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By Leonard J . y' ch Vice President 41GNED AS TO OBJECTIONS:
By Leonard J . y' ch Vice President 41GNED AS TO OBJECTIONS:
r
r
[[Mg- y' -
((Mg- y' -
Peter V. Fazio,>Jr> >
Peter V. Fazio,>Jr> >
One of the Attorneys for 3                                    Applicants.
One of the Attorneys for 3                                    Applicants.

Latest revision as of 12:29, 15 March 2020

Response to State of Il First Set of Interrogatories Re Personnel Needs & Qualifications
ML20009H053
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 07/27/1981
From: Koch L
ILLINOIS POWER CO.
To:
ILLINOIS, STATE OF
Shared Package
ML20009H052 List:
References
ISSUANCES-OL, NUDOCS 8108050397
Download: ML20009H053 (37)


Text

__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __.

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

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIV2, INC.)

and WESTERN ILLINOIS POWER ) Docket Nos. 50-461-OL COOPERATIVE, INC. ) 50-462-OL

)

(Operating Licenses for Clinton)

Power Station, Units 1 and 2) )

RESPONSE OF ILLINOIS POWER TO THE STATE OF ILLINOIS' FIRST SET OF INTERROGATORIES l

Illinois Power Company ("IllinoL Power" or "the Company" or "IP") hereby responds to the State of Illinois' First Set of Interrogatories as follows:

(1. State all employment positions that will exist at the CPS, when operation is commenced,

, and for each position state as follows:

a. the total number of persons who will hold the position;
b. the number of persons who have been hired to date;]

ANSWER: Since personnel f rom the Nuclear Station Engineer-ing Department ("NSED") and the Quality Assurance Department

(" QA " ) have responsibilities that are carried out at the Clinton Power Station (" CPS " ) site, employment positluns in these departments , as well as those for CPS Operations ,

are set forth in the attached Exhibits A, B, and C.

t 8108050397 810727 DRADOCK05000g

[1.c. the minimum qualifications that must be met for each position, inclading education, experience, training, security clearance, and licenses-NRC, state and other;

f. a description of the duties and responsibili-ties.]

k ANSWER: See attached Exhibit D for the NSED, Exhibit E for CPS Operations, and Exhibit F for 0A.

(l .d . the training, of any kind, .'ach person will receive subsequent to airing but

) prior to assumption of the duties for which he or she was hired;

> e. the training, of any kind, each person will receive on a continuing or periodic basis subsequent to ansumption of the

) duties for which he or she was hired;]

ANSWER: See Exhibit G for the NSED, Exhibit H for CPS Oporations, and Exhibit I for QA.

A

[2. Identify and specify the qualifications of all persons who are now or will be assigned c to any safety-related supervisory, control or maintenance duties at the CPS, and state the position each person is or will be hold-ing.]

)

. ANSWER: NSED nuclear safety-related supervisory personnel qualifications are set forth in Appendix 13.A of the FSAR.

For CPS Operations personnel, see the attached Exhibit J.

[3. Identify all persons IP has employed in Quality Assurance (QA) and Quality control g; (G ) positions at the CPS within the last five years, and for each person state:

a. the date when employment began;
b. the date, if applicable, when employment ended;
c. his or her qualifications]

)

ANSWER: The names , dates of employment, and qualifications

) for the QA employees are set forth in the attached Exhibit K.

[3.d. the reason (s) , if applicable and known

). to IP, for termination of employment.]

ANSWER: Illinois Power obj ects to Interrogatory No. 3.d.

on the grounds that the information requested (a) is not relevant, and (b) is exempted from disclosure under 10 C.F.R.

S 2c790, and disclosure is not necessary to a proper decision

/

in the procee61r.g.

)

7

[4. Identify all documents related to, referring to, or discussing any of the following:

a. the management of QA/QC f unctions at the CPS;
b. the quality of QA/QC work at the CPS)

)s ANSWER: Relevant documents are available fer inspection at the offices of Illinois Power.

[4.c. the reason (s) for the termination of employ-

. ment of any person in QA/QC positions.]

ANSWER: Illinois Power objects to Interrogatory No. 4.c.

on the grounds that the information requented (a ) is not relevant, and (b) is exempted from disclosure under 10 y,i C.F.R. S 2.790, and disclosure is not necessary to a proper decision in the proceeding.

[5. Identify all documents related to, referring to, or discussing any of the following:

a. the management of the construction t of the safety-related systems of the

) CPS

)

J

J C) 1 1

b. the quality or integrity of work on q

the construction of the safety-related systems of the CPS) o ANSWER: Relevant documents are available for inspection at the offices of Illinois Power.

o

[5.c. the reason (s) for the termination of persons employed at such tasks.]

ANSWER: Illinois Power objects to Interrogatory No. 5.c.

o g, on the grounds that the information requested (a) is not relevant, and (b) is exempted from disclosure under 10 C.F.R. 5 2.790, and disclosure is not necessary to a proper

) decision in the proceeding.

[6. Identify all persons who prepared the Final Safety Analysis Report (FSAR) for the CPS, and for each of the following parts of the v~ FSAR identify all persons whose data, studies,

'7) reports, comments or other information were used in the preparation thereof:

o.

a. Volume 16, Chapter 13, Section 13.1,

" Organizational Structure of Applicant";

[) b. Volume 16, Chapter 13, Section 13.2,

" Training";

d'

c. Volume 18, Chapter 17, " Quality Assur-ance '; and L3 d. Volume 15, Chapter 11, Section 11.2.1.4,

" Quality Control,"]

g, ANSWER: The preparation of the FSAR extended over about 4

a two year period and involved several hundred persons D

from Illinoi? power, Sargent & Lundy, General Electric Company ("GE") , and other organizations.

M

(

)

D The Illinois Power personnel directly involved

D in the preparation and approval of the specific FSAR sections identified in Interrogatory No. 6 are
a. Volume 16, Chapter 13, Section 13.1, " Organizational Structure of Applicant" O

L. S. Brodsky Assistant Power Plant Manager Clinton Power Station G. H. Reed D Shift Supervisor Clinton Power Station G. E. Wuller Supervisor - Licensing, NSED Illinois Power Company T. F. Plunkett Power Plant Manager Clinton Power Station

L. J. Koch j Vice President Illinois Power Company 4

J. D. Geier Manager - Nuclear Station Engineering Dept.

Illinois Power Company 3

b. Volume 16, Chapter 13, Section 13.2, " Training' o'

L. S. Brodsky Assistant Power Plant Manager Clintoa Power Station O

R. F. Schaller Supervisor - Training Clinton Power Station J. G. Cook e Supervisor-- Technical Clinton Power Station T. F. Plunkett Power Plant Manager Clinton Power Station M

-s-J

O

c. Volume 18, Chapter 17, " Quality Assurance" M. C. Hollon

() Supervisor - Construction

. Quality Assurance Clinton Power Station J. D. Geier Manager, Nuclear Station Engineering Deat.

(3 Illinois Power Company

d. Volume 15, Chapter 11, Section 11.2.1.4, " Quality Control" g M. C. Hollon Supervisor - Construction Quality Assurance Clinton Power Station G. E. Wuller Supervisor - Licensing

( Illinois Power Company D. L. Holtzscher Supervisor - Technology Assessment Illinois Power Company c-) [7. State, both in terms of percentage and total outlay, the capital investment of each of IP, Western Illinois Power Cooperacive, Inc. ("WIPCO" ) , and Soyland Power Coopera-tive, Inc. ("Soyl and" ) in the CPS Unit 1, both to date and the estimated final total

.g investment.]

ANSWER: A. Investment to date Clinton Unit 1 Capital Investment through May 31, 1981

() Amount Percent IP $ 967,243,047 83.0%

WIPCO 94,329,881 8.1 Soyland 104,259,343 8.9

() $1,165.832,271 100.0%

C#

O

O B. Estimated final tota). investment O Clinten unit 1 Estimated Total Capital Investment Amount Percent IP $1,455,537,000 84.0%

WIPCO 131,786,000 7.6 g Soyland 145,658,000 8.4

$1,732,981,000 100.0%

[8. State the current total assets of IP, as C) well as the current value of each of IP's operating electrical generation facilities.)

ANSWER: At May 31, 1981, the current total assets of Illinois Power were $2,558,446,514.

O At May 31, 1981, the current value (original cost) of Illinois Power's operating electrical generation facilities was as follows:

O Generating Sta* ion Original Cost Havana $231,730,563 Wood River 101,553,080 Henepin 49,687,714 C) Vermilion 35,707,345 Baldwin 356,074,128 Oglesby 8,481,417

, Stallings 10,045,728 l Jacksonville 3,203,270 l Bloomington 1,027,561 C) Vandalia 426,971 Total $787,937,777

'() [9. State.the percentage of the total assets of IP that CPS Unit 1 will represent when operation is commenced.]

ANSWER: 45.2% (Estimated)

'() -

l

O J

lO

[10. State the current total electrical generating

.(3 capacity of IP.]

ANSWER: Capacity

  • owned by IP: 3815 MW Other capacity **: 57 MW 33 Total: 3872 MW i In addition to the above capacity, Illinois Power l receives 65 MW of firm power f rom TVA between May and Novem-O ber of each year as part of a seasonal capacity exchange.

In 1985, this purchace is scheduled to be reduced to 9 MW.

  • Summer ratings O
    • Available under long term firm power supply contracts.

[11. State the estimated electrical generating

() capacity of CPS Unit I when operation is commenced.]

ANSWER: Total Unit (100%) : 950 MW net I? Share ( 80%): 760 MW cet O

[12. State the percentage of the total electrical generating capacity of IP that CPS Unit 1 will represent when operation is commenced.]

O ANSWER: Based on Illinois Pot,er's 760 MW of CPS Unit 1 and Illinois Power's 3872 MW of owned and other capacity, CPS will represent 16.4% of Illinois Power's capacity in 1983.

O

[13. State the percentage of the total electrical generating capacity of WIPCO that CPS Unit 1 will represent when operation is commenced.]

ANSWER: 62%

O O

~ . _. ._

1

,0

)

[11. State the percentage of the total electrical generating capacity of Soyland that CPS C) Unit 1 will represent when operation is commenced.]

ANSWER: 100%

C) [15. State the annual load factor (i .e . percentage of capacity) for IP for each of the last five years .]

ANSWER: Illinois Fower's average annual system load factor

,!O for each of the last five years, based on the formula set forth below, is as as follows:

1980 56.1%

1979 57.6%

1978 58.8%

1977 55.9%

)

1976 57.7%

Load factor = MWhrs x iOQ%

C) Peak MW x Annual Hours

[16. State IP's anticipated load f actor when operation of CPS Unit 1 is commenced.]

O ANSWER: Illinois Power's estimat~!d Irerage annual system load factor, based on the formula set forth below, is 52.4%

for 1983.

Load factor = MWhr s x 100 % _ _

Peak MW x Annual Hours

'O O

%- _ , ,., _~, ,, ___ ~- ..~.,yr ._ ,,,,.w., , , , , + - - , - , , . - , - , . , ,y -.y. . ,, ,, ,..v,..--

- . . . , _,m, , , ,y- - - , . . . y- .w-, -, e

)

l

[17. For the fiscal year 1980, state the amount, D if any, of electricity IP sold to other l

utilities, as well as the revenue derived by IP from such sales.]

i ANSWER: During fiscal year 1980, Illinois Power sold D 3,224,161 MWhrs of electricity to other utilities, including wholesale deliveries to cooperatives and municipals and interchange sales to other utilities, for revenues of J S89,554,335.

[18. For the fiscal year 1981 state the estimated amount, if any, of electricity IP will sell to other utilities, as well as the revenue 3 expected to be derived by IP from such sales.]

ANSWER: During fiscal year 1981, Illinois Power expects to sell 3,346,218 MWhrs of electricity to other utilities for revenues of approximately $101,965,162. These figures I

include deliveries to cooperatives and municipals and inter-change sales to other utilities and are based on actual D data through May and estimated data f rom June through Decem-be r .

[19. State the estimated annual costs of operating CPS Unit 1, including figures for estimated D repairs and maintenance.]

ANSWER: The estimated annual costs for operating, maintenance, and repairs for Illinois Power's 80% share of CPS Unit 1 for a D full year (1984) are $10,600,000.

1 D

D

l'

[20. State the estimated total cost of decommission-O ing CPS Unit 1 at the end of its expected usef ul lif e, and state the estimated cost of each of the tasks involved in that decom-missioning.]

ANSWER: The estimated total cost of decommissioning CPS Unit 1 is $42 million in 1978 constant dollars.

The assumed method of decommissioning is immediate dismantlement. This method involves removal of radioactive O

materials from the plant site immediately following final shutdown. Af ter the radioactive materials have been shipped f rom the site, the f acility can be released for unrestricted use. The estimated cost of significant tasks involved in the decommissioning are:

O Estimated Percent Item Cost of Total C)

(Millions of $)

Fuel Shipment $3.1 7%

Equipment and Supplies 3.0 7 C) Disposal of Radioactive Materials 10.7 26 Power 4.4 10 g Labor 11.2 27 Contractors and Demolition 8.7 21 Insurance 1.0 2 O

$42.1 100%

O

)

l [21. State the estimated total cost of maintaining

7) CPS Unit 1 in a safe condition after CPS Unit I has been decommissioned, and state the estimated cost of each of the tasks involved in that maintenance program.]

ANSWER: The immediate dismantlement decommissioning method allows for unrestricted use of the site after decommissioning is completed. Therefore, there are no estimated costs for maintaining the site.

b

[22. Identify all documents referring to or discuss-ing any of the matters raised in Interroga-tories Nos .19, 20 or 21 a bove .]

) ANSWER: Relevant documents are available for inspection at the offices of Illinois Power.

J

[23. Identify the principal financial officers of IP.]

ANSWER: Mr. Charles W. Wells Executive Vice President g Illinois Power Company 500 South 27th St.

Decatur, Illinois 62525 Mr . Larr y D. Haab 3 Vice President and Treasurer Illinois Power Company 500 South 27th St.

Decatur, Illinois 62525 9 l 0

S

4 (D 1

[24. Identif y all persons , including financial of ficers , who supervised the preparation

.() of IP's latest annual statement.]

ANSWYR: Charles W. Wells Executive Vice President Illinois Power Company 500 South 27th Street

'(3 Decatur Illincis 62525 A. E. Gray Vice-President and Secretary Illinois Power Company

.I3 500 South 27th Street Decatur Illinois 62525 I

Elmer R. Turner Manager of Accounting

'() Illinois Power Company 500 South 27th Street Decatur Illinois 62525 q') [25. Identify all persons , including financial officers, who supervised the preparation of IP's proposal to the Illinois Commerce Commission in the proceeding captioned Illi-l nois Power Co., Propoced General Increase 1

in Electric Rates, 80-0544 and 80-0365.]

ANSWER: Mr. Larry D. Haab i Vice President and Treasurer Illinois Power Company 500 South 27th St.

Decatur, Illinois 62525 10 Mr. Miro P. Mladiner Manager of Rates j Illtr.ois Power Company 500 South 27th St.

(7 Decatur, Illinois 62525 1 P

- , , ,,--, , .. -- . . , _ .. .--,.- e

1

[26. Identify the principal financial ctficers of WIPCO.]

ANSWER: Gene H. Burton Secret ar y-Treas ur er WIPCO Box 609 Jacksonville, Illinois 62651 O

Robert E. Gant Assistant Secretar y-Treasurer WIPCO Box 609 C) Jacksonville, Illinois 50651

[27. Identif y all persons , including financial of ficers , who super vised the preparation of WIPCO's latest annual sta.tement.]

ANSWER: D. B. Bringman General Manager WIPCO Box 609

, Jacksonville, Illinois 62651 Charles W. Heacox Office Manager WIPCO Box 609 C) Jacksonville, Illincis 62651

[28. Identify the principal of ficers of Soyland.]

) ANSWER: Walter R. Smith, President Soyland Power Cooperative , Inc.

P.O. Box A1606 Decatur, Illinois G2525 b Allen Sisk, Vice-President Soyland Power Cooperative, Inc. i P.O. Box A1606 i Decatur, Illinois 62525 l

C O

Dennis L. Tachick, Secretary-Treasurer Soyland Power Cooperative, Inc.

O P.O. Box A1606 Decatur, Illinois 62525 William D. Champion, Assistant Secretary g Goyland Power Cooperative, Inc.

P.O. Box A1606 Decatur, Illinois 62525

[29. Identify all persons , including financial of ficers, who supervised the preparation

() of Soyland's latest annual statement.]

ANSWER: Walter R. Smith, President Soyland Power Cooperative, Inc.

P.O. Box A1606 Decatur, Illincta 62525 O

Allen Sisk, Vice-President Soyland Power Cooperative, Inc.

P.O. Box A1606 Decatur, Illinois 62525

()

Dennis L. Techink, Secretary-Treasurer Soyland Power Cooperative, Inc.

P.O. Box A1606

() Decatur, Illinois 62525 William D. Champion, Assistant Secretary Soyland Power Cooperative, Inc.

P.O. Box A1606

<3 Decatur, Illinois 62525 Royal B. Newman, Executive Vice President and General Manager Soyland Power Cooperative , Inc.

'O P.O. Box A1606 Decatur, Illinois 62525 Richard R. Ruzich, Assistant General Manager Soyland Power Cooperative , Inc.

iO P.O. Box A1606 DECatur, Illinois 6?525

.O i _

i

O

[30. State each anticipated transient without scram (ATWS) condition that IP has considered g and will consider with respect to the opera-tion of the CPS. For each ATWS condition so stated identify the following:

a. the ASME class into which the condition falls; O b. all documents that describe the ATWS condition; and
c. all persons who were and are responsible for, or who have had and currently have knowledge of, the ATWS condition con-

.(3

sidered.)

ANSWER: Illinois Power objects to Interrogatory No. 30 on the grounds that the information requested is beyond the scope of the admitted contention, and is therefore irrelevanc.

j Prairie Alliance Revised Contention 6 contained h the general allegation that the " CPS has not been designed and constructed to resolve the matter of [ATWS]," along i

with the specific allegation that the CPS "is especially

o vulnerable to ATWS" due to inadeqJate repair of faulty welds on a number of control rod drive tubes. In its Memoran-l j dum and Order issued May 29, 1981, the Board rejected the LO general allegation concerning design and construction, and admitted a revised version of the ATWS contention based on a narrow question of fact: "It is alleged that f aulty n"

welds on a number of control rod drive tubes raise the likelihood that an ATWS can occur." Order at 10.

.O O

D In the absence of a question of fact concerning a particular vulnerability to ATWS, there is no basis for 7) consideration of the ATWS issue in this proceeding. ATWS was one of the generic issues listed in Prairie Alliance Revised Contention 19, which was rejected by the Board.

3 The documents made available for inspection by Illinois Power in response to Interrogatories Nos. 33 and g 36 show that all control rod drive tubes with faulty welds were discarded and replaced with new tubes. Since there is no increased likelihood that an ATWS can occur at the

) CPS, information relating to the generic aspects of the l

hTWS issue is irrelevant.

{31. Describe all analyses or assessments that

, IP has performed and will perform with respect to the occurrence of an ATWS condition at the CPS. For each analysis or assessment:

a. state the assumed rate of occurrence per reactor year;
b. describe the results and conclusions;
c. identify all documents related to, referring to, or discussing the analysis or assessment; and
d. identify all persons, including BWR owners' groups or other organizations, who were and are responsible for, or who have had knowledge and currently have knowledge of, the analysis or

, assessment.]

ANSWER: Illinois Power objects to Interrogatory No. 31

'or the reasons set forth in its objection to Interrogatory q, No. 30.

O

. ___1__

!O

[32. State all measures IP has taken and will take to reduce the risk of an ATWS condition at the CPS. For each measure so stated:

!O j a. describe how it will work;

b. identify all documents ref erring to, related to or discussing the measure; 4

and

!O

c. identify all percons who were and are responsible for, or who have had and have knowledge of, the use of the measure.]

ANSWER: Illinois Pcwer objects to Interrogatory No. 32 f or the reasons set forth in its objection to Interrogatory No. 30.

33 [33. Identify all documents, including NRC I & E reports and correspondence related thereto,

referring to, related to, or discussing the quality of welding during construction of control rods and control rod drive tubes at the CPS.]

ANSWER: Admitted contention No. 5 concerns only control rod drive tubes. Therefore, all parts of this interrogatory concerning the control rods are irrelevant. Relevant docu-ments concerning the control rod drive tubes are available

( for inspection at the offices of Illinois Power.

() [34. Identify sll persons who were and are respon-sible for the management, review, or inspec-  !

i tion of weiding durirca construction of the l

control rods and control rod drive tubes at the CPS.]

lO ANSWER: Admitted Contention No. 5 cencerns only control rod drive c.ubes. Therefore, all parts of this interrogatory concerning the control rods are irrelevant. Personnel lO 4

O

O who were and are responsible for the management, review, O

or inspection of welding during construction of the control rod drive tubes at CPS are as follows:

() Bill J. Wright - Engineer Clinton Power Station P.O. Box 306 Clinton, IL 61727 .

1 Jim F. Gleason - Technical Services Coordinator O Address not known Bill W. Merit - Quality Control Address not known Ron C. Campbell - Quality Control O Clinton Power Station P.O. Box 306 Clinton, IL 61727 Mike J. King - Authorized Nuclear Inspector Clinton Power Station O P.O. Box 306 Clinton, IL 61727 Paul F. Gardner - Welding Inspector Clinton Power Station P.O. Box 306 O Clinton, IL 61727 John F. Linehan - Manager Quality Control Address not known Bill G. Carson - Manager Technical Services O Baldwin Associates Clinton Power Station P. O. Box 306 Clinton, IL 61727 Bob L. Peters - Mechanical Superintendent O Clinton Power Station P.O. Box 306 Clinton, IL 61727 O

O m - - - - _ - _ _ _ . . _ . _ _ _ . _ . _

O Larry A. Gelbert - Manager Quality Control Clinton Power Station 3 P.O. Box 306 Clinton, IL 61727 Glen A. Chapman - Manager Technical Servicer Clinton Power Station P.O. Box 306 O Clinton, IL 61727

[35. Identif y all persons who have performed and are now performing the tasks of welding during construction of the control rods C) and control rod drive tubes at the CPS.)

ANSWER: Admitted Contention No. 5 concerns only control rod drive tubes. Therefore, all parts of this interrogatory

[) concetning control rods are irrelevant. The following individuals made tube sheet welds in the control rod drive penetrations associated with the replacement of tubes having O Lurn tnrough or suck back conditions:

l J. L. Suttle 615 E. Franklin St., Evansville, Ind. 47711 W. M. Mosby R. R. 1, Junction, IL 62954 D. R. Rowsey R. R. 1, Box 337, Farmville, Va. 23901 A. J. Pippitt 3 4511 Independence , Peoria, IL 61614 H. W. Valencia R. R. 1, Manito, IL 61546

[36. Identify all docaments referring to, related 3 to, or discussing analyses of the strength and adequacy of the control rods and the control rod drive tubes installed at the CPS.]

ANSWER: Admitted Contention No. 5 concerns only control S rod drive tubes. Therefore, all parts of thic interrogatory concerning control rods are irrelevant.

S

iO 4

All control rod drive tubes with faulty welds

C) were replaced with new tubes. All installed control rod drive tubes at CPS meet the original design criteria.

The control rod drive tubes which were adversely affected i C) by welding were not specifically analyzed for strength and adequacy since they were replaced with tubes which j met the original design criteria, tO

[37. Identify all persons who have knowledge of any analysis of the strength and adequacy of the control rods and the control rod

, drive tubes installed at the CPS.]

O ANSWER: Admitted Contention No. 5 concerns only control rod drive tubes. Therefore, all parts of this interrogatory concerning control rods are irrelevant.

'(3 Since all control rod drive tubes with faulty welds were replaced with new tubes, they were not specifically analyzed for strength or adequacy.

O

[38. State whether IP has complied, or will comply, with the NRC recommendations, applicable to the CPS, in NUREG 0460, Vol. IV.]

ANSUER: Illinois Power objects to Interrogatory No. 38

O l

for the reasons set forth in its objection to Interrogatory No. 30.

(O [39. State whether IP has complied, or will comply, with the NRC recommendation in NUREG 0460, alternative 4A, to revise the standby liquid I control system (SLCS) to provide for higher flow rates. If the answer is in the negative, please state the reason (s) and explain.]

.O l

j l lO

)

ANSWER: Illinois Power objects to Interrogatory No. 39 for the reasons set forth in its objection to Interrogatory No. 30.

[40. State whether IP has complied, or will comply, with the NRC reccmmendation in NUREG 0460,

) alternative 3A, to revise the SLCS to provide for higher flow rates. If the answer is in the negative, please state the reason (s) and explain.]

ANSWER: Illinois Power objects to Interrogatory No. 40 for the reasons set ictth in its objection to Interrogatory No. 30.

) [41. Describe all systems that IP has installed, or will install, for the detection of reactor coolant pressure boundary leakage. For each system so described:

a. state what piping, pumps and drains

) are monitored;

b. state the minimum detectable leak rate, in gallons per minute;
c. state the minimum change in leak rate, in gallons per minute, that can be

) detected;

d. identify all documents related to, referring to, or discussing its function and operation; and

) e. identify all persons who are responsible for its function and operation.]

ANSWER: Illinois Power objects to Interrogatory No. 41

) on the grounds that the information requested is beycnd the scope of the admitted contention, and is therefore irrelevant. The issues raised under Contention 8 concern

)

)

_ - - _ - - i

O the seismic qualification of sump flow monitoring calculation O'

and indication devices and the accessibility of transmitters for sump flow monitoring instruments.

The systems which Illinois Power has installed O'

for the detection of reactor coolant pressure boundary (RCPB) leakage are described in section 7.6.1.4 of the CPS FSAR. Further description of the monitored parameters O

is provided in subsection 5.2.5.2.1. of the CPS FSAR.

Diverse means are employed to detect RCPB leakage as sug-gested by Regulatory Guide 1.45, including temperatures, 3

dif f erential temperatures , flow rates , water levels, steam pressures, sump fill rates and pumping times, and fission product levels. Lists of the monitored points are provided D

in Figure 7.6-2 of the CPS FSAR. The minimum detectable change in leakage rate is 1 gal / minute in a 60 minute period, and the minimum detectable leakage rate is 5 gal / minute D

for unidentified leakage and 25 gal / minute for identified leakage. This appeared in CPS FSAR, Section 5.2.5.1.1.

Responsibility for the function and operation of RCPB leakage D

detection will rest with the Supervisor-Maintenance of the CPS staff as discussed in Section 13.1.2 of the CPS FS AR.

D lJ

<3

D

[42. Describe the analysis performed by IP of the seismic qualifications of the sump
) flow monitoring, calculation and indica-i tion devices to be used at the CPS in the l reactor coolant pressure boundary leakage

! detection systems. For each analysis per-formed, identify:

l

'[) a. all documents related to, ref erring to, or discussing the seismic qualifica-tions for those devices; and

b. all persons who are responsible for or who have knowledge of this analysis.]

)

ANS!3ER: The drywell transmitter for floor drain senp monitoring will be seismically qualified. The vendor ceismic test reports are not available as yet due ta) incomplete D

procurement. The calculation and indication devices will not be seismically qualified and therefore no analyses are to be performed. The calculation and indication devices

) are not part of the RCPB.

[43. Describe the measures IP has taken or will take to ensure that the sump flow calculation

) and indication devices are readily accessible for maintenance or replacement during a seismic event. For each measuf e so described, identify:

a. all documents referring to, related

) to, or discussing such measure; and

b. all persons who are responsible for the implementation of such measure.]

ANSWER: Sump flow calculation and indication devices are'

) located in areas which are accessible for maintenance or replacement at any time. These devices are located i'n -

the Cable Spreading Room at elevation 781 of the Control

)

)

O Building and in the Main Control Room. Relevant documents O

are available for inspection at the of fices of Illinois Power. The Supervisor-Maintenance on the CPS Plant Operating l Staff is responsible for the maintenance of this equipment O

as disc 2ssed in Section 13.2.1 of the CPS FSAR.

[44. Describe the measures IP has taken or will take to account for the lack of accessibility D during plant operation to the sump flow monitoring instruments for the drywell equip-ment and floor drain sumps. For each measure so described , identif y:

a. all documents referring to, related O to, or discussing such measure; and
b. all persons responsible for the implemen-tation of such measure.]

ANSWER: Illinois Power has committed to install diverse D

means of detecting leakage from the RCPB. These diverse means are described in the CPS-FSAR Sections 5.2.5 and 7.6.1.4.

D Accessibility during plant operation to the sump flow monitoring instruments in the drywell is not a regula-tory reqpirement. The sump monitoring system is not part of the RCPB, and Criterion 14 of 10 C.F.R. Part 50, Appen-dix A, is therefore not applicable to these devices.

S [45. State whether the design, analysis and documen-tation of the CPS presently complies with the requirements of 10 C.F.R. 50, Appendix K ,

Section I. If not, describe each area of -

non-compliance , and f or each area:

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a. describe the measures IP intends to take to correct the non-compliance; b

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b. state the date by which IP intends to achieve compliance; and
c. identify all documents, including corres-pondence between IP and the NRC, referr-ing to, related to, or discussing the non-compliance.]

ANSWER: The design, analysis, and documentation of the CPS ptesently complies with the requirements of 10 C.F.R. Part 50, Appendix K,Section I.

[46. Describe the analytical models used by IP or its suppliers to analyze fuel swelling and flow blockage in the core due to loss-O of-coolant accident (LOCA) conditions.

For each model so described;

a. state whether it is conservative or non-conservative in comparison to the models described in NUREG 0630, and explain;
b. describe how the model is different from the models described in NUREG 0630]

ANSWER: The analytical model used by GE for Erediction of BWR response to postulated LOCAs is documented in NEDO-20566 (and supplements) . Included in this document is a description of the model for predicting cladding swell-ing and rupture. Further discussions of the f uel clad swelling and rupture model are contained in a letter from GE to the NRC, Buchholz to Rubcnstein, GE Fuel Clad Swelling and Rupture Model, dated May 15, 1981. This letter includes a comparison of the GE model with the correlations contained 9

3 in NUREG-0630. The GE model is conservative in comparison D

to the models described in NUREG 0630 within the range applicable to BWRs.

e [46.c. describe the computer code for the model]

ANSWER: The computer codes for the GE model are documented in NEDO-20566.

3

.[ 46.d . identif y all documents related to, ref erring to, or discussing the model, including manuals, dictionaries or machine recdable source codes for the model,]

3 ANSWER: Relevant documents are available for inspection at the offices of Illinois Power.

[46.e. identify all personn who created the model]

O ANSWER: 1. John D. Duncan Manager, BWR-TMI Programs General Electric Company 175 Curtner Avenue M/C 738 9 San Jose, CA 95125

2. Atambir S. Rao M2. nager, ECCS Engineering General Electric Company 175 Curtner Avenue M/C 766
  1. San Jose , CA 95125
3. John M. Sorensen (former GE employee)

S. Levy Inc.

1999 S. Bascom Avenue

  1. Campbell, California O

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[46.f . identity all persons who are responsible

() for running the model.]

ANSWER: Atambir S. Rao Manager, ECCS Engineering General Electric Company 175 Curtner Avenue M/A 766 (D San Jose, CA 95125

[47. State whether IP has compared or will compare the models, described in answer to Interroga-tory 47, to those in NUREG 0630 to determine jO the accuracy of those modele in predicting the degree of swelling in high stress condi-tions. If so, describe the results of that comparison and identify:

a. all documents related to, referring to, O or discussing this comparison]

ANSWER: GE has compared its LOCA model with the correla-tions presented in NUREG-0630. This comparison is discussed 3 in a letter f rom GE to the NRC, Buchholz to Rubenstein, "GE Fuel Clad Swelling and Rupture Model", dated May 15, 1981.

Relevant documents are available for inspection D at the offices of Illinois Power.

[47.b. all persons who were responsible for making the comparison.]

3 The persons responsible for making the. comparisons are:

1. Atambir S. Rao Manager, ECCS Engineering
  1. General Electric Company 175 Curtner Avenue M/C 766 San Jose, CA 95125 0

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2. David A. Hamon Technical Leader, ECCS Engineering General Electric Company 175 Curtner Avenue M/C 766 San Jose, CA 95123
3. Ricnard J. Williams Engineer, Fuel Rod Thermal and Mechanical Analysis
  1. General Electric Company 175 Curtner Avenue M/C 155 San Jose, CA 95125

[48. State IP's position on the adequacy of the 3 straight line approximation used in the GE model in NUREG 0630 in meeting the require-ments of 10 C.F.R. 50, Appendix K.]

ANSWER: Illinois Power's position is that the straight 3 line approximation used in the GE model meets the require-ments of 10 C.F.R. Part 50, Appendix K.

[49. Describe IP's justification for the position stated in answer to Interrogatory 48, and state the nature of and schedule for addi-tional connections and analyses, if any.]

ANSWER: Justification for the position stated in the 3 Answer to Interrogatory No. 48 is found in the documents made available for inspection in response to Interrogatory Nos. 46 and 47. GE has agreed with the NRC to perform

) several additional sensitivity studies. These studies are scheduled for completion by the end of July 1981.

No additional changes or analyses are planned.

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[50. Identify all documents, including drawings, blue prints and specifications, that are related to and describe the spent full trans-CD fer tube, including physical location, access points, cross sections , interlocks , entry and exit points, and methods for removal of stuck fuel bundles.]

ANSWER: The spent fuel transfer tube is described in O

Section 9.1.4.2.3.11 and 12.3.1.9.1 of the CPS FSAR. CPS FSAR drawings 9.1-14 and 9.1-16 show the f uel transf er t u be . CPS FSAR drawings 1.2-4, 1.2-5, 1.2-6, 1.2-8, 1.2-10 O

and 12.3-63 show the physical location, cross section, access points, and entry and exit points. Other relevant n

documents are available for inspection at the offices of Illinc!s Power.

[51. State the anticipated radiation exposure rate, at each point where a person can gain O access to the spent fuel transfer tube, during each of the following:

a. normal transfer of fuel bundles through the tube; 9 b. of f-normal occurrence of a spent f uel lodging in the tube at a point of access; and
c. worst-case conditions.]

e ANSWER: The spent fuel transfer tube has been provided with radiation shielding on all sides as shown in the FSAR Figure 12.3-63. The shielding is enough to reduce the e exposure rate to a few mR/hr at all points outside the shield where access can be gained. This exposure rate is experienced during normal or any "of f-normal" transfer 9 of fuel bundles through the tubes.

O

O There are two areas within the shielding envelope

, where access can be gained; one in the containment building and the other in the fuel building. Access to these areas can only be gained through the removal of massive hatcher,

, Interlocking mechanisms are provided in the fuel transfer system, as discussed in the FSAR Section 12.3.1.9.1, such that the f uel cannot be loaded into the transfer tube when-ever either one of the hate;tes is opened. Hence the exposure

)

rate in any one of these accessible areas will be limited to a f ew mR/hr , f rom the residual activity in the tube, whenever access is gained into these areas.

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[52. Describe all analyses of anticipated or possible malf unctions of the spent f uel transfer tube system. For ehen analysis:

) a. describe the system's behavior during worst-case conditions;

b. describe the methods IP plans to use to correct malf unctions]

3 ANSWER: A generic failure modes and effects analysis applicable to all BWR/6's has been performed by GE for the cpent fuel transfer system. This analysis does not identify a " worst-case" condition. The results of this analysis, and of the tests deceribed in the Answer to Inter-rogatory No. 53, demonstrate that the spent fuel transfer system will reliably perform its intended function. The methods used to correct any malfunction can only be described in the context of the specific situation that arises.

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O Operation, maintenance, and repair procedures are set forth c) in a manual that is available for inspection at the offices of Illinois Power.

[52.c. identify all documents related to, ref erring c) to, or discussing the analysis]

ANSWER: There are no documents related specifically to the GE f ailure modes and effects analysis in the possession, O custody, or control of Illinois Powcr. These documents are in the possession of GE.

[52.d. all persons who were or are responsible g for performing the analysis.]

ANSWER: David Faulstich Manager of Reactor Refueling and Servicing Equipment Design General Electric Company

() 175 Curtner Avenue San Jose, CA 95125

[53. Describe all tests that have been performed or will be performed on the spen', fuel trans-j) far tube, and for each test:

a. descrite the results]

ANSWER: The transf er tube has been extensively tested.

c) The testing is broken into three categories:

First, prototype and life testing of the avstem was conducted by GE. These tests involved the construction g of a f ull scale -mock-up of the system at a GE test facility.

l A dummy fuel assembly was passed through the c.ystem in several hundred different cycles. Following the prototype C) ,

5

D test, the operating components used in the test were instal-D led at the Kuo Sheng Power Station in Taiwan. Life testing involved the cycling of fuel bundle substitutes through the transfer tube 12,000 times. Measurements of equipment O

wear were made at various times during the test procedure.

The results of the prototype had life tests demonstrate that the system will reliably perform its intended function.

3 Second, functional testing is required of all hardware. These tests are designed to insure that each item has been manuf actured to design specifications, and 3

that it functions properly in conjunction with other elements of the spent fuel transfer system.

Final preoperational testing will be conducted

[3 at the site af ter the spent fuel transfer equipment has been installed . See FSAR 14.2.12.1.10 for the preoperational testing procedure.

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[53.b. identify all documents related to, referring tc, or discussing the test]

ANSWER: There are no documents relevant to functional, prototype, or life testing of the spent fuel transfer system in the possession, custody, or control of Illinois Power.

Documents concerning GE tests and analyses are in the posses-sion of GE.

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[53.c. identify all persons who assisted in or carried out the test.]

g ANSWER: The individuals performing the tests were exclu-sively GE personnel, numbering approximately fifty people, including testing and quality assurance engineers, techni-

) cians, and supervisors.

[54. Describe all engineering and field changes to the original design and construction of the spent fuel transfer tube, and identify

) all documents containing information on these changes.]

ANSWER: The engineering and field changes to the spent fuel transfer tube are minor in nature, such as changing

) bolt lengths or replacing damaged parts. Relevant documents are available f or inspecticn at the of fices of Illinois Power.

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[55. State the estimated life, in the number of spent fuel bundle transferc, of the spent f uel transf er tube.]

) ANSWER: The design life for the tut.e and equipment is 12,000 cycles occuring over a 40 year span.

[56. Explain the basis for the estimation stated g in the answer to Interrogatory 55.]

ANSWER: The 12,000 cycles over 40 years was bu.ed upon a 12 month refueling cycle and an expected 25% discharge 3 of fuel assemblies from the core.

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[57. State the percentage completion of - 1struc-() tion of the CPS Unit 2:

a. as of the date IP filed its oper ting license application; and
b. as of the date IP answers these Iiterroga-O tories.]

ANSWER: The estimated percentage of completion of construc-tion of CPS Unit 2 to date, and as of the date Applicants O filed their operating license application, is 1-1/2%.

[58. State the date by which IP expects to complete construction of the CPS Unit 2.]

O ANSWER: For planning purposes, the scheduled completion date of CPS Unit 2 is 1995.

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STATE OF ILLINOIS )

) SS COUNTY OF MACON )

O LEONARD J. KOCH, being duly sworn, deposes and says that he is Vice-Presideat of Illinois Power Company, one of the Applicants in the proceeding; that he has read O the foregoing Answers of Illinois Power Company to the State of Illinois' First Set of Interrogatories, end that the same are true and correct to the best of his knowledge, O information, and belief.

/

r Leonarc . K6ch l

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SUEJCRIBED and SWORN to before me this .27" day of July, 1981.

D &a mu. M. b'f/

~'

Notary Public l

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S e

ILLINOIS POWER COMPANY 3

By Leonard J . y' ch Vice President 41GNED AS TO OBJECTIONS:

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((Mg- y' -

Peter V. Fazio,>Jr> >

One of the Attorneys for 3 Applicants.

3 J

J Sh'eldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 3 7200 Sears Tower 233 Jouth Wacker Drive Chicago, Illinois 60606 (312) 876-1000 3 Dated: July 27, 1981