ML20033B973
| ML20033B973 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/25/1981 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 8112020534 | |
| Download: ML20033B973 (3) | |
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'gj gV 30 P1:46 ATOMIC SAFETY & LICENSING BOARD M
JECPE'kn IN THE MATTER OF:
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Docket Nos. 50M I" CLEVELAND ELECTRIC ILLUMINATING
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COMPANY [ Perry Nuclear Power Plants )
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i RESPONSE OF SUNFLOWER ALLIANCE, INC., et al., TO APPLICANT'S REQUEST FOR PRODUCTION OF DOCUMENTS I D c.,
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M Sunflower Alliance, Inc., et al., as an intervenor, has. Q g g answered the First Set of Interrogatories propounded to it by Applicant.
In our Answers, we have set forth the documents, reports, books and other publications upon which we have relied in preparing the Answers.
The vast majority of the material upon which we are relying is either Nuclear Regulatory Commission reports or other readily available material.
Sunflower Alliance, Inc., as a group of concerned citizens, does not have the financial capability of xeroxing and sending to all parties in this proceeding copies of all of the reports, documents and books set forth in our Answers.
It seems to Sunflower Alliance, Inc., that this is not necessary inasmuch as the majority, if not all, of the documents set forth in our Answers to Interrogatories are freely available to the public.
However, if Applicant or other parties would aavise Sunflower Alliance, Inc., as to any specific material that is not availa'ble in public form which Applicant would seek to have, Applicant may request of the undersigned that specific material and we will M s
Ii 8112O20534 811125 PDR ADOCK 05000440 G
M provide same.
It is the hope of Sunflower Alliance, Inc., that by way of this response we can preserve our limited financial resources and at the same time comply with the legitimate needs or Applicant as set forth in Applicant's request.
Respectfully subanitted Am4 e Dapiel D. Wilti 7301 Chippewa Road Brecksville, OH 44141 Attorney for Sunflower Alliance',
Inc., et al.
PROOP OF SERVICE A copy of this Answer to Request for Production of Documents has been sent to all those persons listed on the attached service list by First Class Mcil, postage pre-paid, on this 47 day of November, 1981.
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Daniel /D. Wilt I
l Attorney for Sunflower Alliance, Inc., et al.
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i SERVICE LIST
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Peter B. Bloch, Chairman Dr. Jerry R. Klein Atomic Safety & Licensing Board Atomic Safety & Licensing Board 1
Nuclear Regulatory Commission Nuclear Regulatory Commission j
Washington, D.C.
20555 Washington, D.C.
20555 1
Frederick J. Shon Jay Silberg, Esq.
Atomic Safety & Licensing Board 1800 M Street N.W.
Nuclear Regulatory Commission Washington, D.C.
20036 Washington, D.C.
20555 Donald T. Ezzone, Esq.
Daniel J. Herron, Esq.
Assistant Prosecuting Attorney Assistant Prosecuting Attorney i
105 Main Street Ashtabula County Courthouse J
Painesville, Ohio 44077 Jefferson, Ohio 44047 Tod J. Kenney Jeff Alexander 228 Soouth College St.
Apt. A 920 Wilmington Ave. -
Bowling Green, Ohio 43402 Dayton, Ohio 45420 Terry Lodge, Esq.
Robert Alexander 915 Spitzer Bldg.
2030 Portsmouth St. Apt. 2 Toledo, Ohio 43604
' Houston, Texas 77098 Atomic Safety & Licensing Appeal Board Docketing & Service Section Nuclear Regulatory C6mmission Office of the Secretary
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Washington, D.C.
20555 Nuclear n.3ulatory Commission Washington, D.C.
20555 Charles Barth, Esq.
Nuclear Regulatory Commission Washington, D.C.
20555 i
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