ML20008G168

First Set of Interrogatories Directed to Util.Notice of Svc Encl.Related Correspondence

ML20008G168
Person / Time
Site:	Clinton
Issue date:	06/26/1981
From:	Willman P ILLINOIS, STATE OF
To:	ILLINOIS POWER CO.
Shared Package
ML20008G169	List: ML20008G168 ML20008G172
References
ISSUANCES-OL, NUDOCS 8107020385
Download: ML20008G168 (17)

Text

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i NUCLEAR REGULATORY COMMISSION g N./pg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD e,

,p-NI s 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) )

THE STATE OF ILLINOIS' FIRST SET OF INTERROGATORIES TO ILLINOIS POWER COMPANY The State of Illinois (Illinois) hereby serves its First Set of Interrogatories to Illinois Power Company (IP),

pursuant to 10 C.F.R. 52.740b. Each interrogatory must be answered fully in writing, under oath or affirmation, and must include all relevant information known to IP. Each answer must clearly indicate the interrogatory to which it responds. Pursuant to 10 C.F.R.

S2.740(e) IP must supplement responses to interrogatories under certain circumstances when new or different information becomes

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available. If IP cannot answer one or more of the interrogatories j

in full, after exercising due diligence, state so and answer to the extent possible, specifying the inability to answer the remainder and stating when IP expects to be able to answer the unanswered portions. s 6I Ik/f3

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DEFINITIONS

1. "BWR" refers to the General Electric Company boiling-water reactor, Mark III.

2. " CPS" refers to the Clinton Power Station, Units 1 and 2.

3. " Document" means all written or recorded material of any kind or character known to IP or in its possession, custody, or control, including, but not limited to, correspondence, letters, telegrams, memoranda, notes, records, minutes, contracts, agreements, records, studies, pamphlets, books, articles, treatises, records or notations of personal conversations or conferences, inter-offico communications, micro-film, bulletins, circulars, blue prints, plans, drawings, photo-graphs, teletype messages, invoices, tape recordings, and work-sheets.

4. " Identify", when used with respect to a document, means to state its date, author, addressee, type of document, present location and custodian, and brief description of its contents.

If any such document was, but is no longer, in IP's custody, control,or possession state what disposition was made of it.

5. " Identify", when used with respect to a person, means to state his or her full name, business or home address, and occupation or position.

6. " Person" means an individual, partnership, firm, company, corporation, association, political sub-division, governmental agency, or any other legal entity, or its legal representative, agent or assign. ' - * -

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INTERROGATORIES

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;

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

d. the training, of any kind, each person will receive subsequent to hiring 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 sub-sequent to assumption of the duties for which he or she was hired; and

. f. a description of the duties and responsibilites.

2. Identify and specify the qualifications of all persons 4

who are now or will be assigned to any safety-related supervisory,

-control or maintenance duties at the CPS, and state the position each person is or will be holding.

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3. Identify all persons IP has employed in Quality Assurance (QA) and Quality Control (QC) 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; and

d. the reason (s), if applicable and known to IP, for termination of employment.

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

a. the management of QA/QC functions at the CPS;

b. the quality of QA/QC work at the CPS; and

c. the reason (s) for the termination of employment e of any person in QA/QC positions.

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

! a. the management of the construction of the safety-l related systems of the CPS; l

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b. the quality or integrity of work on the construc-tion of the safety-related systems of the CPS; and

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

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6. Identify all persons who prepared the Final Safety

. Analysis Report (FSAR) for the. CPS, and for each of the following

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parts of the FSAR identify all persons whose data, studies, reports, comments or other information were used in the preparation thereof:

a. Volume 16, Chapter 13, Section 13.1, "Or.ganiza-tional Structure of Applicant";

b. Volume 16, Chapter 13, Section 13.2, " Training";

c. Volume 18, Chapter 17, " Quality Assurance"; and

d. Volume 15, Chapter 11, Section 11.2.1.4, " Quality l

j Control."

l 7. State, both in terms of percentage and total outlay,

! the capital investment of each of IP, Western Illinois Power Cooperative, Inc. ("WIPCO"), and Soyland Power Cooperative, Inc.

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('Soyland") in the CPS Unit 1,both to date and the estimated final l

total investment.

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

9. State the percentage of the total assets of IP that CPS Unit 1 will represent when operation is commenced.

10. State the current total electrical generating capacity of IP.

11. State the estimated electrical generating capacity l

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of CPS Unit 1 when operation is commenced.

12. State the percentage of the total electrical genera-ting capacity of IP that CPS Unit 1 will represent when operation j

is commenced.

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

14. State the percentage of the total electrical generating capacity of Soyland that CPS Unit I will represent when operation is commenced.

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

16. State IP's anticipated load factor when operation of CPS Unit 1 is commenced.

17. For the fiscal year 1980, state the amount, if any, of electricity IP sold to other utilities,as well as the revenue derived by IP from such sales.

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 expected to be derived by IP from such sales.

19. State the estimated annual costs of operating CPS Unit 1, inc.uding figures for estimated repairs and maintenance.

20. State the estimated total cost of decommissioning CPS Unit 1 at the end of its expected useful life, and state the estimated cost of each of the tasks involved in that decommissioning.

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21. State the estimated total cost of maintaining CPS Unit 1 in a' safe condition after CPS Unit 1 has been decommissioned, and state the estimated cost of each of the tasks involved in that maintenance program.

22. Identify all documents referring to or discussing any of the matters raised in Interrogatories Nos. B , 20 or 21 above.

23. Identify the principal financial officers of IP.

24. Identify all persons, including financial officers, who supervised the preparation of IP's latest annual statement.

25. Identify all persons, including financial offic.ers, who supervised the preparation of IP's proposal to the Illinois Commerce Commission in the proceeding captioned Illinois Power Co.,

Proposed General Increase in Electric Rates, 80-0544 and 8d-0365.

l 26. Identify the principal financial officers of WIPCO.

27. Identify all persons, including financial officers, who supervised the preparation of WIPCO's latest annual statement.

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28. Identify the principal officers of Soyland.

29. Identify all persons, including financial officers, who supervised the preparation of Soyland's latest annual statement.

30. State each anticipated transient without scram (ATNS) condition that IP has considered and will consider with respect to n .Jc ;i,A, Je . . . , , , - --  ;# .

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the operation of the CPS. For each ATWS condition so stated identify the following:

a. the ASME class into which the condition falls;

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

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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:

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a. state the assumed rate of occurrence per reactor year;

. b. describe the results and conclusions;

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c. identify all documents related to, referring to, or l

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discussing the analysis or assessment; and l

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.

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

a. describe how it will work;

b. identify all documents referring to, related to or discussing the measure; and

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

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.

34. Identify all persons who were and are responsible for the management, review, or inspection of welding during con-struction of the control rods and control rod Clive tubes at the CPS.

35. Identify all persons who have performed and are now performing the tasks of welding ,during construction of the contr'ol rods and control rod drive tubes at the CPS.

36. Identify all documents referringto, related to, or discussing analyses of the strength and adequacy of the control rods and the control rod drive tubes installed at the CPS.

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.

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

IV.

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

40. State whether IP has complied, or will comply, with the NRC recommendation 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.

41. Describe all. systems that IP has installed, or will

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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 gr.llons per minute;

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

d. identify all documents related to, re:' erring to, or discussing its function and operation; and

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

42. Describe the analysis performed by IP of the seismic qualificationc of the sump flow monitoring, calculation and indica-l I tion devices to be used at the CPS in the reactor coolant pressure

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boundary leakage detection systems. For each analysis performed, identify:

a. all documents related to, ref arring to, or discussing the seismic qualifications for those devices; and

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

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 measure so described, identify:

a. all documents referringto, related to, or discussing such measure; and

b. al'1 persons who are responsible for the implementa-tion of such mbasure. .

44. Describe the measures IP has taken or will take t-account for the lack of accessibility during plant operation to the sump flow conitoring instruments for the drs,rwell equipment and floor drain sumps. For each measure so described, identify:

a. all documents referring to, related to, or discussing such measure; and

b. all persons responsible for the implementation of such measure.

45. State whether the design, analysis and documentation 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 for each area; s  ;

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

b. state the date by which IP intends to achieve compliance; and

c. identify all documents, including correspondance between IP and the NRC, referring to, related to, or discussing the non-compliance.

46. Describe the analytical models used by IP or its suppliers to analyze fuel swelling and flow blockage in the core due to loss-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 descibed in NUREG 0630;

c. describe the computer code for the model;

d. identify all documents related to, referring to,

. or discussing the model, including manuals, dictionaries or machine readable source codes for the model; ,

e. identify all persons who created the model ; and

f. identify all persons who are responsible for running the model.

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47. State whether IP has compared or will compare the models, described in answer to Interrogatory 47, to those in

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NUREG 0630 to determine the accuracy of those models in predicting the degree of swelling in high stress conditions. If so, describe the results of that comparison and identify:

a. all documents related to, referring to, or liscussing this comparison; and

b. all persons who were responsible for making the comparison.

48. State IP's position on the adequacy.of the straight i

line approximation used in the GE model in NUREG 0630 in meeting

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the requirements of 10 C.F.R. 50, Appendix K.

. 49. Describe IP's justification for the position stated in answer to Interrogatory 48, and state the nature of and scheddle for additional connections and analyses, if any.  ;

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

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

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a, normal transfer of fuel bundles through the tube;

b. off-normal occurrence of a spent fuel lodging in the tube at a point of access; and

c. worst-case conditions.

52. Describe all analyses of anticipated or possible malfunctions of the spent fuel transfer tube system. For each analysis:

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

b. describe the methods Ip plans to use to correct malfunctions;

c. identify all documents related to, referring to, or discussing the analysis; and

d. all persons who were or are responsible for perfor-ming the analysis.

53. Describe all tests that have been performed or will be performed on the spent fuel transfer tube, and for each test:

a. describe the results;

b. identify all documents related to, referring to, or discussing the test; and

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

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.

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55. State the estimated life, in the number of spent fuel bundle transfers, of the spent fuel trarsfer tube.

56. Explain tne basis for the estimation stated in the answer to Interrogatory 55.

57. State the percentage completion of construction of the CPS Unit 2:

a. as of the date IP filed its operating license application; and

b. as of the date IP answers these Interrogatories.

58. State the date by which IP expects to complete l

construction of the CPS Unit 2.

l Respectfully submitted, l

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• PEOPLE OF THE STATE OF ILLINOIS TYRONE C. FAHNER Attorney General l

State of Illinois l

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OF COUNSEL: BY:

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PHILIP L./WILLMAN REED NEUMAN Assistant Attorney General Assistant Attorney General Environmental Control Division 188 West Randolph Street 500 S. Second Street Suite 2315 Springfield, IL 62701 Chicago, Illinois 60601 (312) 793-2491 DATED: June 26, 1981

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

ILLINOIS POWER COMPANY, )

SOYLAND POWER COOPERATIVE, INC. )

and WESTERN ILLINOIS POWER )

COOPERATIVE, INC. )

) Docket Nos. 50-461 OL

) 50-461 OL (Operating Licenses for Clinton )

Power Station, Units 1 and 2) )

NOTICE TO:

Hugh K. Clark, Esq., Chairman P.O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.

~ Washington, D.C. 20059 , ,

Dr. Oscar H. Paris Atomic Safety and Lice'nsing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard J. Goddard Office of the Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Peter V. Fazio, Jr.

Schiff, Hardin, & Waite 7200 Sears Tower 233 South Wacker Drive l

Chicago, Illinois 60606

( Prairie Alliance P.O. Box 2424 l Station A 1

Champaign, Illinois 61820 1

l Atomic Safety and Licensing Board Panel

! U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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l Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE TAKE NOTICE THAT I have filed with the Secretary of the United States Nuclear Regulatory Commis-sion The State of Illinois' First Set of Interrogatories to Illinois Power C.ompany and the State of Illinois '

First Request for Production of Documents. A copy of -

these documents is attached hereto and hereby served upon you.

PHILIP Lt WILLMAN As:';istant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60601 (312) 793-2491 DATED: June 26, 1981

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