ML20049H853

Discovery Progress Rept.Applicant Responses to First Set of Interrogatories Received.Second Set of Interrogatories Directed to Applicant to Be Sent Shortly.Proof of Svc Encl. Related Correspondence

ML20049H853
Person / Time
Site:	Perry
Issue date:	02/24/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:
References
ISSUANCES-OL, NUDOCS 8203040328
Download: ML20049H853 (3)

Text

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>% W g \\? I Q ce c es D U3:tC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cmcicie.:sec. f BEFORE THE ATOMIC SAFETY & LICENSING BO C'.[M ' $#'

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IN THE MATTER OF: ) 9g : -

) Docket Nos [.'150 s

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CLEVELAND ELECTRIC ILLUMINATING ) . / 5 0-4 41-OL COMPANY, et al., ) y

[ Perry Nuclear Power Plant Units 1 & 2] ) ') -

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-a ,,o, E 2 SUNFLOWER ALLIANCE DISCOVERY PROGRESS REPORT Id w ~

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Sunflower Alliance, et al., desires to present to the Atom.4 Ng Saf ety & Licensing Board the following report dealing with discover y. Sunflower recently received material from the applicant in response to the First Set of Interrogatories filed by Sunflower to applicant. Sunflower intends to file very shortly a second set t of Interrogatories directed to applicant. It is also conceivable that Sunflower may file a Motion to Compel Discovery if dif ferences between Sunflower and applicant cannot be resolved on matters which applicant has objected to. Sunflower has been discussing the Interrogatories filed with the NRC staf f with James Thessin, Esq. , Attorney for the NRC staf f. The answers which Mr. Thessin intends to file should be filed shortly and sent to Sunflower. Gunflower intends to file a second set of Interrogatories and a Request for Production of Documents directied to the NRC staff in the very near future.

                ' Sunflower recently sent a letter to Donald Ezzone, Attorney W for the Lake County Commissioners and the Lake County Disaster Services Agency in connection with the f ailure of the Lake County I6 Commissioners and the Lake County Disaster Services Agency to respond to the First Set of Interrogatories filed by Sunflower.

8203040328 820224 PDR ADOCK 05000440 Q- PDR

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To d ate, Sunflower has not had a response from Mr. Ezzone. In the event that no response is made, a Motion to Compel Discovery directed to the Lake County Commissioners and the Lake County l Disaster Services Agency will be filed. In add it ion , a second set of Interrogatories directed to the Lake County Commissioners and the Lake County Disaster Services Agency will be filed. Mr. Thessin indicated to the undersigned that the NRC staff may be filing a set of Interrog atories to Sunflower. Thus, the discovery process is still proceeding. Respectfully submitted

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W Dp6iel D. W id t" l 7301 Chippewa Road Brecksville, OH 44141 l (216) 526-2350 L Attorney for Sunflower Alliance

PROOF OF SERVICE A copy of this report has been sent to a those persons listed on the attached Service List on this t, day of February, l 1982. (

i l Qcal Dep el D. Wtlt e h+ Attorney for Sunflower Alliance l l l 1 Page 2

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, - 2> SERVICE LIST Peter B. Bloch, Chairman Dr. Jerry R. Klein Atomic Safety & Licensing Board Atomic Safety & Licensing Boar 6 Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, D.C. 20555 - Washington. D.C. 20555 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 1 Donald T. Ezzone, Esq. Daniel J. Herron, Esq. Assistant Prosecuting Attorney Assistant Prosecuting Attorney 105 Main Street Ashtabula County Courthouse

• Painesville, Ohio 44077 Jefferson, Ohio 44047 ',

Tod J. Kenney Jeff Alexander 228 Scouth 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 j Atomic Safety & Licensing Appeal Board Docketing & Service Section f Nuclear Regulatory Cammission Office of the Secretary Washington, D.C. 20555 Nuclear Regulatory Commission Washington, D.C. 20555 i Charles Barth, Esq. i Nuclear Regulatory Commission R Washington, D.C. 20555 l Q l C'h j y' 4 s naen ,j 04 4 g' 9- - MARY 1982% Q { G k ren,dc'tu%se,- ' A t ca 1 @ y

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