affect the design, construction or operation of the Clinton Power Station. 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.
Contention 2
[ General Interrogatory No. 1: Identify all persons who have assisted in any way in the preparation of each answer to each inter-rogatory below and describe the substance of each person's assistance.]
ANSWER: All information supplied on Contention 2 was pre-pared under the supervision and direction of Allen J. Budnick, Illinois Power Director-Quality Assurance.
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[5. Identify the persons who were, but are no no longer, employed on the inspection staff of Baldwin Associates' (BA) Department of Quality Control (QC). For each person so i tified state:
(d) the substance of any complaints made by him to IP, BA, or NRC about QA/QC program.]
ANSWER: To the best of Illincis Power's knowledge, there have been no such complaints. The documents used in answer-ing this interrogatory were the Baldwin Associates' personnel files.
[8. Identify those persons who were, but are no longer, employed on the inspection staff of BA's piping department. For each person so identified state:
(d) the substance of any complaints he made to IP, BA, or NRC about the QA/QC program.]
ANSWER: As noted in the original Answer to Interrogatory No. 8, inspection activities at Clinton Power Station are performed by Baldwin Associates Quality Control Department.
Baldwin Associates Piping Department does not have an inspec-tion staff. See the Answer to Interrogatory No. 5 (d) .
[9. Identify those persons who are now employed on the inspection staff of BA's Piping Depart-ment. For each person so identified state:
(c) the substance of any complaints he had made to IP, BA, or NRC about the QA/QC program.]
ANSWER: As noted in the original Answer to Interrogatory No. 9, Baldwin Associates' Piping Department does not have an inspection staff. Inspection of activities relating to
piping at Clinton Power Station is performed by Baldwin Asso-ciates' Quality Contro) employees responsible for mechanical inspections. To the best of Illinois Power's knowledge, there have been no such complaints from any of these employees.
The documents used in answering this interrogatory were the Baldwin Associates' personnel files.
[10. Identify each person who is now employed in the BA small bore design group. For each person so identified state:
(a) his duties and responsibilities; (b) his qualifications for the position; and]
ANSWER: See Exhibit A, attached hereto.
[ (c) the substance of any complaints he had made to IP, BA or NRC about the QA/QC program.]
ANSWER: To the best of Illinois Power's knowledge, there have been no such complaints. The documents used in answer-ing this interrogatory were the Baldwin Associates' personnel files.
[11. Describe the current QA system for the docu-mentation of procurement and specification requirements.]
ANSWER: See the original Answer to Interrogatory No. 11 for the general description of the current Quality Assurance system for the documentation of procurement and specification requirements.
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[(a) Describe the changes if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05.]
ANSWER: The following changes have been made since the issuance of IE Inspection Report 50-461/81-05:
- 1) Baldwin Associates Procedures have been revised to clarify the system description and process.
- 2) For procurement where contracts are still open, Engineering Change Notices (ECN 's ) will be issued where necessary. The ECN's will modify the documentation handling requirements to achieve consistency with the project documentation system.
- 3) For procurement where final payment has been made, Illinois Power and Baldwin Associates are developing documentation checklists and obtaining further documentation where necessary.
- 4) Specifications for future procurement will be consistent with Clinton Power Station receiving practices l
to preclude the type of documentation control problems reported by the NRC.
[(b) Identify all those persons who are responsible for the changes, if any, that IP had made in this system.]
ANSWER: The persons responsible are Julius D. Geier, Illinois Power Manager Nuclear Station Engineering Department, J. E.
I Findley, Baldwin Associates Manager of Quality and Technical Services, and H. E. Swif t, Baldwin Associates Project Engineer.
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[(c) Identify all those persons who are responsible for the management, operation and implementation of this system.]
ANSWER: The persons responsible are Julius D. Geier, Illinois Power Manager Nuclear Station Engineering Department, Allen J. Budnick, Illinois Power Director-Quality Assurance, J. C. Findley, Baldwin Associates Manager of Quality and Technical Services, and H. E. Swift, Baldwin Associates Project Engineer.
[12. Describe the current system of using travelers to detail installation and inspection require-ments.]
ANSWER: See the original Answer to Interrogatory No. 12 for the general description of the current system of using travelers to detail installation and inspection requirements.
[(a) Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/61-05.]
ANSWE R: The following changes have been made since the issuance of IE Inspection Report 50-461/81-05:
- 1) A new procedure, BAP 3.2.5, covering the installation and inspection of piping component supports and hangers has been written, reviewed, approved, and issued for implementation. This procedure provides specific instal-i lation and inspection instructions and criteria. Quality Control Instructions, including checklists, have been revised to reilect the new installation and inspection requirements.
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- 2) Construction supervisors are now required to sign travelers to signify that installation is in accord-ance with requirements.
- 3) Changes have been made in other discipline traveler systems to clarify the system description and process.
[(b) Identify all those persons who are responsible for the changes, if any,that IP has made in this system.]
ANSWER: The persons responsible are Edward E. Connon, Illinois Power Director-Compliance, and J. E. Findley, Baldwin Associates Manager of Quality and Technical Services.
(c) Identify all those persons who are responsible for the management, operation and implementation of this system.]
ANSWER: The persons responsible are James O. McHood, Illinois Power Vice President, Allen J. Budnick, Illinois Power Director-Quality Assurance, William Harrington, Baldwin Associates Vice President-Nuclear Construction, and J. E. Findley, Baldwin Associates Manager of Quality and Technical Services.
[13. State the basis for IP's conclusion that the requirement that vendors acquire written authorization from IP, prior to shipment, to substitute a certificate of compliance for missing documentation is unrealistic.]
ANSWER: A certificate of compliance is not required for engineering and design documentation available at time of shipment. Manufacturing documentation must be shipped with the equipment or a certificate of compliance must be supplied. Substitution of a certificate of compliance for manufacturing documentation requires prior written authorization from Illinois Power. The documents used in answering this interrogatory were:
- 1. IP letter U-0244, Q37-81 (06-11) dated June 11, 1981 from L. J. Koch, Vice President-IP to James G. Kepplet, Director, Region III NRC in response to NRC-IE Report 50-461/81-05.
- 2. IP letter U-0263, Q37-81 (07-17) dated July 17, 1981 from L. J. Koch, Vice President-IP to James G. Keppler, Director Region II NRC, Supplemental response to NRC-IE Report 50-461/81-05.
[14. Describe the QA system of document account-ability and control that IP believes assures compliance with requirements for issuance of materials and equipment for installation or use at CPS-1.]
ANSWER: The system of document accountability and control which assures compliance with requirements for issuance of materials and equipment for installation or use at Clinton Power Station is described in Baldwin Associates Project Procedures, BAP 2.3 and BAP 2.20.
[15. State what IP believes is the purpose of Procedures BA 2.20 and BA 2.3, and describe what procedures IP uses to meet this purpose.]
ANSWER: The purpose of BAP 2.3, " Receiving and Issuance",
is to ident.fy responsibilities and provide instruction for accomplishing activities associated with the receiving and issuance of permanent plant items and materials at Clinton Power Station.
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The purpose of BAP 2.20, " Final Documentation I Review", is to define the responsibilities and steps taken for compilation, review and verification, and accountability of vendor manufacturing and engineering documentation and completed Baldwin Associates installation documentation.
The above noted procedures also cover interface responsibilities and requirements of the Architect Engineer (Sargent and Lundy) , the Nuclear Steam Supply System (General Electric) and Illinois Power relative to the activities of receiving, issuance, and documentation review for permanent plant items and materials used in construction of the Clinton Power Station.
[16. Describe the system IP is using to inspect safety related pipe hangers.]
ANSWER: The system used to inspect safety related pipe hangers is described in BAP 3.2.5, Rev. 2 and QCI 300, Rev. 2.
[ (a) Describe the changes, if any, that IP has made in this system since the issu-ance of IE Inspection 50-461/81-05.]
ANSWER: The following changes have been made since the issuance of IE Inspection Report 50-461/81-05:
- 1) Procedures have been revised to provide specific installation and inspection instructions and criteria.
- 2) Quality Control inspection checklists have been revised to reflect new installation and inspection requirements.
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- 3) Construction supervisors are now required to sign travelers to signify that installation is in accordance with requirements.
[(b) State the average maximum time span between hangar installaticz and QC inspection.]
ANSWER: Inspections are normally performed the same day or next working day after receipt of notice that construction has been completed.
[(c) State whether this system requires documentation of who installed the hangar components and when intcallation was completed.]
ANSWER: Yes.
[(d) Identify all those persons who were responsible for the changes, if any, that IP has made in this system.]
ANSWER: The persons responsible are J. E. Findley, Baldwin Associates Manager of Quality and Technical Services, and T. Selva, Baldwin Associates Former Manager of Quality and Technical Services.
[(e) Identify all those persons who are responsible for the management, operation and implementation of this system.]
ANSWER: The persons responsible are William C. Gerstner, Illinois Power Executive Vice President, Allen J. Budnick, Illinois Power Director-Quality Assurance, and J. E. Findley, Baldwin Associates Manager of Quality and Technical Services.
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[18. Describe the record and document control system that IP uses to correlate IP audit findings to the necessary corrective actions.]
ANSWER: See the original Answer to Interrogatory No. 18 for the general description of the record and document control system.
[(a) Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05.]
ANSWER: The following changes have been made since the issuance of IE Inspection Report 50-461/81-05:
- 1) The Illinois Power Construction Quality Assurance Surveillance Finding File was reviewed. All incomplete records were removed and replaced with complete records.
- 2) A new system of transmitting " closed" sur-veillance findings by Illinois Power Construction Quality Assurance to the Clinton Power Station Document Records Center has been implemented to ensure that the records file is complete and accurate.
[(b) Identify all those persons who are responsible for the changes, if any, that IP had made in this system.
(c) Identify all those persons who are responsible for the management, operation and implementation of this system.]
ANSWER: The person responsible is Allen J. Budnick, Illinois Power Director-Quality Assurance.
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[19. Describe the system that IP uses to control the time taken between the completion and QA/QC inspection of work.
ANSWER: See the original Answer to Interrogatory No. 19 for the general description of this system.
[(a) Describe the changes, if any, that IP has made in this system since the issuance of IE Inspection Report 50-461/81-05.]
ANSWER: See the Answer to Interrogatory No.12(a) .
[(b) Identify all those persons who are responsible for the changes, if any, that IP had made in this system.]
ANSWER: See the Answer to Interrogatory No. 12(b).
[(c) Identify all those persons who are responsible for the management, operation and implementation of this system.]
ANSWER: See the Answer to Interrogatory No. 12 (c) .
[22. Identify all S & L, BA, or GE documents, known to IP, specifically calling into ques-tion the judgment, experience, capability of commitment to quality of IP regarding the construction or proposed operation of CPS-1.]
ANSWER: To the best of Illinois Power's knowledge, none.
[23. State whether IP has any knowledge of any IP, BA or S & L employee resigning his posi-tion or otherwise being terminated on account of disagreement or dissatisfaction with the quality of construction or engineering work, or management decisions or policies relating to the construction or proposed operation of CPS-1 and, if so, identify documents or otherwise provide details per-taining to any such occurrances.]
ANSWER: Illinois Power has knowledge of one such employee.
J. N. Baysden, Illinois Power Supervisor, Station Design,
resigned in March 1978 because of differences with management over the allocation of engineering responsibilities between the office staff and the on-site staff.
[24. State whether IP has any knowledge of any IP, BA or S & L employee lodging a complaint with IP concerning disagreement or dissatis-faction with the quality of construction or engineering work, or decisions or policies relating to the construction or proposed operation of CPS-1, which complaint did not result in the resignation or termination of that employee, and, if so, identify documents or otherwise provide details pertaining to any such occurrances.]
ANSWER: In the day to day course of construction, individual employees may have complained to supervisors concerning the construction or proposed operation of the Clinton Power Station. The supervisors may have made notes or otherwise recorded an individual's concerns and the actions taken in in response. Such notes or other records, if they exist, would be scattered throughout various files in various locations. Illinois Power is presently searching files where such notes or other records may be located. Upon completion of this review, Illinois Power will, if necessary, supplement this response.
As of February 24, 1982, a Quality Report System was implemented at Clinton Power Station. This system provides a means for all Clinton Power Station personnel to inform Illinois Power management of quality problems or concerns which they feel are not adequately addressed t
by other means. Quality Report forms are available at all Quality Control field offices and most field document control centers. Completed forms are deposited in a box outside the Illinois Power Quality Assurance office. The forms are transmitted directly to William C. Gerstner, Illinois Power Executive Vice President, in strictest confi-dence. To date, seven Quality Reports have been submitted.
Contention 3
[ General Interrogatory No. 1: Identify all -
persons who have assisted in any way in the preparation of each answer to each inter-rogatory below and describe the substance of each person's assistance.]
ANSWER: Robert L. McPherron, Illinois Powcr Supervisor-Planning.
[25. State whether IP has done an independent study of the tasks and costs involved in decommissioning CPS-1, and if not, whether IP plans to do so, and when.]
[26. Why is immediate dismantlement the " assumed method" for decommissioning CPS-l?]
[27. State whether IP has studied or commissioned any studies of alternatives to the immediate dismantlement method of decommissioning CPS- and, if so, summarize the results of those studies in terms of the tasks and costs involved.]
ANSWER: The documents used in answering Interrogatory Nos. 25, 26 and 27 were a letter from John B. Gillett of Whitman, Requardt and Associates to Mr. Arthur E. Gray, Illinois Power Company, of July 28, 1981, and NUREG/CR-0130
" Technology, Safety, and Costs of Decommissioning of A Reference Pressurized Water Reactor Power Station."
[34. State the assumed capacity factors for each of the first ten (10) years of operation of CPS-1.]
ANSWER: For each twelve month period, CPS-1 is expected to operate at 60-75% capacity factor. The document used in answering this interrogatory was " Nuclear Unit Operating Experience, 1978 and 1979 Update", EPRI NP-2092 (Electric Power Research Institute, October 1981).
Contention 10
[ General Interrogatory No.1: Identify all persons who have assisted in any way in the preparation of each answer to each inter-rogatory below and describe the substance of each person's assistance.]
ANSWER: The Answers to all interrogatories relating to Contention 10 were prepared under the supervision and direc-tion of Julius D. Geier, Illinois Power Manager-Nuclear Station Engineering Department.
[40. Explain the basis for IP's conclusion that the worst single failure / break type combina-tion is tge HPCS line break of approximately 0.02 feet and the failure of the LPCS diesel generator that powers one LPCS pump and one low-pressure coolant injection (LPCI) pump.]
ANSWER: The worst single failure / break type combination is determined by analyzing the full spectrum of pipe break location, sizes, and postulated single failures. The worst l
single failure / break type combination will be that combina-tion which results in the least amount of margin to the acceptance criteria specified in 10 CFR 50.46. Typically, the combination resulting in the highest peak cladding
temperature (least amount of margin to the 2200 F peak cladding temperature limit) determines the worst single failure / break type combination. A complete description of the Loss of Coolant Accident (LOCA) analysis, assumptions, evaluation models, and typical results for a BWR/6 reactor are presented in Section 6.3.3. of the FSAR. These typical results ,show that the worst single f ailure ' break type com-bination is the failure of the HPCS line break of approxi-2 and the failure of the LPCS diesel gener-mately 0.02 feet ator that powers one LPCS pump and one LPCI pump, with diversion of one of the remaining operable LPCI pumps to containment cooling ten minutes after the pipe break.
[41. Explain the basis for IP's conclusion that the worst single failure / break type combina-tion, referred to above in Interrogatory 40, will yield the highest peak cgadding temperature of approximately 2085 F of all cases affected by LPCI diversion at 10 minutes.]
ANSWER: A typical analysis of all of the cases affected by LPCI diversion at 10 minutes is presented in Section 6.3.3.7.8 of the FSAR. This analysis provides the basis for the determination of the worst single failure / break type combination affected by LPCI diversion. In that analy-sis, it was shown that the worst single failure / break type combination identified in the Answer to Interrogatory N9 40 will yield the highest peak cladding temperature of all cases affected by LPCI diversion. For the HPCS line break, it is conservatively assumed that no flow enters the vessel through the broken line regardless of the break size.
For this case, the failure of the diesel generator associated with LPCS and LPCI is the worst single failure since all credit for core spray cooling is eliminated. The ECCS systems remaining before diversion at ten minutes are two LPCI plus ADS, and after diversion at ten minutes, are one LPCI plus ADS. Because in both cases the reflooding time is based on only subcooled LPCI flow reflooding the vessel, there is a longer reflooding time associated with the diverted case with reduced ECCS flow. The longer reflood-ing time results in a higher peak cladding temperature for the diverted case. All other cases affected by LPCI diversion either have a core spray system available providing core spray cooling, or have more ECC systems available after diversion of the LPCI flow. These other cases will therefore yield lower peak cladding temperatures than the worst combination.
[42. Does a change in the reduction factors for averaging cladding strain affect this con-clusion? Explain what affect a change in this factor will have.]
ANSWER: A change in the reduction factor for averaging cladding strain will not affect the conclusion in the Answer to Interrogatory No. 41. This is because the reduction factors only apply following cladding perforation and no perforations are calculated to occur. Sensitivity studies
on cladding perforation strain performed by General Electric are summarized in the letter identified as Reference 4 in the Answer to Interrogatory No. 46. They show that for cases in which perforations occur the current General Electric procedure of averaging cladding strain produces the most conservative results (i.e. , the highest peak clad-ding temperature).
[43. Does a change in the reduction factor of 2.8 for fuel bundle interior rods affect this conclusion? Explain what af fect a change in this factor will have.]
ANSWER: A change in the reduction factor for fuel bundle interior rods has no effect on the results or conclusion because no perforations are calculated to occur. See the Answer to Interrogatory No. 42 for additional details.
[44. Does a change in the reduction factor of 4.1 for fuel bundle peripheral rods affect this conclusion? Explain what affect a change in this factor will have.]
ANSWER: A change in reduction factors for fuel bundle peripheral rods has no effect on the results or conclusions because no perforations are calculated to occur. See the Answer to Interrogatory No. 42 for additional details.
[45. State the basis for IP's conclusion that the GE model is conservative in comparison to the models described in NUREG 0620 within the range applicable to BWR.
(a) Describe specifically what range is applicable to BWR.
(b) Identify all documents of communication between IP and NRC regarding the GE model.
(c) Identify all documents of communication between IP and GE regarding the GE model.)
ANSWER: The letters identified as References 1 through 4 in the Answer to Interrogatory No. 46 present the results of sensitivity studies performed by General Electric on the cladding swelling and rupture model. These studies show that for the purpose of calculating peak cladding temperature and maximum local oxidation the current General Electric models produce conservative results. The range of conditions which General Electric considers to be applic-able to BWR fuel is for heatup rates of less than 10 F/second and for rupture temperatures above 1700 F.
[46. Describe the additional sensitivity studies GE has agreed with NRC to perform.
(a) State whether these studies were com-pleted by the end of July 1981, and if not, when they are scheduled for completion.
(b) Describe what actions IP plans to take in response to the results of these studies.]
ANSWER: Reference 1 contains the results of sensitivity studies performed by General Electric on the perforat on .
stress versus temperature curve. The results of sensitivity studies performed on the perforation strain model are sum-marized in Reference 4. The last of these studies was completed in October 1981. No additional studies have been requested by the NRC or are planned by General Electric.
These sensitivity studies demonstrate the adequacy of the current General Electric swelling and rupture model for the purpose of calculating peak cladding temperatures and maximum local oxidation. No actions are required in response to the results of these studies. References for the Answer to Interrogatory No. 46 are:
- 1) Letter from R. H. Buchholz (Q3) to L. S. Rubenstein (NRC) " General Electric Fuel Clad Swelling and Rupture Model", May 15, 1981.
- 2) Letter from G. G. Sherwood (GE) to L. S. Rubenstein (NRC ) , " Impact of Large Rupture Strains on BWR LOCA Analysis", August 14, 1981.
- 3) Letter from J. F. Quirk (GE) to L. S. Rubenstein (NRC) ,
" General Electric Analytical Model for calculation of Local Oxidation in LOCA Analysis", September 14, 1981.
- 4) Letter from J. M. Quirk (Qs) to L. S. Rubenstein (NRC)
" General Electric Analytical Model for Calculation of Cladding Rupture Strain and Maximum Local Oxidation in LOCA Analysis", October 19, 1981.
[50. Describe in detail how the operation of the ECCS has been verified for worst-case, anticipated transient without scram condi-tions.
(a) State whether this verification has been achieved by actual, operational tests, and, if not, why not.
(b) Identify all documents used in support of IP's answer.]
ANSWER : The operation of the ECCS is independent of any possible occurrence of an ATWS event. An ATWS event would not affect the design capability of the ECCS.
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[51. Describe the classification of theInautomatic addition, depressurization system (ADS).
state whether:
(a) The ADS is safety-grade;]
ANSWER: Yes.
[(b) The ADS is classified as important to safety; and)
ANSWE R: Yes.
[(c) The relief valves and their controls and instruments, which are used in conjunction with ADS, are classified as safety-grade.]
ANSWE R: Yes.
Contention 12 i
[ General Interrogatory No. 1: Identify all persons who have assisted in any way in the preparation of each answer to each interrogatory below and describe the sub-stance of each person's assistance.]
ANSWER: The answer to Interrogatory No. 53 was prepared under the supervision of Larry S. Brodsky, Illinois Power Assistant Plant Manager of the Clinton Power Station.
[53. Describe the assumptions IP made and the calculations IP performed to determine that the dose rates in the accessible areas of the drywell, in the vicinity of the refueling pool bellows, will not exceed 16 mrem /hr.]
ANSWE R: The assumptions made were the same as those listed in the original response to Interrogatory No. 52. The calculations were performed using the shielding computer code QAD. The dose value of 16 mrem /hr. presently reported in the FSAR should read 160 mrem /hr. The area of the drywell l
affected by this dose rate is very narrow, because of the ;
i geometry of the bellows and shielding. In the highly un-j likely event that a person occupies this narrow area through
( the entire refueling operation, it is estimated that he will be exposed to a total dose of less than 100 mrem.
[(a) Identify all documents IP used to answer i this interrogatory.]
1 ANSWER: The document used was the QAD shielding computer l
4 Code.
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l ILLINOIS POWER COMPANY By:
i V ~ Leonard Jf Koc.1 l Vice Pre (ident !
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Sheldon A. Zabel .
William Van Susteren
.; charles D. Fox IV i SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive
- Chicago, Illinois 60606 (317) 876-1000 1
) Dated: March 16, 1982 i
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STATE OF ILLINOIS )
) SS COUNTY OF MRCON )
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 foregoing Supplemental Response of Illinois Power to the State of Illinois' Second Set of Interrogatories, and that the same are true and correct to the best of his knowledge, information, and belief.
y' Lbonard Jj/ Koch Vice Prearident SUBSCRIBED and SWORN to before me this /g Yh day of % s w tu ,
1982.
6 < ~e w .a n du 7-b +> d
Notary Public
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EXHIBIT A
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Exhibit A Baldwin Associates Small Bore Design Group Employees DUTIES /
NAME & ADDRESS POSITICN RESPONSIBILITIES CATIOE R. L. Neeb Sr. Piping Engineer Handling, distribution Eight years experience P.O. Box 306 and clarification of in power plant piping Clinton, Ill 61727 piping and mechanical construction experience.
design drawings and Additional five years specifications; pro- power plant design viding infornation experience.
and advice on problems of a technical or BS Degree - Mechanical engineering nature; Adnunistration and maintaining oon-trols over the pro-gress of the work.
Supervises the acti-vities of piping engineers, technicians, and clerks within Piping group.
M. N. Engineer Piping Engineer Responsible f3r reviewing Ten years experience P. O. Box 306 all instrunen 2 tion related in power plant con-Clinton, Ill 61727 drawings generated by BA struction in mechanical /
piping drafting department. piping systems.
Supervises technical assistants and draftsmen. BS Degree - Mthical Engineering Master - Nuclear Engineering Registered P.E.
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D(EIES/
NAME & ADDRESS POSITION RESPONSIBILITIES QUALIFICATIONS J. C. Invinsky Piping Drafting Responsible for preparation 'I%enty-four years P. O. Box 306 Supervisor and checking of all piping experience in design Clinton, Ill 61727 drawings produced at Clinton and drafting piping Power Station by BA. Super- systans, includirxJ vises piping draftsmen 14 yesrs nuclear power pir.nt experience.
Five years post high school education in mechanical engineering math and Huac.
M. Tiffin-Alsup Hanger Coordinator Assigns langers which are Eight years experience P. O. Box 306 to be detailed to drafts- in drafting and design Clinton, Ill 61727 men. Checks hanger drawings including 4 1/2 years which are prepared by drafts- experience at Clinton.
men. Supervises checkers design draftsmen, detail BS Degree - Architec-draftsmen and junior tural studies.
draftsmen. Tracks the progress of 2" and under hanger program.
C. Bowles Instranentation Checks and reviews instru- Two years experience P. O. Box 306 Hanger Gecker mentation tubing hanger in drafting.
Clinton, Ill 61727 drawings prepared by design draftsmen, detail Two years college.
draftsmen, and junior draftsmen.
R. Jackson Piping Designer Prepares instrumentation BS Degree - Architecture P. O. Box 306 (D-4) tubing isanetrics utilizing 10 months at Clinton Clinton, Ill 61727 Instrumentation S&L "ic" series M05 & M10 job site.
Group drawings.
DUTIES /
NAME & ADDRESS IOSITION RESPOtEIBILITIES QUALIFICATICts A. Saraiya Piping drafting Checks and reviews 2" and BS Mechanical P. O. Box 306 Hanger checker under hanger drawings engineering.
Clinton, Ill 61727 prepared by design BS Autmobile draftsmen, detail drafts- engineering men, and junior drafts-men. 13 years college progessor in mechanical engineering. 20 months power plant experience.
S. Jariwala Piping drafting Checks and reviews 2" and BS - Civil Engineering P. O. Box 306 Hanger checker under hanger drawings Clinton, Ill 61727 prepared by design 10 years experience draftsnen, detail drafts- in design.
- men, and junior drafts- 3 1/2 years nuclear men. power plant experience including 2 years at Clinton.
G. R. Smith Piping drafting, Assigns piping work to be Associate Degree -
P. O. Box 306 2" and under drawn in ismetric form by Mechanical Engineering Clinton, Ill 61727 piping coordinator draftsmen, checks drawings prepared by draftsnen. 9 years experience Supervises design drafts- in construction men, detail draftsmen, piping engineering junior draftsnen, and including 5 years checkers. nuclear power plant experience.
J. R. Rice Instrunentation Assign instre.?tation BS - Architecture P. O. Box 306 Tubing tubing work to be insmetrically Clinton, Ill 61727 Coordinator drawn by draftsmen. Checks 2 1/2 years at Clinton drawings prepared by drafts- job site.
men. Supervises checkers, design draftsmen, detail draftsmen and junior draftsmen. Tracks progress of instrunentation tubing ismetric program.
DUTIES /
NAME & ADDRESS POSITION RESPONSIBILITIES QUALIFICATIONS
. . . Checks and review 2" 6 3nus college
." O x 306 " and under isaneMcs & awn Mucadon.
W design & af e ,
Clinton' Ill 61727 checker detail draftsmen, and 3 1/2 years at junior draftsmens. Clinton job site.
D. Reynolds Piping drafting, Assigns piping work to 1 year college P. O. Box 306 piping checker be drawn into isometric Clinton, Ill 61727 2" and under form by draftanen. 01ecks 20 months experience '
and large bore drawings prepared by at Clinton job site.
revisions draftsnen. Supervises detail draftsmen and junior draftsmen. Monitors large bore piping revisions.
S. Isach Checker decks and reviews 2 years experiax:e in P. O. Box 306 Instrunentation insttunentation tubing construction plus Clinton, Ill 61727 tubing isometrics prepared by design 2 1/2 years at draftsmen, detail drafts- Clinton job site, men, and junior draftsmen.
R. Rawlins 2" and under Checks and review 2" l years experience P. O. Box 306 checker and under isonetrics drawn in construction.
Clinton, Ill 61727 by design draftsmen, 3 5 ears experience at detail draftsmen, and Clinton job site, junior draftsmen.
W. Kangneier Piping designer Prepares instrunentation 3 years College ,
P. O. Box 306 Instrunentation tubing isometrics utilizing S&L "K" series drawings, 15 years experience Clinton, Ill 61727 tubing group M05 and M10 drawings. in drafting and design including 2 1/2 years experience at Clinton job site.
l
DUTIES /
NME & ADDRESS POSITION RESPOEIB 1ITIES QUALIFICATIONS D. Parker Checker Instrumen- Checks and reviews 2 years experience P. O. Box 306 tation Group instrunentation tubing in drafting and design Clinton, Ill 61727 ismetrics prepared by at nuclear power plant.
design draftsmen, detail draftsmen, and junior draftsmen.
S. Michelassi Piping detail Prepares instr mentation 2 years college P. O. Box 306 draftsmen tubing ismetrics utilizing Clinton, Ill 61727 Instrunentation S&L "K" series, M05 and 41 years drafting tubing group M10 drawings. and design experience.
K. Mandrell Piping Detail Prepare ismetric drawings 1 year college P. O. Box 306 Draftsmen (Piping of 2" and snaller, utilizing drafting Clinton, Ill 61727 Group), D-3 S&L MOS and M07 cmposite drawings. Determine hanger 15 months at Clinton locations and configurations frun S&L and BA criteria.
Prepare spool drawings of floor and rcof drain piping and revision thereto.
H. Aparviz Piping Detail Prepare ismetric drawings 2 years college P. O. Box 306 Draftsmen (Piping of 2" and smaller, utilizing education. 1 year Clinton, Ill 61727 Group) , D-3 S&L M05 and M07 cmposite technical school drawings. Determine hanger drafting.
locations and configurations frm S&L and BA criteria. 1 year experience at Prepare spool drawings Clinton.
of floor and roof drain piping and revision thereto.
DUTIES /
NME & ADDRESS POSITIOti RESPONSIBILITIES QUALIFICATIONS D. Turley Piping Detail Prepare iscmetric drawings 1 year college P. O. Box 306 Draftsmen (Piping of 2" and analler, utilizing education. 4 1/2 Clinton, Ill 61727 Group) , D-3 S&L M05 and M07 cmposite years drafting drawings. Determine experience.
hanger locations and configura-tions from S&L and BA criteria.
Prepare spool drawings of floor and roof drain piping and revision thereto.
D. Kraaner Piping Detail Prepare isonetric drawings 2 years technical P. O. Box 306 Draftsnen (Piping of 2" and analler, utilizing school drafting Clinton, Ill 61727 Group) , D-3 S&L M05 and M07 ocmposite and structural drawings. Determine tech, hanger locations and configura-tions from S&L and BA criteria.
Prepare spool drawings of floor and roof drain piping and revision thereto.
R. Picchietti Piping draftsman Prepares instrumentation 2 years college P. O. Box 306 (D-3) Instrunenta- tubing ismetrics utilizing education. 2 years Clinton, Ill 61727 tion Group S&L "K" series, M05 and M10 technical school, drawings. drafting and electrical engineering. 3 1/2 drafting expu-ience.
N. Fecurka Piping detail Prepare instrirentation 2 years technical P. O. Box 306 draftsnen, D-3 tubing iscmetrics utilizing school. Instrunentation Clinton, Ill 61727 Instrumentation S&L "K" series, MOS and M10 and process control.
Group drawings.
DUTIES /
NME & ADDRESS POSITION RESPONSIBILITIES OlmLIFICATICES J. Smith Piping detail Prepare instrmentation 2 years technical P. O. Box 306 draftsmen, D-3 tubing ismetrics utilizing school instrtrnental ion Clinton, Ill 61727 Instrumentation S&L "K" series, M05 and M10 and process control Group drawings.
U.S. Army Helicopter mechanic ocurse.
G. W. Smith Piping detail Prepare instrunentation 2 years technical P. O. Box 306 draftsmen, D-3 tubing ismetrics utilizing school instrumentation Clinton, Ill 61727 Instrunentation S&L "K" series, M05 and M10 and process control.
Group drawings.
L. Carr Junior Draftsnen Incorporate revisions and 9 years design P. O. Box 306 D-2 transfer revisions frm experience Clinton, Ill 61727 check prints to original drawings. Prepare standard detail sheets.
K. Petyjohn Junior Draftsnen Incorporate revisions and 1 year college P. O. Box 306 D-2 transfer revisions frm education. 2 3 ears Clinton, Ill 61727 check prints to original drafting experience.
drawings. Prepare standard detail sheets.
B. Pike Junior Draftsmen Incorporate revisions and 1 year technical D -2 transfer revisions frm schooling. 10 years check prints to original drafting experience.
drawings. Prepare standard detail sheets.
J. Porter Junior Draftsmen Incorporate revisions and 6 years drafting P. O. Box 306 D-2 transfer revisions frm experience. Associates Clinton, Ill 61727 check prints to original degree in applicxl drawings. Prepare sciences in drafting standard detail sheets. technology.
DUTIES /
tWE & ADDRESS POSITION RESPONSIBILITIES Qw\LIFICATICNS S. Coleman Piping Detail Prepare detail drawings of 2 years technical P. O. Box 306 Draftsmen (Instrumen- hangers utilizing S&L or BA school instrtrnentation Clinton, Ill 61727 tation IIanger Group) standards. Prepare sketches and process control.
D-3 cf required hanger configura-tions. Determine hanger locations utilizing S&L and BA criteria.
W. Diller Piping detail General revision work, 13 years technical P. O. Box 306 draftsnan, 2" chart preparation, title illustrator Clinton, Ill 61727 and under group block preparation, etc.
B. Kingston Piping detail Prepare detail drawings of 24 years drafting P. O. Box 306 draftsman, 2" 2" and under piping hangers experience including Clinton, Ill 61727 and under group utilizing S&L or BA standards. 3 years at Clinton.
Prepare sketches of required hanger configurations.
Determine hanger locations utilizing S&L and BA criteria.
R. Masterson Piping detail Prepare detail drawings of 1 1/2 years college P. O. Box 306 draftsman, 2" 2" and under piping hangers education. 2 years Clinton, Ill 61727 and under group utilizing S&L or BA standards, technical scirol Prepare sketches of required architectural design hanger configurations. drafting.
Determine hanger locations utilizing S&L and BA criteria.
T. Saffaripour Piping detail Prepare instrumentation Technical Civil /
P. O. Box draftsman tubing isanetrics utilizing Structural and Clinton, Ill 61727 Instrumentation S&L "K" series, M05 and drafting degrees Group M10 drawings.
15 years drafting experience plus 1 year at Clinton.
DUTIES /
!WE POSITIOi RESPONSIBILITIES O(RLIFICATIO S J. Stober Piping Designer Prepares instrunentation 17 years drafting Instrtmentation tubing isometrics utilizing experience SE drawsings.
T. Brewer Piping Designer Prepares instrumentation 3 1/2 years drafting Instrumentation tubing iscmetrics utilizing experience S E drawings.
J. West Checker - Checks and reviews 3 1/2 years Instrumentation instrumentation tubing experience iscmetrics.
T. Escalante Piping Designer Prepares detail drawings 15 years drafting /
Instrumentation of instrumentation tubing design e. w ience Hanger hangers utilizing S E standards.
E. Apolinar Piping Designer Prepares instnnentation BS - Mechanical Engr.
Instrunentation tubing im m trics utilizing BS - Arch. Tecture E E drawiays. 21 years construction /
design experience P. Ellison Piping Designer Prepares instrumentation 2 years college Instrunentation tubing iscmetrics utilizing 2 years drafting SE drawings. experience O
9
LXJfIES/
NAE & ADDRESS POSITION RESPONSIBILITIES QUALIFICATIONS D. Haworth Piping Designer Prepares instrmentation 2 years college Instrmentation tubing isometrics utilizirxJ 3 years nuclear S&L drawings. drafting experience T. Taylor Piping Designer Prepares instrmentation 4 1/2 years experience Instrmentation tubing ismetrics utilizing S&L drawings.
W. Wilson Piping Designer Prepares instrmentation 1 year college Instrunentation tubing ismetrics utilizing 15 years drafting S&L drawings. experience J. Torio Piping Designer Prepares instr mentation BS - Civil Engineer Instrmentation tubing ismetrics utilizing BS - Sanitary Engineer S&L drawings. E - Sanitary Engineer 21 years construction /
design experience K. White Instrumentation Prepares detail drawings 6 years design /
Hanger Group of instrmentation tubing drafting experience utilizing S&L standards.
G. Blackburn Piping Designer Prepares iscmetric drawings 8 years drafting 2" and under of 2" and under piping experience utilizing S&L drawings.
Determines hanger locations frm S&L criteria.
e CERTIFICATE OF SERVICE I hereby certify that the original of the foregoing document was served upon the following:
Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 and that three conformed copies of the foregoing document were filed with the following:
, Secretary of the Commission United States Nuclear Regulatory Ccamission 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 Jan L. Kodner Tutt and Kodner 173 W. Madison Street Suite 1004 Chicago, Illinois 60602
. . >o 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 Mail, postage prepaid, on March 16, 1982.
YL- D . M One of the Attorneys :for Applicants t Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicrgo, Illinois 60606 (312) 876-1000 I
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UNITED STATES OF AMERICA Q S NUCLEAR REGULATORY COMMISSION:
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IN THE MATTER OF ) M A,. $ ,fIOS2s ILLINOIS POWER COMPANY, SOYLAND POWER COOPERATIVE, INC.
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, ~"2"- sgy}g j and WESTERN ILLINOIS POWER )
COOPERATIVE, INC. Docket No. 50-4 ' OL,. b'
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~(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 l Jan L. Kodner Tutt and Kodner 173 W. Madison Street Suite 1004 Chicago, Illinois 60602 k) 5b()3
/ /
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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 PLEASE TAKE NOTICE that I have today served upon Philip L. Willman, Assistant Attorney General, Environmental Control Division, 188 West Randolph Street, Suite 2315, Chicago, Illinois 60610, and have filed with the Secretary of the United States Nuclear Regulatory Commission SUPPLEMENTAL RESPONSE OF ILLINOIS POWER TO THE STATE OF ILLINOIS' SECOND SET OF INTERROGATORIES in the above-captioned matter. A copy of this document is attached hereto and hereby served upon you.
YL Cl) J Y One of the Attorneys for Applicante Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower i 233 South Wacker Drive 60606 Chicago, Illinois (312) 876-1000 Dated: March 16, 1982 i
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