ML20052E580

Motion to Allow Discovery on Events Re Prairie Alliance Contention 2 That Have Been Reported or Occurred Since 811111 Cutoff of Second Round Discovery Requests.Addl Problems W/Qa/Qc Plan Discovered.Certificate of Svc Encl

ML20052E580
Person / Time
Site:	Clinton
Issue date:	04/29/1982
From:	Willman P ILLINOIS, STATE OF
To:	NRC COMMISSION (OCM)
References
ISSUANCES-OL, NUDOCS 8205110246
Download: ML20052E580 (9)

Text

s NTO UNITED STATES OF AMERICA N ~3 P ? ~ j NUCLEAR REGULATORY COMMISSION IN THE MATTER OF ILLINOIS )

POWER COMPANY, SOYLAND POWER )

COOPERATIVE, INC., and. )

WESTERN ILLINOIS POWER CO- ) Docket No.50-46L G OPERATIVE, INC. ) ., '? I

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, PRAIRIE ALLIANCE CONTENTION NO.\' Ch,@n"@"

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The State of Illinois (Illinois) by TYRONE C. ,

Attorney General of the State of Illinois, pursuant to Section 2.730 of the NRC Rules of Practice & Procedure, hereby moves the presiding officer to allow discovery in this proceeding on events relating to Prairie Alliance (PA) Contention No. 2 that either have been reported or have occurred since November 11, 1981, the date for filing second round discovery requests. The reasons for this motion are as follows:

1. Further discovery is necessary for a proper decision on PA Contention No. 2. Without extended discovery on this contention Illinois will not be able ta adequately ascertain facts, refine its position, and prepare for hearing. PA Contention No. 2 concerns various problems with the Quality Assurance (QA)/

Quality Control (QC) program at the Clinton plant. Pursuant p503 s

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8205110246 820429 PDR ADOCK 05000461 G PDR

to the discovery schedule ordered by the Board, Illinois has propounded interrogatories and requestad documents on same of l these. It has not, however, pursued discovery on activities that either were reported or have occurred since November 11, 1981, which is the cut-off date for second round discovery requests.

Since November 11, 1981 additional problems with the Clinton plant QA/QC plan have been uncovered. Some have been reported by the NRC. Exhibits 1-3, which are attached and incorporated by reference, provide some examples of QA/QC problems, documented by the NRC in Inspection & Enforcement (I&E) Reports, that have occurred since November 11, 1981. Others have not yet been reported. For example, I&E Report No. 81-15, which apparently details a June 1981 investigation by the NRC of over twenty-two alleged QA/QC violations, is not yet available to the public because it is still under NRC interval review, almost a year after the investigation began. And, since January 19, 1982 the Applicants have stopped indefinitely all construction work on electrical cable trays at the Clinton plant. Little

information is publicly available on the reasons for this "stop work" order, although it presumably has some relation to the QA/QC program at the Clinton plant. These reported and 4 unreported QA/QC problems add to the factual bases to PA Contention i

No. 2. Illinois should not be foreclosed from pursuing relevant

, discovery on these problems.

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2. The second round of discovery on PA Contention No. 2 has been delayed and is incomplete. Illinois did not receive answers to most of its second round discovery requests until several months after the date responses were due. On March 16, 1982 the Applicants answered Illinois' second round interrogatories, pursuant to the Board's oral order of February 16, 1982 granting Illinois' motion to compel. And, on April 13, 1982 the Applicants produced most of the documents identified in those interrogatory answers. In addition to these delays there are several important matters left unresolved from the second rouni of discovery. On March 31, 1982 Illinois filed another motion to compel the production of certain documents requested in the second round.

And, on April 22, 1982 the Applicants filed a motion for a pro-tective order to prevent discovery of certain documents the Applicants refused to produce on April 13, 1982. Thus, the second round of discovery remains incomplete until the issues contained in these motions are settled.

3. To allow discovery on PA Contention No. 2 will in no way prejudice the Applicants' position in this proceeding. This request will not cause a delay in the anticipated fuel lead date.

On April 15, 1982 the Applicants announced at an Illinois Power Company shareholders' meeting that the fuel load date has been moved to January 1984, more than a year's delay from the most recently estimated date. Furthermore, as stated previously, the i

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Clinton plant is still subject to an indefinite stop work order, which will certainly further delay completion of construction.

The Applicants cannot claim, therefore, that the discovery request in this motion will delay issuance of an operating license for the Clinton plant, when the date for loading fuel has slipped so much.

4. The information that Illinois intends to seek is relevant to PA Contention No. 2. The discovery requests will be based on specific activities brought to light since the close of the second round of discovery. These activities are related to the allegation in Contention No. 2 that incidents reported in NRC I&E Reports raise questions as to the Applicants' " management technical capabilities to operate, backfit, and permanently shut down the [Clinton plant] in compliance with regulatory requirements."

5. The Applicants have asked for a cut-off date of May 3, 1982 for all discovery in these proceedings in their answer to Illinois' supplemental motion to compel. Illinois objects to the Applicants' request for the reasons set forth above.

WHEREFORE, Illinois moves that the Board allow discovery on events related to PA Contention No. 2 that have occurred

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1 or have been reported since November 11, 1981, the date for 1

i filing second round discovery requests.

Respectfully submitted, TYRONE C. FAHNER Attorney General State of Illinois BY: r "

PHILIP L{ WILLMAN Assistant Attorney General i

Environmental Control Division 188 W. Randolph Street - Suite 2315 Chicago, Illinois 60601 (312) 793-2491 1

OF COUNSEL j REED NEUMAN Assistant Attorney General 500 South Second Street Springfield, Illinois 62701

! DATED: April 29, 1982.

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1 EXHIBITS

1. Excerpts from I & E Report No. 81-24, dated November 12, j 1981.  ;

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! 2. Excerpts from I & E Report No. 81-27,-dated November 24, i 1981.

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3. Excerpts from I & E Report No. 81-25, dated December 9, 1981.

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.r REGION lil C / 799 ROOSEVELT ROAD g GLEN ELLYN, ILLINOIS 60137 November 12, 1981 Docket No. 50-461 Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President 500 South 27th Street Decatur, IL 62525 Gentlemen:

This refers to the routine safety inspection conducted by Mr. H. H. Livermore of this office on September 1-30, 1981, of activities at the Clinton_ Power

. Station, Unit 1, authorized by NRC Construction Permit No. CPPR-137 and to the discussion of our findings with Mr. M. C. Hollon and others of your staff at the conclusion of the inspection, and to the October 27, 1981 tele-phone conversation between Mr. R. C. Knop of this office with Mr. L. C. Koch of your staff in regard to the inspection findings.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in the enclosed Appendix A.

A written response, submitted under oath or affirmation is required.

With regard to Item No. 1 of Appendix A, we are concerned about the timeli-ness and effectiveness of your corrective action on this recurring item. In your response we request that you provide the following additional informa-tion: (1) a detailed timetable to assure that all installed equipment (i.e.

electrical, mechanical, HVAC, etc.) will be inspected / surveyed to verify that nonsafety related installations do not pose a safety concern to safety l

related installations, (2) a program to assure that timely inspections / surveys are performed as equipment installation progresses, (3) acceptance criteria

, relating to system interaction for all equipment previously installed, and l

(4) documentation indicating that each item of safety related equipment has been inspected to verify that nonsafety related equipment will not interfere l with safe plant operations during a postulated seismic event. Further, we l request that you notify our Senior Resident Inspector of your plans concern-ing the disposition of discrepancies identified during the performance of this program.

l Certain other activities, set forth in Appendix 3 to this letter, appear j to be a deviation from co=mitments which you have made in previous corres-pondence with the Commission. Please advise us in writing within tventy-five i

davs of the date of this letter of the corrective action fou have taken l

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Illinois Power Company November 12, 1981 or plan to take, showing the estimated date of completion with regard to this deviation.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures and your response to this letter will be placed in the NRC's Public Document Room. If the enclosures contain any infor=ation that you or your conteactors believe to be exempt from dis-closure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-five (25) days from the date of this letter a written application to this office to withhold such information. Section 2.790(b)(1) requires that any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with 1pecificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, k'A

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L. Spessard, Director Livision of Resident and Project Inspection

Enclosures:

1. Appendix A, Notice of Violation

2. IE Inspection Report No.

50-461/81-24 cc w/encls:

DMB Document Control Desk (RIDS)

Resident Inspector, RIII Mary Jo Murray, Office of Assistant Attorney General Gary N. Wright, Manager Nuclear Facility Safety Randall L. Plant, Prairie Alliance

-e G Vid) n MVUn Appendix A NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a result of the inspection conducted on September 1-30, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),

the following violations were identified:

1. 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states: " Activities affecting quality shall be prescribed...

and shall be accomplished in accordance with these instructions, pro-cedures, or drawings."

Illinois Power Nuclear Station Engineering Dopartment Procedure 26, Revision 0, of November 5, 1980 states: "This procedure describes the method to be used for periodic surveillances of site construction to identify potential interaction problems between nonsafety-related systems and nuclear safety-related systems. A Systems Interaction Survey Team shall schedule regular monthly tours of selected CPS areas..."

10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states that:

" Measures shall be established to assure that conditiono adverse to quality, such as...nonconformances are promptly identified and corrected, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition. .shall be... reported to appropriate levels of management."

Contrary to the above, procedures for an interaction analysis program were not implemented, in that, monthly identification tours and design engineering analysis were not being performed. Further, Quality Assurance notified Illinois Power management of failure to implement the program, and prompt corrective action had not been taken.

This is a Severity Level IV violation (Supplement II).

2. 10 CFR 50, Appendix B, Criterion XIII, Handling, Storage and Shipping, states: " Measures shall be established to control the... preservation of material and equipment...:c prevent damage or deterioration."

Baldwin Procedure, Storage a:= *aintenance, BAP 2.4 paragraph 5.1.3a states: " Items stored in-pl shall be suitably protected to minimize the possibility of damage...

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• Appendix A Contrary to the above, physical protection was not provided for installed Class 1E electrical cable 1 DC03D, thereby resulting in damage from ongoing HVAC construction activity.

This is a Severity Level V violation (Supplement II).

L Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including for each item of noncompliance; (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.

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November 12, 1981 ,

Dated R. L. Spessard, Director Division of Resident and Project Inspection l

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Illinois Power Company Docket No. 50-461 Appendix B NOTICE OF DEVIATION Based on the results of an NRC inspection conducted during the period September 1-30, 1981, it appears that one of your activities was not con-ducted in conformance with your commitments to the Commission as indicated below:

The Clinton Final Safety Analysis Report (FSAR), Volume 4, Figure 3.2-1, Classification and Containment Isolation Diagram, Note #9 states: "The RCIC storage tank will be designed, fabricated and tested to meet the intent of ANSI B96.1-73. In addition, the specifications for this tank will require (1) 100 percent surface examination of the side wall to bottom joint and (2) 100 percent volumetric examination of the side wall weld joints, group D classification."

Contrary to the above, only spot radiography (four) in lieu of 100% was performed.

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500 South 27th Street ,

7 Decatur, IL 62525

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Gentlemen:  %:;5;;% ,.

This refers to the routine safety inspection conducted by Messrs. R. N. Gardner and R. L. Lee of this office on October 20-23, 1981, of activities at Clinton Power Station, Unit 1, authorized by NRC Construction Permit No. CPPR-137 and to the discussion of our findings with Messrs. J. O. McHood, W. C. Gerstner and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-terviews with personnel. -

During this inspection, certain of your activities appeared to be in non--

compliance with NRC requirements, as specified in enclosed Appendix A. A written response, submitted under oath or affirmation, is required.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If the enclosures ccatain any information that you or your contractors believe to be exempt f rom dis-closure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for withholding; and (b) submit within twenty-fite (25) days from the date of this letter a written application to this office to withhold such information. Section 2.M0(b)(1) requires that any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to )e withheld, and which contains a full statement of tne reasons which are the bases for the claim that the information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The Exhibit "2" ni '

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Illinois Power Company gg, 3 ,g, information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely,

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C. E. Norelius, Director Division of Engineering and Technical Inspection

Enclosures:

1. Appendix A, Notice of Violation

2. Inspection Report No. 50-461/81-27 cc w/encls:

DMB/ Document Control Desk (R1ES)

Resident Inspector, RIII Mary Jo Murray, Office of .

Assistant Attorney General Gary N. Wright, Manager, Nuclear Facility Safety Randall L. Plant, Prairie l Alliance i

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Appendix A NOTICE OF VIOLATION Illinois Power Company Docket No. 50-461 As a restilt of the inspection conducted on October 20-23, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:

10 CFR 50 Appendix B, Criterion III, states, in part, " Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the license applica-tion...are correctly translated into specifications, drawings, procedures, and instructions."

The Illinois Power Company Quality Assurance Manual, Chapter 3 states in part that, design bases and regulatory requirements shall be adequately translated into the various design documents.

The following instances of failure to correctly translata PSAR requirements into specifications, drawings, procedures, and inst. ructions were identified:

a. Paragraph 8.3.1.4.2.2.3 of the Clinton Power Station PSAR states in part, "Open raceways assigned to different Divisions shall be separated by at least (a) one foot of horizontal free air space, (b) three feet of vertical free air space, or (c) a fire-resistant barrier with dimen-sions sufficient to maintain the minimum free air spacing of (a) and (b). This spacing shall apply if both raceways are open." Contrary to this requirement, eight installed Class 1E cable trays were physically separated from non-Class IE cable trays by less than the required three foot vertical separation. The licensee stated that it was the design intent to install fire protection barriers in accordance with PSAR requirements. The applicable S&L cable tray installation drawings did not specify the use of fire resistant barriers in these instances.

b. Pa ragraph 8.3.1.4.4.3.4 of the Clinton Power Station PSAR states in part, " Instrumentation cables shall be installed in separate conduit or in separate nonventilated solid trays with covers to provide elec-tromagnetic shielding." Contrary to this requirement, two installed Class 1E instrumentation cable trays were of the open ladder type.

Neither S&L drawings nor other documents specified the use of solid trays.

This is a Severity Level VI violation (Supplement II).

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Appendix A Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance: (1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.

NOV 4 =8 Dated C. E. Norelius, Director Division of Engineering and Technical Inspection I

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• ....j December 9, 1981 Docket No. 50-461 '

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Illinois Power Company ATTN: Mr. W. C. Gerstner Executive Vice President _

500 South 27th Street

'i ' 28 Decatur, IL 62525 Centlemen:

This refers to the routine safety inspection conducted by Mr. H. H. Livermore of this office on October 1 through November 9, 1981, of activities at the Clinton Power Station, Unit 1, authorized by NRC Construction Permit No. CPPR-137 and to the discussion of our findings with Mr. M. C. Hollon and others of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in noncom-pliance with NRC requirements, as specified in enclosed Appendix A. A written response, submitted under oath or affirmation, is required.

In accordanca with 10 CFR 2.790 of the Commission's regulations, a copy of this let:er, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room. If the enclosures contain any information that you or your contractors believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your inten: ion to file a request for withholding; and (b) submit within twenty-five (25'. days from the date of this letter a written application to this office :a vithhold such information. Section 2.790(b)(1) requires that any such application must be accompanied by an affidavit executed by the owner of the infer =ation which identifies the document or part sought to be withheld, and which contains a full statement of the reasons which are the bases for the claim that the Exhibit "3" g -

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.111nois Power Cowpany December 9, 1981 t information should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4) . The information sought to be withheld shall be If incorporated as far as possible into a separate part of the affidavit.

we do not hear from you in this regard within the specified periods noted above, a copy of this letter the enclosures, and your response to this letter will be placed in the Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, Of fa / u n e -+

R. L. Spessard, Director Division of Resident and Project Inspection

Enclosures:

1. Appendix A, Notice of Violation ~

2. IE Inspection Report No. 50-461/81-25 cc w/encls:

DM3 Document Control Desk (RIDS)

Resident Inspector, RIII Mary Jo Murray, Office of Assistant Attorney General Gary N. Wright, Manager ,-

Nuclear Facility Safety Randall L. Plant, Prairie Alliance

Anoendix A NOTICE OF VIOLATION Docket No. 50-461 1111nois Power Company As ,a result of the inspection conducted on October 1 through Nove=ber 9, 1981, and'in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),Je he following.vio'lat. tons were identified:

1. ~ 10 CFR 50, Appendix B, Criterion XIII, Handling, Storage and Shipping, states: " Measures shall be established to control the... preservation of material and equipment...to prevent damage or deterioration."

3aldwin Procedure, Storage and Maintenance, BAP 2.4, paragraph 5.1.8a

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states:

" Items stored in-plant shall be suitably protected to =inimize the possibility of damage, vandalism or misuse."

Contrary to the above, physical and environmental protection from nearby construction activity was not provided for five installed Class 1E Elec-

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trical Cabinets and numerous precut, coiled, temporarily stored Class 1E Electrical Cables.

This is a Severity Level V violation (Supplement II).

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2. 10 CFR 50, Appendix 3, Criterion V, Instructions, Procedures, and

" Activities affecting quality shall be prescribed...

Drawings, states:

and shall be accomplished in accordance with these instructions, pro-cedures, or drawings."

Baldwin Procedure, Cable Installation, BAP 3.3.2, Rev. 8, paragraph 5.8.4 states in part: "If the cable has not been correctly installed...

the Senior Electrical Quality Control Engineer shall not sign off the Pull Card, but shall note the discrepancies in the Remarks section. . ."

Baldwin Procedure, Quality Control Inspection Checklist, Form JV 353 states:

" Cable is correct color, type and size as specified on Cable Pull Card--Acceptable (A) or Reject (R)."

Contrary to the above, Quality Control Inspectors failed to follow procedures, by accepting twelve incorrectly marked (color coded) Class lE electrical cables. Inspection checklists and Cable Pull Cards were incorrectly ac.c epted for the installed (pulled) cables.

This is a Severity Level V violation (Supplement II).

to Pursuant to the provisions of 10 CFR 2.201, you are required to submit this office within thirty days of the date of this Notice, a written state-ment or explanation in reply, including for each item of noncompliance; (1) corrective action taken and the results achieved; (2) corrective action i ,, .

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and (3) the date when full com-to be takeri to avoid further noncompl anceUnder the authority i d of underSection oath 182 of the Atomic pliance_will be achieved.

Enargy Act of 1954, as amended,'this response shall be subm tt or afiirmation.

for good cause shown,

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December 9, 1981 ._

R. L. Spessard, Director Dated Division of Resident and Project Inspection

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

ILLINOIS POWER COMPANY, ) ' '

SOYLAND POWER COOPERATIVE, )

INC. and WESTERN ILLINOIS ) Docket No. 50-461 OL POWER COOPERATIVE, INC. )

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(Operating License for Clinton )

Power Station, Unit 1) )

NQTIgE 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 Richard J. Goddard Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 l Sheldon Zabel

' Schiff, Hardin & Waite 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 Jan L. Kodner l Tutt and Kodner 173 West Madison Street Suite 1004 Chicago, Illinois 60602

a Prairie Alliance P.O. Box 2424 Station A Champaign, Illinois 61820 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 mailed for filing with the Secretary, United States Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Chief, Docketing and Service Section, one original and two conformed copies of Illinois' Motion To Allow Discovery On Prairie Alliance Contention No. 2. A copy of this document is attached and served upon you.

PHILIP L.' WILL N Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED: April 29, 1982 n

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

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, )

INC. and WESTERN ILLINOIS ) Docket No. 50-461 OL POWER COOPERATIVE, INC. )

)

(Operating License for Clinton )

Power Station, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that I served copies of Illinois' Motion To Allow Discovery On Prairie Alliance Contention No. 2 on the persons listed on the attached Notice by causing same to be deposited in the United States Mail, First Class, postage prepaid, on this 29th day of April, 1982.

bW PHILIP L. ' WILLMAN