ML20054C687

Fourth Discovery Progress Rept Per ASLB 810909 Memorandum & order,LBP-81-35.Certificate of Svc Encl

ML20054C687
Person / Time
Site:	Perry
Issue date:	04/15/1982
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
References
LBP-81-35, NUDOCS 8204210503
Download: ML20054C687 (3)

Text

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- e April 15, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION Before the Atomic Safety and Licensine Board

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In the Matter of )

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, Et A1. ) 50 441

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(Operating[LicenWh'/j' (Perry Nuclear Power Plant, Units 1 and 2)

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. o n '6M OCRE' S FOURTH DISCOVERY PROGhESS REPORT ' d j'

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) WQj[g:P *^ L the directives of the Atomic Sa N'tysand Pursuant to v7 -

27TTie Licensing Board's September 9, 1981 Memorandum and Oraer, LSP-81-35, 14 NHC 682, 689 (1981), Ohio Citizens for Re-sponsible Energy ("0CRE") hereby files its fourth progress report on discovery activities.

In the past two months, OCRE has received:

1. Applicants' answers to OCHE's first set of interrogatories, with the documents and resumes listed in the Appendix to said answers (dated March 17, 1982), and a corrected response, dated March 25, 1982, to same.

2. NRC Staff answers to OCHE's second set of interrogatories, with the documents listed in Appendix B to said answers (dated March 24, 1982).

Both of these sets of interrogatories dealt with Issue #7, on clam biofouling. 3 OChE has not propounded any discovery requests in the ['5 past two months. Very shortly, CCRE will file interrogatories f/O to both Staff and Applicants concerning Issue #5, s cram dis-charge volume pipe break. OCRE may' request', pursuant to 10 CFR 2.741, the opportunity to inspect the scram discharge 8204210503 020415 PDR ADOCK 05000440 G PDR

volume at the Perry site, depending on the answers received to said interrogatories.

The above details OCRE's discovery activities on those issues for which OCRE is lead intervenor. In addition, the undersigned OCRE Interim Representative participa:ed in a conference call with counsel for Sunflower Alliance and counsel for Applicants on March 29, 1982 in an attempt to resolve controversy surrounding interrogatories and requests for production of documents involving the remaining issues, for which OCRE is not lead intervenor. The resolution of said matters is being pursued by Sunflower Alliance, the lead intervenor.

Respectfully submitted, g.%$<M l Y YW Susan L. Hiatt OCHE Interim Representative 8275 Munscn Rd.

Mentor, OH 44060 (216) 255-3158

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing OCRE'S FOURTH DISCOVERY PROGRESS hEPORT were served by deposit in the U.S. Mail, first class, postage prepaid, this 15th day of April, 1982 to those on the Service Lis; below.

e Susan L. Hiatt i

SERVICE LIST Peter B. Bloch, Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 i Dr. Jerry R. Kline-Atomic Safety & Licensing Board -3 U.S. Nuclear Regulatory Comm'n '"

Washington, D.C. 20555 -

l Frederick J. Shon -

2 l- Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n  ;

Washington, D.C. 20555 1

f Docketing & Service Section

! Office of the Secretary j U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 James Thessin. , Esq.

Office of the Executive 4

Legal Director U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq.

1800 M Street, N.W.

l Washington, D.C. 20036 3 Daniel D. Wilt, Esq.

i 7301 Chippewa Rd.

Brecksville, OH 44141 i Atomic Safety and Licensing Appeal Boarc Panel

! U.S. Nuclear Regulatory Commission j a s hingt on, D . C . 20555 t

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