ML20086L265
| ML20086L265 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/03/1984 |
| From: | Lodge T SUNFLOWER ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8402080053 | |
| Download: ML20086L265 (3) | |
Text
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RELATED CORRESM DOCE TEir
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UNI 7ED STATES OF AMERICA
. NUCLEAR REGULATORY COtNISSION
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Befom the Atcrnic Safety and Licensing Board e,i : 9 b
. Docket Nos.
50-440-OLCO.2ilau 4 Ef r 1 In the Matter of
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DE 50-441-OL CLEVELAtD ELECTRIC ILUUfENATIrG
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COMPANY, et. al.
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(Perry Nuclear Power Plant, Units 1 and 2)
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SUfFLDAER'S !<TTION TO REOPEN DISCOVERY ON ISSUE 10.1 Now ccmes Sunflower Alliance, by and through counsel, and moves the Boarti to allow the mopening of discovery on Issue No.1 in
.this proceeding.
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Terry J / %) St., Suite 105 618 N. !
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- Toledo, 43624 (419) 255-7552 Counsel for Sunflower Alliance ISORAIOUM As the Boarti is well aware, there were previous rounds of interrogatories served and responses rendered on Issue Ib.1 prior to In its order at that time, the Board closing of discovery in 1982.
clearly left the door open for renewal of discovery:
The fact that Sunflower will obtain additicnal infonmtion in the future will permit it to argue that it has good cause for late-filing of interro-gatories with mspect to that material, providing that the information was not previously available
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to it.
"Menorandum and Order (Conceming Request to Extend Discovery on Issue Ib.
NRC (October 8, 1984).
1)," LDP Sunflower represents that there is considerable cause for reopen-Technical arrangemmts for emergency planning irg discovery on this issue.
8402000053 840203 75 DR ADOCK 0500044 0.s
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. coorthnation have been made, or are considerably more ccrrpleted, than was the case in:1982. Upon information and belief, the Federal Emergency Management Agency and Ohio Disaster Services Agency have begun to plan q
or conduct tabletop exert:ises. Al) of the affected counties have greatly and materially expanded their physical response capabilities as part of emergency planning.
Emergency preparations will likely to be the last, and length-iest, issue to be tried before the Boarti. Substantial justice and fair-ness dictates that the intervenors be allowed, not just to receive the seasonable updates to previous discovery reg:ests, but that new discovery requests, including but not limited to dep0sitions and further intorro-gatories, be authorized by the Board.
hMEREFORE, Sunflower respectfully prays the Board allow reopening forthwith on Issue No I of this pru eeding.
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S ower Alliance Counse CERTIFICATION I hereby certify that a copy of the foregoing "fbticn to Reopen Discovery on Issue No.1"was sent by me to the parties on the acccrnpanying " Service List" via regular U.S. fbil this 3rd day of February, 1984.
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Terry Jj Lodge i k,
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'84 FEB -6 P2:10 Peter B. Bloch, Chairman 9
Atomic Safety & Licensing Board LFFu f g.g.
GCChErpsasggtr.
U.S. Nuclear Regulatory Commission mRANCH Washington, D.C.
20555 Dr. Jerry R. Kline Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Glenn O. Bright Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Colleen P. Woodhead, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Jay Silberg, Esq.
1800 M Street, N.W.
Washington, D.C.
20036 Atomic Safety and Licensing Appeal Board Panel U.S. Nu:.Nar Regulatory Commission Washington, D.C.
20555 Susan L. Hiatt S275 Munson Road Mentor, Ohio
% 060 Christine N. Kohl, Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Gary J. Edles, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555