ML20054E176

Fourth Discovery Progress Rept.Certificate of Svc Encl

ML20054E176
Person / Time
Site:	Perry
Issue date:	04/21/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO.
To:
References
NUDOCS 8204260217
Download: ML20054E176 (5)

Text

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UNITED STATES OF AMERICA , , _ ,

NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 22 l?2 22 fin:52 In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441 o>

) O C (Perry Nuclear Power Plant, ) 4 Units 1 and 2) ) /

RECEIVED

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97 APR 2 31982=.- O APPLICANTS' FOURTH PROGRESS REPORT rsnunmaaramans -

REGARDING DISCOVERY ACTIVITIES mu sween g

st 7

Since Applicants' February 16, 1982, Progress Report, n>

Applicants filed on March 17, 1982, " Applicants' Answers to Ohio Citizens for Responsible Energy First Set of Interrogatories."

On March 29, 1982, counsel for Applicants and Mr. Daniel Wilt, counsel for Sunflower Alliance, Inc. (" Sunflower"), conducted a telephone conference-1/ regarding Sunflower's document dis-covery request of February 24, 1982, as well as Mr. Wilt's letter of March 24, 1982, concerning Applicants' objections to l certain of Sunflower's first round interrogatories. Applicants at that time informed Mr. Wilt that certain of the requested documents do not appear to be within the scope of the admitted contentions, that Applicants are unable to identify some of the requested documents, and that many of the reg .sted docu -

ments are not in Applicants' possession. Mr. Wilt agreed to review certain of the discovery requests as to relevancy and 1/ Ms. Sue Hiatt also participated in the conference in her capacity as advisor to Mr. Wilt.

QS8 820426 0sL/1 6of

identification, and get back to Applicants. As of this time, Mr.

Wilt has not provided the requested clarifications. Applicants anticipate filing their response to the document discovery re-quest within a few weeks. During the March 29, 1982, telephone conference, Applicants informally requested that Ms. Hiatt, as interim representative for Ohio Citizens for Responsible Energy

("OCRE"), make available to Applicants for copying a thesis,

" Population Energetics of the Freshwater Clam Musculium Lacustre," identified by OCRE in its responses to Applicants' discovery requests on Contention #7 (Asiatic clams). Ms. Hiath has not yet made the document available.

Applicants also expect to file in the near future additional discovery requests on Sunflower with regard to Contention #4 (ECCS),and may file discovery with regard to Contention #8 (hydrogen generation).

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

/

d By: 'r Jay E. Silberg Robert L. Willmore Counsel for Applicants 1800 M Street, N. W.

Washington, D. C. 20036 DATED: April 21, 198;

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UNITED STATES OF AMERICA NUCLEAR REGULATORY. COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2) )

A'PPLICANTS' FOURTH PROGRESS REPORT REGARDING DISCOVERY ACTIVITIES This is to certify that copies of the foregoing " Applicants' Fourth Progress Report Regarding Discovery Activities", were served by deposit in the U.S. Mail, first class, postage prepsid, 4

this 21st day of April, 1982, to all those on the attached Service List.

/

Robert L. Willmore Dated: April 21, 1982 e

e

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440

' ILLUMINATING COMPANY, e_t _a_l.

) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and 2 )

. SERVICE LIST Pcter B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Frederick J. Shon James H. Thessin, Esquire Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

' N Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Wcshington,.D.C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing Wegman, Hessler & Vanderburg Appeal Board Suite 102 U.S. Nuclear Regulatory Commission 7301 Chippewa Road Washington, D.C. 20555 Brecksville, Ohio 44141 Gary J. Edles, Esquire Terry Lodge, Esquire Atomic Safety and Licensing 915 Spitzer Building Appeal Board Toledo, Ohio 43604 i

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 _. .

1 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 L

l Tha C'leveland Electric Illuminating Company, et al.

Sarvice List Page Two ,

Donald.T. Ezzone, Esquire A20istant Prosecuting Attorney Lake County Administration Center 105 Center Street Painesville, Ohio 44077 John G. Cardinal, Esquire Prosecuting Attorney Achtabula County Courthouse Jafferson, Ohio 44047 9

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