ML20054D560
| ML20054D560 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/16/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8204230134 | |
| Download: ML20054D560 (2) | |
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'2 - a' IN THE UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION w
BEFORE THE ATOMIC SAFETY & LICENSING BOARD f
IN THE MATTER OF:
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Docket Nos. 50-440-OL CLEVELAND ELECTRIC
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50-441-OL ILLUMINATING CO.,
et al.,
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[ Perry Nuclear Power Plant,
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Units 1 and 2]
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0 SUNFLOWER ALLIANCE, INC., et FOURTH DISCOVERY PROGRESS REPORT g.~'
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Pursuant to the Directors of the Atomic Safety 9 Licensing,.['
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Board's Memor andum and Order of September 9, 1981, Sunf owec -
Alliance, Inc., et al.,
hereby files its f ourth progress report on discovery activities.
In the past two months, Sunflower Alliance has received answers from the NRC staff to Sunflower's First Set of Inter rogatories and has received a response from the NRC staff to Sunflower Alliance's first Request for Production of Documents.
Further, Sunflower and counsel for applicant have been attempting j
to resolve applicant's objections to several discovery requests l
filed by Sunflower.
After several conversations with Mr. Silberg, Attorney for applicant, resolution of applicant's objections was not h ad and, therefore, a Motion to Compel Discovery will be filed by Sunflower Alliance within the very near future.
om 4tQ att Sunflower Alliance also has two sets of Interrogatories and a to 00gg
-Recuest for Production of Documents pending.
Counsel for Sunflower o
8g has discussed the matter with counsel f or Lake County and counsel Eo 3
go for Lake County assures counsel for Sunflower that the discovery
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will be completed without the necessity of a Motion to Compel.
ft) 1 DLG However, to date, Lake County Commissioners and Lake County
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JEFOR Disaster Services Agency has not responded.. Therefore, a Motion to Compel Discovery may become necessary.
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Contingent No. 8 has recently been admitted as a contention jTRIC KO.,,
in this proceeding.
Sunflower Alliance, Inc., intendn to file r Pok
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within the next two-month period a discovery request covering the new contention.
In addition, Sunflower Alliance, Inc., intends to file within the next two-month period additional discovery directed to applicant.
s to i Respectfully submitted 3andui B., et qT3 3
'\\ / Ju_ s O /bu'M tivit Daqiel C. Wilt past i 7301 Ch;ppewa Road Brecksville, OH 44141 b the 1 Attorne'; for Sunflower Alliance, Inc., et al.
ies a PROOF OF SERVICE L11anc aflowe A copy of this Fourth Progress Repor: has been sent to all persons on the attached Service List en tais Os day of applic April, 1982.
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Or appl Daniel D. Wilt Attorney f or Sunflower Alliance,
),. ther Inc., et al.
pr'Allh i
pver Al r-Prodjl sed th county amplete Page 2, po date L
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