ML20063D190
| ML20063D190 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/24/1982 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | SUNFLOWER ALLIANCE |
| References | |
| NUDOCS 8208270506 | |
| Download: ML20063D190 (4) | |
Text
.,
g\\
o80 oC August 24, 1982 Mg&c c
.( E0
~
v;_
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)
)
APPLICANTS' ADDITIONAL ANSWER TO SUNFLOWER ALLIANCE, INC. ET AL.
FIRST ROUND DISCOVERY REQUESTS In its Order (Concerning a Motion to Compel), dated August 18, 1982, the Licensing Board directed Applicants to answer Interroga-tory 72 of Sunflower Alliance, Inc. et al. first round discovery requests " absent some objection not yet made known to the Board."
Slip op. at 7.
With the correction noted by the Licensing Board in its Order, the Interrogatory reads:
72.
What mechanisms are available at Perry Nuclear Power Plant to reduce dilution of the boron injected by the SLCS.
The Licensing Board observed that "[it] would appear [that the interrogatory] is relevant to the evaluation of the importance of Applicant's allegation that there is a greater risk that an automatic SLCS will introduce boron into the reactor rather than a manual system."
Id.
8208270506 820824 PDR ADOCK 05000440 G
PDR 3Xs03
4 f
e Applicants object to the interrogatory as irrelevant and beyond the scope of Issue #6.
As the Board stated, appropriate interrogatories should deal with the " differential advantages and disadvantages associated with using a manual rather than an auto-matic standby liquid controi system."
Id.
Interrogatory 72 has nothing to do with these differences.
Nor are mechanisms to reduce dilution of injected boron relevant to the risk of inadver-tant initiation of an automated SLCS.
Therefore, Applicants respectfully submit that Interrogatory 72 is irrelevant to Issue #6.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE I
BY:
M i
JA E
SILBERG, P.C WILLMORjE RC ER ? L.
Counsel for Applicants 1800 M Street, N.W.,
Suite 900 South Washington, D.C.
20036 (202) 822-1000 Dated:
August 24, 1982 9
e e.
)V 7
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)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Additional Answer to Sunflower Alliance, Inc. et al. First Round Discovery Requests" were served by deposit in the U.S. Mail, first class, postage prepaid, this 24th day of August, 1982, to all those on the attached Service List.
I If
%' t,'M,
JAY \\E/ SILBERG, P.C.
ROBERT L. NILLMOstE Dated:
August 24, 1982 h..mm m,rmim eim
NU
.::AR 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
)~
SERVICE LIST Peter 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.
Rline Docketing and Service Section Atomic Safety and Lice'nsing Board Office of the Secretary U.S. Nuclear Regulatory Commission V.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D. C.
20555-
'Mr.
Fre'derick J.
Shon
,, Stephen H., Lewis,.. Esquire _
Atomic Safety and Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Wahsington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Christine N.
Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appea'l Board U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D.C.
20555 Mentor, Ohio 44060 Dr. John H.
Buck Daniel D. Wilt, Esquire Atomic Safety and Licensing P. O.
Box 08159 Cleveland, Ohio 44108 Acceal Board U. 'S. Nuclear Regulatory Commission Washington,
D.C.
20555 Donald.T. E::ene, Esquire Assistant Prosecuting Attorney Gary J.
Edles, Esquire Lake County Administration Center Atomic Safety and Licensin9 105 Center Street Appeal Board Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John G.
Carc..anali, Esquire Prosecuting Attorney Atcmic Safetv and Licensing Ashtabula County Courthouse Board Panel' Jefferson, Ohio 44047 U.S. Nuclear Regulatory Commission Washinc:cn, D.C.
20555 Terry Lodge, Esquire
~
915 Spitzer Bui' ding Tcle do, Ohio 43604