ML20065T595

Response to 820930 Third Set of Interrogatories & Request for Production of Documents.Related Correspondence

ML20065T595
Person / Time
Site:	Perry
Issue date:	10/29/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	CLEVELAND ELECTRIC ILLUMINATING CO.
References
ISSUANCES-OL, NUDOCS 8211020600
Download: ML20065T595 (3)

Text

l RELATED CORRESPONDENC2 T.

I 00CKETED 1 tV UNITED STATES OF AMERICA U3NRC NUCLEAR HEGULATORY COMMISSION 82 NOV -1 All :25 Before the Atomic Safety and Licensing ~Boardsgcaggy

- " gggERVfCE In the Matter of ) ,

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CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPAtPI, g al. ) 50-441

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(Perry Nuclear Power Plant, )

Units 1 and 2) ) October 29,,1982 RESPONSE OF SUNFLOVIER ALLIANCE, INC. , et al., TO APPLICANT'S INTERROGATORIES AND REQUEST FOR PRO-DUCTION OF DOCUMENTS (THIRD SET)

Intervenor Sunflower Alliance, Inc., et al. herewith supplies its answers to Applicant's Third Set of Interrogatories and Request for Production of Documents, dated September 30, 1982.

Sunflower Alliance, Inc. is at this time responding to only those.

interrogatories pertaining to Issues No. 1 and No. 3. Sunflower will defer answering those interrogatories and requests for production of documents concerning Issue No.11 until 'a later date. Sunflower Alliance, 'Inc. will not repeat here the inter-rogatories directed to Sunflower; the answers to said inter- _

rogatories are provided below.

Issue No. 1

1. (a) Sunflower Alliance, Inc. has examined certain draft emergency response plans for Lake and Ashtabula Counties.

(b) (1) All portions of the draf t plan for Achtabula.

County; all portions of the working draft plan for Lake County.

(2) Sunflower Alliance, Inc. objects to this subpart

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r of Interrogatory 1 as irrelevant to Issue No. 1 and therefore beyond the scope of discovery.

(3) The Ashtabula County plans were examined by:

James McIntyre Stephen Sass P.O. Box 91 1104 East 15th St.

Jefferson, OH 44047 Ashtabula, OH 44004 The Lake County plans were examined by:

Amy Hubbard 3901 Bridge Ave.

Cleveland, OH 44113 Sunflower Alliance, Inc. considers the portion of this inter-rogatory pertaining to tne employers of these persons to be'ob-jectionable, as such information is irrelevant to Issuc No. 1.

(4) Sunflower Alliance, Inc. objects to this supbart of Interrogatory 1 as irrelevant to Issue No. 1 and therefore oeyond the scope of discovery.

2. (a) Sunflower Alliance, Inc. does possess copies of the draft plans identified in the response to Interrogatory 1.

However, Sunflower objects to having to produce said copies, as these documents are readily available to Applicant and the production of same would place an undue burden on Intervenor's limited resources.

(b) Sunflower Alliance, Inc. objects to this subpart of Interrogatory 2 as irrelevant to Issue No. 1 and therefore beyond the scope of discovery.

3. (a) and (b) Sunflower Alliance, Inc. objects to this Interrogatory as irrelevant to Issue No. 1 and therefore beyond the scope of discovery.

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( lasue No. 3

4. .(a) and (b) Sunflower Alliance, Inc. objects to this -

Interrogatory as irrelevant to Issue No. 3 and therefore , --

beyond the scope of discovery. .

5. (a) through (e) Sunflower Alliance, Inc. does not have knowledge of any alleged deficiencies in construction or quality

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identified in the NRC's inspection reports, Applicant's ; reports s.

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to the NRC, or accounts in the news media, as identifiedlin; -

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Sunflower's previous filings. p; . 19

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Issue No. 11 _

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Answers to Interrogatories 6 through 10 are. deferred. ~< .>_

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General Interrogatories .

11. and 12. Answers to these interrogatories are'pr vided

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by the attached affidavit. ~ - l'E.' - ,

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13. and 14. No document search was conducted in order to respond .

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to the Interrogatories pertaining to Issues No..1.and'Noi~3. -

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' JN . ; - , 15. Sunflower Alliance , . Inc. does not possess -or contEo'1kany '.Y'?iW ;d -

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such~ written or recorded statements pertaining.to Idsu"esi.Nd N' EX'* M')

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or No. 3. .

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Repsectfully.sudditte'dp .-

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I;faniel D. Wilt, -Esq. -

Attorney! for Sunflower Alliance P.O.' Box O8159  ;

. s'f Cleveland, OH 44108 ' ['

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