ML20065M706

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Motion to Extend Discovery on Issue 9 to 821101 to Permit Review of Documents Referenced in Applicant Responses to 820830 Interrogatories & Followup Discovery.Certificate of Svc Encl.Related Correspondence
ML20065M706
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 10/15/1982
From: Hiatt S
OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20065M679 List:
References
ISSUANCES-OL, NUDOCS 8210210366
Download: ML20065M706 (3)


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October 15, 1982 o?4gp UNITED STATES OF AMERICA

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02 DCT 7g All:50 NUCLEAR HLGULATORY COMMISSION

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Before the Atomic Safety and Licensing Board":Y;,(f y...

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-.u ;,Q,j' In the Matter of

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CLEVELAND ELECTRIC ILLUMINATING

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Docket Nos.

50-440 COMPANY, et al.

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50-441

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(0L)

(Perry Nuclear Power Plant,

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Units 1 and 2)

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MOTION TO EXTEND DISCOVEhY ON ISSUE #9 s._

Ohio Citizens for Responsible Energy ("0CRE") hereby moves the Licensing Board to extend the deadline for filing discovery on Issue #9.

In its September 16, 1982 Memorandum and Order (Concerning Scheduling), the Board set October 15, 1982~as a target date for the completion of discovery on Issues 9 and 11.

OCRE, on August 30, filed interrogatories on both Applicants and NHC Staff pertaining to Issue #9.

Applicants have responded.

Staff has not.

In their response, Applicants have referenced many documents which are only available for inspection at PNPP.

Due to circumstances beyond OCRE's control (e.g.,

the Perry plant contact person whom Applicants have designated in their response was on vacation unS'l Octobe.12), OCRE has had difficulty in making arrangements to review these documents and will not be able to examine them until October 24.

OCRE should have the ri,ght to file follow-up discovery on information in these documents, as well as that in the Staff's response.

Therefore, OCRE requests that the deadline for filing discovery on Issue #9 8210210366 821015 PDR ADOCH 05000440 o

PDR

4 be extended to November 1 for discovery on Applicants and, for Staff, to 1C days following the Staff's filing of its answer to OCRE's Fourth set of Interrogatories to Staff.

Respectfully submitted,

[

Susan L. Hiatt OCHE Representative 8275 Munson R*d.

Mentor, OH 4,4.0 6 0,.

(216) 255-3158' 1

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CERTIFICATE OF SERVICE gg DCT 18 pyg ;59 This is to certify that copies of the foregoing 0CRE8S.

SEVENTH DISCO'EhY PRCGRESS hEPORT and MOTION TO EXTENDr: DISCOVERY ON' ISSUE #9 were served by deposit in the U.S. Mail, first'(41 ass, postage prepaid, this 15th day of October, 1982, to those on the service list below.

+WY$

susan L.

H1att

' 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 4

James M. Cutchin, IV, Esq.

Office of the Executive Legal Director U.S~. Nuclear Regulatory Comm'n Wasnington, D. C.

20555 Jay Silberg, Esq.

1800 M Street, N.W.

Washington, D. C.

20036 i

Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Wa s hington, D.C.

20555

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