ML20054D560

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Fourth Discovery Progress Rept Per ASLB 810909 Memorandum & Order.Proof of Svc Encl
ML20054D560
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 04/16/1982
From: Wilt D
SUNFLOWER ALLIANCE, WILT, D.D.
To:
References
ISSUANCES-OL, NUDOCS 8204230134
Download: ML20054D560 (2)


Text

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IN THE UNITED STATES OF AMERICA '2 - a' n- n . .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD w

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IN THE MATTER OF: )

) Docket Nos. 50-440-OL CLEVELAND ELECTRIC ) 50-441-OL ILLUMINATING CO., et al., ) *

[ Perry Nuclear Power Plant, ) Q Units 1 and 2] )

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SUNFLOWER ALLIANCE, INC., et al . A[ 3 1hy.,p 0 3 '

FOURTH DISCOVERY PROGRESS REPORT i g.~' d -- ,

5, gl[% .ll$.lj 1 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.

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4tQ att Sunflower Alliance also has two sets of Interrogatories and a '

to 00 gg -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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DLG will be completed without the necessity of a Motion to Compel. ft) 1 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.

HOF l Contingent No. 8 has recently been admitted as a contention ,

jTRIC Sunflower Alliance, Inc., intendn to file KO . , , in this proceeding. ,

r Pok within the next two-month period a discovery request covering the

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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 3

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tivit '\ / Ju_ s O /bu'M Daqiel C. Wilt past i 7301 Ch;ppewa Road Brecksville, OH 44141 b the 1 Attorne'; for Sunflower Alliance, Inc., et al.

ies a L11anc PROOF OF SERVICE 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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Daniel D. Wilt

), . ther Attorney f or Sunflower Alliance, Inc., et al.

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pver Al r-Prodjl sed th ,

county amplete Page 2, po date L_ -. __ k

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