ML20062C913
| ML20062C913 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/02/1982 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8208050396 | |
| Download: ML20062C913 (3) | |
Text
1982 D0j,t@ust2, UNITED STATES OF AMERICA i, g
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and LicenslyR,ibpand P1:04 In the Matter of
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6FFf0E OF SECAElMY l
CLEVELAND ELECTRIC ILLUMINATING
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Dock 86fftI[ M M O COMPANY, Et A1.
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id-441
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(Operating License)
(Perry Nuclear Power Plant,
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Units 1 and 2)
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OCRE REPLY TO SUNFLOWER ALLIANCE et al. SECOND MOTION TO EXPAND QUALITY ASSURANCE CONTENTION Pursuant to 10 CFR 2.730(c), Ohio. Citizens for Responsible Energy ("0CRE") hereby responds to the July 21, 1982 Sunflower Alliance et al. Second Motion to 5xpand Quality Assurance Contention.
Intervenor -Sunflower Alliance again ' requests i hat,,
t Issue #3, on QA of construction at the Perry facility, be expanded beyond the artificial limitations imposed by the Licensing Board.
OCRE supports Sunflower's motion and urges that Issue #3 be expanded to include the entire construction QA program at PNPP, from inception of the project until the completion of construction.
Only then can intervenors properly protect their health, safety, and environmental interests, The Licensing Board 8s argument (March 3, 1982 Memorandum l
and Order at 12) that Sunflower Alliance already has the right to discovery on most QA matters would make sense if all parties to this proceeding were participating in good faith and in the interest of full disclosure.
Obviously this is not so.
As Sunflower Alliance has pointed out, parties have continually thwarted discovery on this issue.
Applicants, in particular, have used a narrow interoretation of the wording of this and 8208050396 820802 DRADOCK05000ggg
2 It should be clear to the other issues to evade discovery.
Board by now that certain parties are not participating in this Coercive measures proceeding with the public benefit in mind.
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are therefore nec2ssary to protect the public interest.
The Licensing Board's opinion that this issue is not ripe for decision is undoubtedly due to the fact that the Board, in Washington, DC, is not bombarded with media reports concerning the PNPP QA deficiencies, as are those in the vicinity of Perry.
However, to expect intervenors to base their litigation on
!l newspaper articles (the major source of information now available to them) is contrary to the Board's previous assertions -regarding.
I the propriety of such articles as good cause for late filing
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1982 Memorandum and Order at 4 and March 3, l
(see February 26, 1982 Memorandum and Order at 3).
Furthermore, it is well known that the news media does not always report these items in a
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totally accurate or timely manner.
Quality assurance at PNPP has become a serious concern to l'
As demonstrated by Sunflower's motion, QA deficiencies OCRE.
OCRE thus concludes that are frequent, numerous, and continuous.
expansion of this issue to include any and all violations identified is certainly at PNPP, regardless of the date of occurrence, appropriate.
i This is evidenced by the fact that Applicants finally
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answered Sunflower's QA interrogatories, not shortly after the March 3 Memorandum and Order, but only following Sunflower's Motion to Compel Discovery.
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. Respectfully submitted, W
Susan L. Hiatt OCHE Representative 8275 Munson Rd.
Mentor, OH 44060 (216) 255-3158 CERTIFICATE OF SERVICE This is to certify that copies of the foregoing OCRE REPLY TO SUNFLOWER ALLIANCE et al. SECOND MOTION TO EXPAND QUALITY ASSURANCE CONTENTION were served by deposit in the U.S. Mail, first class, postage prepaid, this 2nd day of August, 1982, to those on the service list below.
SERVICE LIST Peter B. Bloch, Chairman Daniel D. Wilt, Esq.
Atomic Safety and Licensing Board P.O. Bo'x 08159 U.S. Nuclear Regulatory Comm'n Cleveland, OH 44108 Washington, D. C.
20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comm'n Washington, D. C.
20555 Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear. Regulatory Comm'n Washington, D. C.
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C.
20555 Stephen H. Lewis, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Comm'n l
Was hington, D.C.
20555 Jay Silberg, Esq.
1800 M Street, N.W.
Washington, D. C.
20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Wa s hingt on, D.C.
20555
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