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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION                                                                                 l l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
IN THE MATTER OF                                                     )
IN THE MATTER OF
ILLINOIS POWER COMPANY,                                               )
)
SOYLAND POWER COOPERATIVE,INC.                                       )
ILLINOIS POWER COMPANY,
and WESTERN ILLINOIS POWER                                           )
)
COOPERATIVE, INC.                                                     )     Docket Nos. 50-461 OL
SOYLAND POWER COOPERATIVE,INC.
                                                                                                )                             50-462 OL (Operating Licenses for Clinton                                       )
)
Power Station, Units 1 and 2)                                         )
and WESTERN ILLINOIS POWER
)
COOPERATIVE, INC.
)
Docket Nos. 50-461 OL
)
50-462 OL (Operating Licenses for Clinton
)
Power Station, Units 1 and 2)
)
FIRST SET OF INTERROGATORIES BY APPLICANTS TO INTERVENOR Illinois Power Company ("IP"), Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. (collecti rely " Applicants"),
FIRST SET OF INTERROGATORIES BY APPLICANTS TO INTERVENOR Illinois Power Company ("IP"), Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. (collecti rely " Applicants"),
by their attorney, Peter V. Fazio, Jr., and pursuant to Section 2.740b of the Rules of Practice of the Nuclear Regulatory Commission ("NRC"),
by their attorney, Peter V. Fazio, Jr., and pursuant to Section 2.740b of the Rules of Practice of the Nuclear Regulatory Commission ("NRC"),
propound the following interrogatories to the Intervenor to be answered fully and separately in writing and under oath, the answers to be served
propound the following interrogatories to the Intervenor to be answered fully and separately in writing and under oath, the answers to be served
* upon Applicants within four weeks after receipt hereof, but not later than July 27,1981.
* upon Applicants within four weeks after receipt hereof, but not later than July 27,1981.
I.           Definitions
I.
: 1. " Identification" or identify", when referring to a document, shall mean to set forth the author (s) or originator (s), addressee (s), date, title, a brief description of the form of the document (e.g., letter, memoran-dum, tape recording, etc.) and of its subject matter, the present custodian
Definitions
              -            of the original and of any copies thereof, and the current or last known address of each such custodian. Alternatively, identification may be made by production of such documents for inspection and copying.
: 1. " Identification" or identify", when referring to a document, shall mean to set forth the author (s) or originator (s), addressee (s), date, title, a brief description of the form of the document (e.g., letter, memoran-dum, tape recording, etc.) and of its subject matter, the present custodian of the original and of any copies thereof, and the current or last known address of each such custodian. Alternatively, identification may be made by production of such documents for inspection and copying.
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: 2. " Identification" or " identify", when referring to communi-cetion other than a document, shall mean to (a) set forth the form of the communication - e.g. face to face meeting, telephone conversation, radio, etc. -(b) identify by whom and to whom each such communication was
: 2. " Identification" or " identify", when referring to communi-cetion other than a document, shall mean to (a) set forth the form of the communication - e.g. face to face meeting, telephone conversation, radio, etc. -(b) identify by whom and to whom each such communication was
(                     made, (c) set forth the date it was made, the place at which it was made, and the substance thereof, and (d) identify each of the persons party to, or present during, any part of the communication, state where each parti-I                      cipant in the communication was located at the time of the communication, and state what was said in the communication by each participant therein.
(
: 3. " Identification" or " identify", when referring to a person                                                                                                                       ,
made, (c) set forth the date it was made, the place at which it was made, and the substance thereof, and (d) identify each of the persons party to, or present during, any part of the communication, state where each parti-cipant in the communication was located at the time of the communication, I
!                      or individual, shall mean to set forth the full name, present or last known I
and state what was said in the communication by each participant therein.
: 3. " Identification" or " identify", when referring to a person or individual, shall mean to set forth the full name, present or last known I
residence address and telephone number of such person, the present or l
residence address and telephone number of such person, the present or l
l last known business address and telephone number of such person, employer and job title of the individual, and relationship to the Intervenor.
l last known business address and telephone number of such person, employer and job title of the individual, and relationship to the Intervenor.
: 4. " Identification" or " identify", when referring to a corpora-tion or other business entity shall mean to set forth its complete name and principal place of business.
: 4. " Identification" or " identify", when referring to a corpora-tion or other business entity shall mean to set forth its complete name and principal place of business.
!                                                  5. " Document" shall mean documents and other tangible l
: 5. " Document" shall mean documents and other tangible l
l things and shall include without limitation, any written, printed, typed, l
things and shall include without limitation, any written, printed, typed, l
or other graphic matter of any kind or nature, including all originals and non-identical copies, any mechanical and electonic sound recordings (tape, disc, belt or any other type) or transcripts of such recordings, any letters, correspondence, memoranda, minutes, notes, telegrams (TWX, Telex, Cable-                                                                                                                                       ,
l or other graphic matter of any kind or nature, including all originals and non-identical copies, any mechanical and electonic sound recordings (tape, disc, belt or any other type) or transcripts of such recordings, any letters, correspondence, memoranda, minutes, notes, telegrams (TWX, Telex, Cable-grams, Mailgrams or other types), pamphlets, publications, books, photor-graphs, reports, charts, papers, and uny other writings, printed and/or,.,,.
grams, Mailgrams or other types), pamphlets, publications, books, photor-graphs, reports, charts, papers, and uny other writings, printed and/or
y 3 f;,c ; 'n n >..
                                                                                                                    ~*2                        .,,,,        :,                                                                                    y 3 ,,;
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., - - -. - - ~. -... - - - -. - -, -
  --.    ,                        .. ~ . - - - - , ,                  - - . . - - - - . . , - . . - - . - - - - - , , - - - . . - - - . . . . , _ , -                                . , - - - . - - ~ . - . . . - - - - . - - , -


l typewritten matter, including drafts, together with all copies of said dccu-ments by whatever means made, produced or reproduced, known to, or in the custedy, care, possession or under the control of, any officer, direc-tor, consultant, member, agent, attorney, or representative of the Inter-venor. However, identification of duplicate copias of the same document is requested only if the original or copies contain some material, handwritten or otherwise, that is not on the other copies of the original.
l typewritten matter, including drafts, together with all copies of said dccu-ments by whatever means made, produced or reproduced, known to, or in the custedy, care, possession or under the control of, any officer, direc-tor, consultant, member, agent, attorney, or representative of the Inter-venor. However, identification of duplicate copias of the same document is requested only if the original or copies contain some material, handwritten or otherwise, that is not on the other copies of the original.
: 6. "Second Special Prehearing Conference Order" shall mean that Second Snecial Prehearing Conference Order entered on May 29,
: 6. "Second Special Prehearing Conference Order" shall mean that Second Snecial Prehearing Conference Order entered on May 29, 1981 bJ' the Atomic Safety and Licensing Board of the Nuclear Regulatory
                                                                ~
~
1981 bJ' the Atomic Safety and Licensing Board of the Nuclear Regulatory Commission,In the Matter of Blinois Power Company, Docket Nos. 50-461 OL and 50-462 OL.
Commission,In the Matter of Blinois Power Company, Docket Nos. 50-461 OL and 50-462 OL.
: 7. "Intervenor" shall mean that party, the Prairie Alliance, et al., granted leave to intervene in this proceeding according to the Second Special Prehearing Conference Order.
: 7. "Intervenor" shall mean that party, the Prairie Alliance, et al., granted leave to intervene in this proceeding according to the Second Special Prehearing Conference Order.
: 8. " Person" or " individual" shall mean any natural person, ccrporation, partnership, agency, association or other entity, and includes i                       the plural
: 8. " Person" or " individual" shall mean any natural person, ccrporation, partnership, agency, association or other entity, and includes i
: 9. "And" or "or" shall be construed conjunctively and disjunc-l l                      tively so as to require the broadest possible answers to any particular i
the plural
interrogatory.
: 9. "And" or "or" shall be construed conjunctively and disjunc-l tively so as to require the broadest possible answers to any particular l
i                                                   10. " Contention" followed by numericalidentification shall l
i interrogatory.
i
: 10. " Contention" followed by numericalidentification shall l
mean that contention correspondingly numbered and set forth in Appendix A to the Second Special Prehearing Conference Order.
mean that contention correspondingly numbered and set forth in Appendix A to the Second Special Prehearing Conference Order.
1 l
1 l
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,,,. b., x, m.
_,        . . . , . . . . _ . . _ _        _..,____.,_..--.__,_._.__..1.___,           _ _ . . , , . - . . _ . . _ _ . . . _ , . . _ _ _ . . _ . . _ .    , . . . _ .
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                      . _ .                          . . - .                                      = _ _ _
= _ _ _
II.           Claim of Privilege If Intervenor refuses to answer any interrogatory or part thereof on claim of attorney-client privilege, attorney work product, or any other alleged privilege, Intervenor shall identify, to the extent con-sistent with its claim, the document or communication claimed to b.s prie leged and state why the document or communication is privileged. If the privilege claimed is the attorney-client privilege, identify the attorney, the client, and all persons to whom the substance of the document or commu-nication is known. If the privilege claimed is work product, identify the attorney who performed the work.
II.
III.         Interrogatories A.     General                                       ,
Claim of Privilege If Intervenor refuses to answer any interrogatory or part thereof on claim of attorney-client privilege, attorney work product, or any other alleged privilege, Intervenor shall identify, to the extent con-sistent with its claim, the document or communication claimed to b.s prie leged and state why the document or communication is privileged. If the privilege claimed is the attorney-client privilege, identify the attorney, the client, and all persons to whom the substance of the document or commu-nication is known. If the privilege claimed is work product, identify the attorney who performed the work.
III.
Interrogatories A.
General
: 1. Identify the person or persons signing the answers to these interrogatories on behalf of the Intervenor.
: 1. Identify the person or persons signing the answers to these interrogatories on behalf of the Intervenor.
: 2. Identify every person who participated in any way in the preparation of any answer or partial answer to each interrogatory set forth below and describe fully the substance of each person's partici-l l
: 2. Identify every person who participated in any way in the preparation of any answer or partial answer to each interrogatory set forth below and describe fully the substance of each person's partici-l l
pation.
pation.
B.     Interrogatories Applicable to All Contentions To the extent not answered in response to specific interroga-tories relating to a particular contention, Intervenors should answer Interro-gatory Number 3 through Interrogatory Number 11, contention by centen-l
B.
!              tion, for all contentions admitted by the Atcmic Safety and' Licensing Board in the Second Special Prehearing Confe ence Order, labeling each set of ans'rers to Interrogatory Number 3 through Interrogatory Number W>
Interrogatories Applicable to All Contentions To the extent not answered in response to specific interroga-tories relating to a particular contention, Intervenors should answer Interro-gatory Number 3 through Interrogatory Number 11, contention by centen-l tion, for all contentions admitted by the Atcmic Safety and' Licensing Board in the Second Special Prehearing Confe ence Order, labeling each set of ans'rers to Interrogatory Number 3 through Interrogatory Number '
l-        ., a e           .  ,.,.    , . , - .            %.                  , . , ,      .,.        : - ,      ,  ,
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4 11 with the number of the contention to which that particular set of answers applies.
4 11 with the number of the contention to which that particular set of answers applies.
Line 87: Line 108:
: 4. Identify by sectica, subsection, paragraph and exact state-ment in each statute, rule, regulation, decision, or order, the requirement or requirements allegedly violated by reason of the facts set forth in response to Interrogatory No. 3 or the other interrogatories applicable to the conten-tion.
: 4. Identify by sectica, subsection, paragraph and exact state-ment in each statute, rule, regulation, decision, or order, the requirement or requirements allegedly violated by reason of the facts set forth in response to Interrogatory No. 3 or the other interrogatories applicable to the conten-tion.
: 5. Identify all documents and communications upon which the Intervenor relles to establish each of the facts which support each contention, and identify the part or parts of each such document or com-munication relied upon to establish such fact.
: 5. Identify all documents and communications upon which the Intervenor relles to establish each of the facts which support each contention, and identify the part or parts of each such document or com-munication relied upon to establish such fact.
: 6. Identify any individual whom the Interyenor plans to call f             to testify to any of the facts or allegations which support each contention 1
: 6. Identify any individual whom the Interyenor plans to call f
!            and the qualification of such individual.
to testify to any of the facts or allegations which support each contention 1
and the qualification of such individual.
: 7. Summarize the facts and evidence to which each of the individuals named in the answer to Interrogatory No. 6 is expected to testify.
: 7. Summarize the facts and evidence to which each of the individuals named in the answer to Interrogatory No. 6 is expected to testify.
: 8. Identify each and every document from which any indi-l vidual named in the Intervenor's answer for each contention to Interrogatory No. 6 is expected to testify, whether such document be made by him, used by him in preparation of his testimony, or introduced as an exhibit at the evidentiary hearing.
: 8. Identify each and every document from which any indi-l vidual named in the Intervenor's answer for each contention to Interrogatory No. 6 is expected to testify, whether such document be made by him, used by him in preparation of his testimony, or introduced as an exhibit at the evidentiary hearing. '
l H        -          .      ,,n    ,    4 o:,     '
4 o:,
I           n.                                 ..  ..., , , , . -
I n.
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: 9. Identify any and all exhibits which the Intervenor plans to submit into evidence at the hearing to prove the facts which sut. port each contention.
: 9. Identify any and all exhibits which the Intervenor plans to submit into evidence at the hearing to prove the facts which sut. port each contention.
: 10. Identify the section, page number and exact statement in each volume of Applicants' Final Safety Analysis Report ("FSAR"), Envi-ronmental Report or other document prepared or supplied by IP which any individual called upon to testify by the Irtervenor is expected to chal-lenge, callinto question, rebut, deny or refute with respect to each con -
: 10. Identify the section, page number and exact statement in each volume of Applicants' Final Safety Analysis Report ("FSAR"), Envi-ronmental Report or other document prepared or supplied by IP which any individual called upon to testify by the Irtervenor is expected to chal-lenge, callinto question, rebut, deny or refute with respect to each con -
tention or which the Intervenor at present challenges, calls into gr tion, denies, rebuts or refutes with respect to each contention.
tention or which the Intervenor at present challenges, calls into gr tion, denies, rebuts or refutes with respect to each contention.
i                                                   11. Summarize the facts 'ind identif feach person and docu-ment ralled upon to prove each of the facts which the Intervenor contends rebuts any of the state nents contained in any of the documents described in Interrogatory No.10.                                                                                                      .
i
l                                   C.                 Contention No.1,
: 11. Summarize the facts 'ind identif each person and docu-f ment ralled upon to prove each of the facts which the Intervenor contends rebuts any of the state nents contained in any of the documents described in Interrogatory No.10.
: 12. Identify those " problems"in Contention No.1(a)(1) which Intervenor believes must be considered in the Emergency Plan and explain fully why each identified problem should be considered in the Emergency l                 Plan.
l C.
Contention No.1,
: 12. Identify those " problems"in Contention No.1(a)(1) which Intervenor believes must be considered in the Emergency Plan and explain fully why each identified problem should be considered in the Emergency l
Plan.
: 13. Identify by name and address each "special faellity" l
: 13. Identify by name and address each "special faellity" l
l                referred to Contention No.1(aX2) and identify for each such facility the difficulties posed for which planning has allegedly not been done.
referred to Contention No.1(aX2) and identify for each such facility the l
: 14. With respect to Contention No.1(aX3) identify the degree of severity and the frequency of occurrence of weather conditions for l
difficulties posed for which planning has allegedly not been done.
1 which planning has allegedly been inadequate.
: 14. With respect to Contention No.1(aX3) identify the degree l
  . g v.n ; vr* .            .            .,          ..;                        ,        .
of severity and the frequency of occurrence of weather conditions for 1
which planning has allegedly been inadequate. *
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: 15. Identify by name and address the 17 named agencies, local hospitals, and physicians mentioned in Contention 1(b) with which IP has failed to effect meaningful agreements, and describe what terms and conditions must be included in such agreements in order to make them mean!ngful.
: 15. Identify by name and address the 17 named agencies, local hospitals, and physicians mentioned in Contention 1(b) with which IP has failed to effect meaningful agreements, and describe what terms and conditions must be included in such agreements in order to make them mean!ngful.
: 16. With respect to Contention 1(e) identify and explain fully and precisely what details required by NRC regulations are lacking in the Emergency Plan.
: 16. With respect to Contention 1(e) identify and explain fully and precisely what details required by NRC regulations are lacking in the Emergency Plan.
D.                   Contention No. 2
D.
Contention No. 2
: 17. Identify specifically the " numerous other Quality Assur-ance and Quality Control functions" alleged to be deficient.
: 17. Identify specifically the " numerous other Quality Assur-ance and Quality Control functions" alleged to be deficient.
: 18. Fcr each of the Quality Assurance and Quality Control functions identified in Contention No. 2 or in response to Interrogatory No.17, identify by NRC Region III Inspection Report number, date, page number, and exact statement each Q'tality Assurance and Quality Control problem which allegedly raises serious questions as to IP's management
: 18. Fcr each of the Quality Assurance and Quality Control functions identified in Contention No. 2 or in response to Interrogatory No.17, identify by NRC Region III Inspection Report number, date, page number, and exact statement each Q'tality Assurance and Quality Control problem which allegedly raises serious questions as to IP's management and technical capabilities to operate, backfit and shutdown oermanently the Clinton Power Station.
;                      and technical capabilities to operate, backfit and shutdown oermanently the Clinton Power Station.
E.
E.                   Contention No. 3
Contention No. 3
!                                                          19. Identify any and all criteria used by Intervenor to measure the financial capability of IP to operate the Clinton Powe.r Station, explain why such criteria are relevant, and explain how IP f' ails to meet such criteria.
: 19. Identify any and all criteria used by Intervenor to measure the financial capability of IP to operate the Clinton Powe.r Station, explain why such criteria are relevant, and explain how IP f' ails to meet such criteria.
I l                                     F.                   Contention No. 4
I l
F.
Contention No. 4
( Applicants have no specific interrogatories relating to l
( Applicants have no specific interrogatories relating to l
Contention No. 4; however, Intervenor must answer Interrogatory No. 3 2-   n.            . . .                              , L te., ,. , ,             ,,,,,.,.r''- ., .
Contention No. 4; however, Intervenor must answer Interrogatory No. 3 *'-
, L te.,,.,,
,,,,,.,.r''-
2-n.
l
l


through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
G.                       Contention No. 5
G.
: 20. Identify and describe fully those alleged defects which l                       Intervenor believes make the Clinton Power Station "especially vulnerable" to Anticipated Transients Without Scram ("ATWS") and identify how those l
Contention No. 5
: 20. Identify and describe fully those alleged defects which l
Intervenor believes make the Clinton Power Station "especially vulnerable" to Anticipated Transients Without Scram ("ATWS") and identify how those l
defects relate to ATWS.
defects relate to ATWS.
: 21. Explain fitlly in what manner the alleged defects iden-tified in the preceding interrogatory have not been adequately analyzed or repaired and identify by document, section, page number, and exact statement those passages in documents upon which Intervenor relles to show inadequate analysis or repairs.
: 21. Explain fitlly in what manner the alleged defects iden-tified in the preceding interrogatory have not been adequately analyzed or repaired and identify by document, section, page number, and exact statement those passages in documents upon which Intervenor relles to show inadequate analysis or repairs.
: 22. Identify by document, section, page number, and exact statement those current NRC requirem,ents which require an ATWS analysis for (1) redundancy, (2) systems interaction, (3) loss of coolant accident.
: 22. Identify by document, section, page number, and exact statement those current NRC requirem,ents which require an ATWS analysis for (1) redundancy, (2) systems interaction, (3) loss of coolant accident.
: 23. Identify by place, date, and summary of the facts, each ATWS incident in other General Electric boiling water reactors because of which incidents Intervenor alleges Applicants must complete an ATWS analysis
: 23. Identify by place, date, and summary of the facts, each ATWS incident in other General Electric boiling water reactors because of which incidents Intervenor alleges Applicants must complete an ATWS analysis and explain how this experience relates to the Clinton Power Station.
!                        and explain how this experience relates to the Clinton Power Station.
H.
l H.                       Contention No. 6
Contention No. 6 l
: 24. For each subparagraph of Contention No. 6, identify by section, page r, umber, and exact statement, those current NRC require-ments for which the design and fabrication of the Clinton Power Station control room layout and instrumentation has allegedly not been modified.
: 24. For each subparagraph of Contention No. 6, identify by section, page r, umber, and exact statement, those current NRC require-ments for which the design and fabrication of the Clinton Power Station control room layout and instrumentation has allegedly not been modified.
l
l
                                                                                                                                                        .g.
.g.
r            .       , , , , , .. - l ,t c                                             ,          ,,                                              o .. . ~ .    ;, , , . . , , -
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                                                                                                                                                                                            . ,  s -
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: 25. With respect to Contention No. 6(b), identify and explain why the instrumentation for detecting inadequate core cooling in case of an abnormal occurrence is insufficient.
: 25. With respect to Contention No. 6(b), identify and explain why the instrumentation for detecting inadequate core cooling in case of an abnormal occurrence is insufficient.
: 26. With respect to Contention No. 6(d), identify and explain the features of a Safety Parameter Display System which are not provided in the main control room.
: 26. With respect to Contention No. 6(d), identify and explain the features of a Safety Parameter Display System which are not provided in the main control room.
: 27. With respect to Contention No. 6(e), identify and explain why the instrumentation for monitoring accident conditions is inadequate.
: 27. With respect to Contention No. 6(e), identify and explain why the instrumentation for monitoring accident conditions is inadequate.
: 28. With respect to Contention No. 6(f), explain how IP                               -
: 28. With respect to Contention No. 6(f), explain how IP "has not demonstrated its ability to comply with current NRC requirements."
                        "has not demonstrated its ability to comply with current NRC requirements."
: 29. With respect to Contention No. 6(h), identify the instru-ments on back row panels that should be on front row panels, and explain why it is " insufficient" to place such instruments on back row panels.
: 29. With respect to Contention No. 6(h), identify the instru-ments on back row panels that should be on front row panels, and explain why it is " insufficient" to place such instruments on back row panels.
                                                                                                                                                        ~
~
: 30. With respect to Cont.ention No. 6(j), identify the source l                        for the requirement that Applicants must provide documentation showing that the Clinton Power Station can be modified.
: 30. With respect to Cont.ention No. 6(j), identify the source for the requirement that Applicants must provide documentation showing l
i                                    I. Contention No. 7 l
that the Clinton Power Station can be modified.
: 31. With respect to Contention No. 7(a), define fully " worst l
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case seismic activity now known to occur in the site region" and provide l
Contention No. 7 i
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: 31. With respect to Contention No. 7(a), define fully " worst case seismic activity now known to occur in the site region" and provide l
a detailed reference to the source of the definition.
a detailed reference to the source of the definition.
: 32. With respect to Contention No. 7(a), identify by date, distance in miles from the Clinton Power Station site, and magnitude all examples of the worst case seismic activity which allegedly have not been taken into account in the design of the Clinton Power Station.
: 32. With respect to Contention No. 7(a), identify by date, distance in miles from the Clinton Power Station site, and magnitude all examples of the worst case seismic activity which allegedly have not been taken into account in the design of the Clinton Power Station.
: 33. With respect to Contention No. 7(a), identify all evidence                                               ,
: 33. With respect to Contention No. 7(a), identify all evidence which shows that the Clinton Power Station design does not account for the worst case seismic activity now known to occur in the site region.
which shows that the Clinton Power Station design does not account for the worst case seismic activity now known to occur in the site region.
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: 24. With respect to Contention No. 7(b), identify the three                                                                                   .
: 24. With respect to Contention No. 7(b), identify the three federal vector pathways near the site of the Clinton Power Station which Intervenor alleges should be considered in calculating the probability of aircraft impact of the Clinton Power Station containment, and explain fully why these three federal vector pathways should have 5een considered.
federal vector pathways near the site of the Clinton Power Station which Intervenor alleges should be considered in calculating the probability of aircraft impact of the Clinton Power Station containment, and explain fully why these three federal vector pathways should have 5een considered.
J.
J. Contention No. 8
Contention No. 8
( Applicants have no specific interrogatories relating to Contention No. 8; however, Intervenor must answer fully Interrogatory No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
( Applicants have no specific interrogatories relating to Contention No. 8; however, Intervenor must answer fully Interrogatory No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
K. Contention No. 9
K.
Contention No. 9
: 35. With respect to Contention No. 9(a), specify the number and type of monitors necessary to continuously monitor airborne radio-activity, and identify and explain fully why that number is necessary.
: 35. With respect to Contention No. 9(a), specify the number and type of monitors necessary to continuously monitor airborne radio-activity, and identify and explain fully why that number is necessary.
: 36. With respect to Contention No. 9(a), specify the required sensitivity of the monitors, and identify and explain fully why that degree of sensitivity is necessary.
: 36. With respect to Contention No. 9(a), specify the required sensitivity of the monitors, and identify and explain fully why that degree of sensitivity is necessary.
: 37. With respect to Contention No. 9(b), specify the required level of accuracy of the monitors and identify and explain fully why that l
: 37. With respect to Contention No. 9(b), specify the required level of accuracy of the monitors and identify and explain fully why that l
level of accuracy is necessary.
level of accuracy is necessary.
I L. Contention No.10
I L.
: 38. With respect to Contention No.10(a), identify the criteria used to measure proof of " operating capability" and explain how Applicants hsve failed to meet such criteria.
Contention No.10
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: 38. With respect to Contention No.10(a), identify the criteria used to measure proof of " operating capability" and explain how Applicants hsve failed to meet such criteria.,
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: 39. With respect to Contention No.10(b), identify by section, page number, and exact statement, those requirements of 10 CFR Part 50, Appendix K with which the models used to predict ECCS performance are not in compliance and identify and explain fully the manner in which the models used have not been proven accurate.
: 39. With respect to Contention No.10(b), identify by section, page number, and exact statement, those requirements of 10 CFR Part 50, Appendix K with which the models used to predict ECCS performance are not in compliance and identify and explain fully the manner in which the models used have not been proven accurate.
M. Contention tio.11
M.
Contention tio.11
: 40. With respect to Contention No.11(c), identify those current requirements which allegedly have not been adequately assessed and factored into the NEPA cost-benefit analysis for Clinton Units 1 and 2.
: 40. With respect to Contention No.11(c), identify those current requirements which allegedly have not been adequately assessed and factored into the NEPA cost-benefit analysis for Clinton Units 1 and 2.
N. Contention No.12
N.
( Applicants have no specific interrogatories relating to Contention No.12; however,Intervenor must answer fully Interrogatory                                       -                                                    ,
Contention No.12
No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
( Applicants have no specific interrogatories relating to Contention No.12; however,Intervenor must answer fully Interrogatory No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]
                                                                                                                  .../
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                                                                                                        ~%       !n Peter V. Fazio, Jr4 V One of the Attorneys for Applicants Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 30606                                                                                                                                                     ,
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.                    (312) 876-1000 4        -
!n Peter V. Fazio, Jr4 V One of the Attorneys for Applicants Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 30606 (312) 876-1000 M p t.,. y.
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Latest revision as of 02:15, 23 December 2024

First Set of Interrogatories Directed to Intervenor Prairie Alliance Re Contentions 1-12
ML20008G113
Person / Time
Site: Clinton  Constellation icon.png
Issue date: 06/26/1981
From: Fazio P
ILLINOIS POWER CO., SCHIFF, HARDIN & WAITE
To:
PRAIRIE ALLIANCE
Shared Package
ML20008G112 List:
References
ISSUANCES-OL, NUDOCS 8107020283
Download: ML20008G113 (11)
v • d • e


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

IN THE MATTER OF

)

ILLINOIS POWER COMPANY,

)

SOYLAND POWER COOPERATIVE,INC.

)

and WESTERN ILLINOIS POWER

)

COOPERATIVE, INC.

)

Docket Nos. 50-461 OL

)

50-462 OL (Operating Licenses for Clinton

)

Power Station, Units 1 and 2)

)

FIRST SET OF INTERROGATORIES BY APPLICANTS TO INTERVENOR Illinois Power Company ("IP"), Soyland Power Cooperative, Inc., and Western Illinois Power Cooperative, Inc. (collecti rely " Applicants"),

by their attorney, Peter V. Fazio, Jr., and pursuant to Section 2.740b of the Rules of Practice of the Nuclear Regulatory Commission ("NRC"),

propound the following interrogatories to the Intervenor to be answered fully and separately in writing and under oath, the answers to be served

  • upon Applicants within four weeks after receipt hereof, but not later than July 27,1981.

I.

Definitions

1. " Identification" or identify", when referring to a document, shall mean to set forth the author (s) or originator (s), addressee (s), date, title, a brief description of the form of the document (e.g., letter, memoran-dum, tape recording, etc.) and of its subject matter, the present custodian of the original and of any copies thereof, and the current or last known address of each such custodian. Alternatively, identification may be made by production of such documents for inspection and copying.

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2. " Identification" or " identify", when referring to communi-cetion other than a document, shall mean to (a) set forth the form of the communication - e.g. face to face meeting, telephone conversation, radio, etc. -(b) identify by whom and to whom each such communication was

(

made, (c) set forth the date it was made, the place at which it was made, and the substance thereof, and (d) identify each of the persons party to, or present during, any part of the communication, state where each parti-cipant in the communication was located at the time of the communication, I

and state what was said in the communication by each participant therein.

3. " Identification" or " identify", when referring to a person or individual, shall mean to set forth the full name, present or last known I

residence address and telephone number of such person, the present or l

l last known business address and telephone number of such person, employer and job title of the individual, and relationship to the Intervenor.

4. " Identification" or " identify", when referring to a corpora-tion or other business entity shall mean to set forth its complete name and principal place of business.
5. " Document" shall mean documents and other tangible l

things and shall include without limitation, any written, printed, typed, l

l or other graphic matter of any kind or nature, including all originals and non-identical copies, any mechanical and electonic sound recordings (tape, disc, belt or any other type) or transcripts of such recordings, any letters, correspondence, memoranda, minutes, notes, telegrams (TWX, Telex, Cable-grams, Mailgrams or other types), pamphlets, publications, books, photor-graphs, reports, charts, papers, and uny other writings, printed and/or,.,,.

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l typewritten matter, including drafts, together with all copies of said dccu-ments by whatever means made, produced or reproduced, known to, or in the custedy, care, possession or under the control of, any officer, direc-tor, consultant, member, agent, attorney, or representative of the Inter-venor. However, identification of duplicate copias of the same document is requested only if the original or copies contain some material, handwritten or otherwise, that is not on the other copies of the original.

6. "Second Special Prehearing Conference Order" shall mean that Second Snecial Prehearing Conference Order entered on May 29, 1981 bJ' the Atomic Safety and Licensing Board of the Nuclear Regulatory

~

Commission,In the Matter of Blinois Power Company, Docket Nos. 50-461 OL and 50-462 OL.

7. "Intervenor" shall mean that party, the Prairie Alliance, et al., granted leave to intervene in this proceeding according to the Second Special Prehearing Conference Order.
8. " Person" or " individual" shall mean any natural person, ccrporation, partnership, agency, association or other entity, and includes i

the plural

9. "And" or "or" shall be construed conjunctively and disjunc-l tively so as to require the broadest possible answers to any particular l

i interrogatory.

i

10. " Contention" followed by numericalidentification shall l

mean that contention correspondingly numbered and set forth in Appendix A to the Second Special Prehearing Conference Order.

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II.

Claim of Privilege If Intervenor refuses to answer any interrogatory or part thereof on claim of attorney-client privilege, attorney work product, or any other alleged privilege, Intervenor shall identify, to the extent con-sistent with its claim, the document or communication claimed to b.s prie leged and state why the document or communication is privileged. If the privilege claimed is the attorney-client privilege, identify the attorney, the client, and all persons to whom the substance of the document or commu-nication is known. If the privilege claimed is work product, identify the attorney who performed the work.

III.

Interrogatories A.

General

1. Identify the person or persons signing the answers to these interrogatories on behalf of the Intervenor.
2. Identify every person who participated in any way in the preparation of any answer or partial answer to each interrogatory set forth below and describe fully the substance of each person's partici-l l

pation.

B.

Interrogatories Applicable to All Contentions To the extent not answered in response to specific interroga-tories relating to a particular contention, Intervenors should answer Interro-gatory Number 3 through Interrogatory Number 11, contention by centen-l tion, for all contentions admitted by the Atcmic Safety and' Licensing Board in the Second Special Prehearing Confe ence Order, labeling each set of ans'rers to Interrogatory Number 3 through Interrogatory Number '

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4 11 with the number of the contention to which that particular set of answers applies.

3. Identify and explain fully, by section, subsection, and paragraph, the factual basis or bases for each allegation made in each contention.
4. Identify by sectica, subsection, paragraph and exact state-ment in each statute, rule, regulation, decision, or order, the requirement or requirements allegedly violated by reason of the facts set forth in response to Interrogatory No. 3 or the other interrogatories applicable to the conten-tion.
5. Identify all documents and communications upon which the Intervenor relles to establish each of the facts which support each contention, and identify the part or parts of each such document or com-munication relied upon to establish such fact.
6. Identify any individual whom the Interyenor plans to call f

to testify to any of the facts or allegations which support each contention 1

and the qualification of such individual.

7. Summarize the facts and evidence to which each of the individuals named in the answer to Interrogatory No. 6 is expected to testify.
8. Identify each and every document from which any indi-l vidual named in the Intervenor's answer for each contention to Interrogatory No. 6 is expected to testify, whether such document be made by him, used by him in preparation of his testimony, or introduced as an exhibit at the evidentiary hearing. '

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9. Identify any and all exhibits which the Intervenor plans to submit into evidence at the hearing to prove the facts which sut. port each contention.
10. Identify the section, page number and exact statement in each volume of Applicants' Final Safety Analysis Report ("FSAR"), Envi-ronmental Report or other document prepared or supplied by IP which any individual called upon to testify by the Irtervenor is expected to chal-lenge, callinto question, rebut, deny or refute with respect to each con -

tention or which the Intervenor at present challenges, calls into gr tion, denies, rebuts or refutes with respect to each contention.

i

11. Summarize the facts 'ind identif each person and docu-f ment ralled upon to prove each of the facts which the Intervenor contends rebuts any of the state nents contained in any of the documents described in Interrogatory No.10.

l C.

Contention No.1,

12. Identify those " problems"in Contention No.1(a)(1) which Intervenor believes must be considered in the Emergency Plan and explain fully why each identified problem should be considered in the Emergency l

Plan.

13. Identify by name and address each "special faellity" l

referred to Contention No.1(aX2) and identify for each such facility the l

difficulties posed for which planning has allegedly not been done.

14. With respect to Contention No.1(aX3) identify the degree l

of severity and the frequency of occurrence of weather conditions for 1

which planning has allegedly been inadequate. *

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15. Identify by name and address the 17 named agencies, local hospitals, and physicians mentioned in Contention 1(b) with which IP has failed to effect meaningful agreements, and describe what terms and conditions must be included in such agreements in order to make them mean!ngful.
16. With respect to Contention 1(e) identify and explain fully and precisely what details required by NRC regulations are lacking in the Emergency Plan.

D.

Contention No. 2

17. Identify specifically the " numerous other Quality Assur-ance and Quality Control functions" alleged to be deficient.
18. Fcr each of the Quality Assurance and Quality Control functions identified in Contention No. 2 or in response to Interrogatory No.17, identify by NRC Region III Inspection Report number, date, page number, and exact statement each Q'tality Assurance and Quality Control problem which allegedly raises serious questions as to IP's management and technical capabilities to operate, backfit and shutdown oermanently the Clinton Power Station.

E.

Contention No. 3

19. Identify any and all criteria used by Intervenor to measure the financial capability of IP to operate the Clinton Powe.r Station, explain why such criteria are relevant, and explain how IP f' ails to meet such criteria.

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F.

Contention No. 4

( Applicants have no specific interrogatories relating to l

Contention No. 4; however, Intervenor must answer Interrogatory No. 3 *'-

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through Interrogatory No.11 for this contention, as well as for each of the other contentions.]

G.

Contention No. 5

20. Identify and describe fully those alleged defects which l

Intervenor believes make the Clinton Power Station "especially vulnerable" to Anticipated Transients Without Scram ("ATWS") and identify how those l

defects relate to ATWS.

21. Explain fitlly in what manner the alleged defects iden-tified in the preceding interrogatory have not been adequately analyzed or repaired and identify by document, section, page number, and exact statement those passages in documents upon which Intervenor relles to show inadequate analysis or repairs.
22. Identify by document, section, page number, and exact statement those current NRC requirem,ents which require an ATWS analysis for (1) redundancy, (2) systems interaction, (3) loss of coolant accident.
23. Identify by place, date, and summary of the facts, each ATWS incident in other General Electric boiling water reactors because of which incidents Intervenor alleges Applicants must complete an ATWS analysis and explain how this experience relates to the Clinton Power Station.

H.

Contention No. 6 l

24. For each subparagraph of Contention No. 6, identify by section, page r, umber, and exact statement, those current NRC require-ments for which the design and fabrication of the Clinton Power Station control room layout and instrumentation has allegedly not been modified.

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25. With respect to Contention No. 6(b), identify and explain why the instrumentation for detecting inadequate core cooling in case of an abnormal occurrence is insufficient.
26. With respect to Contention No. 6(d), identify and explain the features of a Safety Parameter Display System which are not provided in the main control room.
27. With respect to Contention No. 6(e), identify and explain why the instrumentation for monitoring accident conditions is inadequate.
28. With respect to Contention No. 6(f), explain how IP "has not demonstrated its ability to comply with current NRC requirements."
29. With respect to Contention No. 6(h), identify the instru-ments on back row panels that should be on front row panels, and explain why it is " insufficient" to place such instruments on back row panels.

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30. With respect to Cont.ention No. 6(j), identify the source for the requirement that Applicants must provide documentation showing l

that the Clinton Power Station can be modified.

I.

Contention No. 7 i

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31. With respect to Contention No. 7(a), define fully " worst case seismic activity now known to occur in the site region" and provide l

a detailed reference to the source of the definition.

32. With respect to Contention No. 7(a), identify by date, distance in miles from the Clinton Power Station site, and magnitude all examples of the worst case seismic activity which allegedly have not been taken into account in the design of the Clinton Power Station.
33. With respect to Contention No. 7(a), identify all evidence which shows that the Clinton Power Station design does not account for the worst case seismic activity now known to occur in the site region.

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24. With respect to Contention No. 7(b), identify the three federal vector pathways near the site of the Clinton Power Station which Intervenor alleges should be considered in calculating the probability of aircraft impact of the Clinton Power Station containment, and explain fully why these three federal vector pathways should have 5een considered.

J.

Contention No. 8

( Applicants have no specific interrogatories relating to Contention No. 8; however, Intervenor must answer fully Interrogatory No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]

K.

Contention No. 9

35. With respect to Contention No. 9(a), specify the number and type of monitors necessary to continuously monitor airborne radio-activity, and identify and explain fully why that number is necessary.
36. With respect to Contention No. 9(a), specify the required sensitivity of the monitors, and identify and explain fully why that degree of sensitivity is necessary.
37. With respect to Contention No. 9(b), specify the required level of accuracy of the monitors and identify and explain fully why that l

level of accuracy is necessary.

I L.

Contention No.10

38. With respect to Contention No.10(a), identify the criteria used to measure proof of " operating capability" and explain how Applicants hsve failed to meet such criteria.,

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39. With respect to Contention No.10(b), identify by section, page number, and exact statement, those requirements of 10 CFR Part 50, Appendix K with which the models used to predict ECCS performance are not in compliance and identify and explain fully the manner in which the models used have not been proven accurate.

M.

Contention tio.11

40. With respect to Contention No.11(c), identify those current requirements which allegedly have not been adequately assessed and factored into the NEPA cost-benefit analysis for Clinton Units 1 and 2.

N.

Contention No.12

( Applicants have no specific interrogatories relating to Contention No.12; however,Intervenor must answer fully Interrogatory No. 3 through Interrogatory No.11 for this contention, as well as for each of the other contentions.]

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!n Peter V. Fazio, Jr4 V One of the Attorneys for Applicants Sheldon A. Zabel William Van Susteren Charles D. Fox IV SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 30606 (312) 876-1000 M p t.,. y.

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