ML20085A788

Affidavit of SL Hiatt,Providing Justification for Addl Time Needed to Respond Properly to NRC Motion for Summmary Disposition of Issue 13.Certificate of Svc Encl

ML20085A788
Person / Time
Site:	Perry
Issue date:	06/29/1983
From:	Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY
To:
Shared Package
ML20085A784	List: ML20085A781 ML20085A788
References
NUDOCS 8307070154
Download: ML20085A788 (3)

Text

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• O AFFIDAVIT I, Susan L. Hiatt, OCRE Representative, duly sworn depose and say that:

A. the statements below are true to the best of my knowledge and belief; B. OCRE will need approximately six (6) months to adequately respond to the Staff's motion for summary. disposition of Issue ~#13'for the following reasons:

1. the experience of the recent hearing on quality assurance has demonstrated to OCRE the: necessity of presenting a direct case. Since then OCRE has been trying diligently to locate persons having the required expertise to serve as witnesses and/or consultants on this and other issues. Such persons are very difficult to find. Apparently there are few persons having the expertise who.are not associated with the nuclear industry or who do not charge exorbitant prices for their services. OCRE has located one person who has expressed his willingness to examine the documents OCRE has obtained through discovery from Staff and Applicants, but he is extremely busy and can only devote spare moments to this task. OCRE therefore speculates that it would take at least four (4)' months for this person to examine all of the materials OCRE now possesses on Issue #13.

2. the turbine missile issue is of such technical complexity that OCRE,must*obtain technical expertise to assist it in evaluating the materials it already has and to assist in

m preparing appropriate discovery questions to further develop ~

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_11 the record on this issue.

3. OCRE'is,.through a related soon-to-be-filed court

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action, seeking additional information necessary for its t:ase on the turbine missile issue.- Any further act%on on this issue should be deferred pending the court's ruling in said action, which may take at least six (6) months.

4. OCRE also speculates that, if available, expert witnesses may demand ' fees far in excess of OCRE's financia'l resources.

OCRE will therefore need time to raise the funds necessary

'. to secure the appearance of such witnesses. This may take at least six (6) months.

5. if, as OCRE hopes, further discovery is allowed on this issue, such discovery, including the time necessary to draft interrogatories, obtain answers from other parties, and, if necessary, file the appropriate motions to compel, would require approximately four (4) months, based on past experience.

6.- since OCRE has other issues in this proceeding, and has limited resources, in terms of finances and personnel, it is just and proper to allow,0CRE the time necessary to properly present its case on'an issue impor, tant to the safety of'the general public.

L Susan L.

W Hiatt b-OCRE Representative c.

Sworn to and scbscribed before.me this _f day'of June, 1983.

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,  : - ,.~i , . NotanyttiProty'ki;9t. Anorney At Law '

'" Notary Putdic. State of Ohio I

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. MtWil'on has no expiration date.

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j$ D'?W CERTIFICATE OF SERVICE ' " "

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.This is to certify that copies of the foreg g , .,.

were served by deposit in the U.S.. Mail, first class, g o,<tah, r .

prepaid, this ,27 day of June, 1983 ,to those oh the service I

lis t belo'w. ,3 cff Y Sdsan L. Hiatt SERVICE LIST -

Peter B. Bloch, Chairman Terry Lodge, Esq. -

Atomic Safety & Licensing Board 824 National Bank Bldg, U.S. Nuclear Regulatory Comm'n Toledo, OH 43604 Washington, D.C. 20555-Dr. Jerry R. Kline Atomic Safety & Licensing Board .

U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Mr. Glenn 0. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Comm'n

. Washington,.D.C. 20555 Docketing & Service Section Offic'e.of the Secretary U.S. Nuclear Regulatory Comm'n Washington, D.C. ~ 20555 James M. Cutc'hin IV Esq.

- Office of the Exec,utiv,e Legal Director U.S. Nuclear Regulatory Comm'n Jay Silberg, Esq. .

1800 M-Street, N.W.

Washington, D.C.;'20036.

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Atomic Safety and Licensing Appeal Board . Panel U.S. Nuclear hegulatory Commission Washington, D.C. 20555 I

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