ML20099L295

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Provides List of Available Matl Re Contention,Per 850314 Telcon.Most Matl Considered Irrelevant by Applicants. Discovery Viewed as Untimely.Svc List Encl.Related Correspondence
ML20099L295
Person / Time
Site: Perry  FirstEnergy icon.png
Issue date: 03/18/1985
From: Silberg J
CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Hiatt S
AFFILIATION NOT ASSIGNED
References
CON-#185-141 OL, NUDOCS 8503200554
Download: ML20099L295 (3)


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i SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNER $MIP OF pmCFESsaONAL CompORA;i egC 1800 M STR E ET, N. W.

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Ms. Susan Hiatt 8275 Munson Avenue Mentor, Ohio 44060 The Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Units 1 and 2)

Docket hos. 50-440 and 50-441

Dear Sue:

In response to your phone call of March 14, this is to confirm our conversation of today concerning additional discovery on Issue No.

8.

Although Applicants consider most of this material to be irrelevant to the contention and all of it to be in the nature of untimely discovery, we will nevertheless make the following available to.yous 1.

Identification of witnesses and scope of testimony:

Other than the individuals whose names I provided to you on March 14 as potential witnesses, we will not have definitive information on actual witness identification or scope of testimony until the testimony is filed.

2.

Physical model of PNPP containment structure:

Applicants have several physical models of portions of the Perry facility.

These models are located at the site and at Gilbert-Commonwealth's offices in Reading, Pennsylvania.

You are welcome to examine those which show the containment structure.

3.

Nonconformance reports on containment and containment penetrations:

The nonconformance reports (which are on microfiche) are not collected for containment and containment penetrations.

You are welcome to review available lists of nonconformance reports for the reactor building (which would include those for' containment and containment penetrations) and examine those which relate to containment and containment penetration.

A 8503200554 850318

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Ms. Susan Hiatt March 18, 1985 Page 2 4.

APTECH Report references:

The two APTECH reports which you requested (AES-82-01-92 (April 1982) and AES-81-11-88 (November 1981)) are available for your inspection.

5.

Procedures concerning operation of the hydrogen control system:

Perry-specific emergency procedures have not yet been drafted.

Nor does CEI have a completed draft of generic emergency procedure guidelines for combustible gas control.

6.

Hydrogen Control Owners' Group Program Plan (updated as of December 1984):

This document is available for your review, as is the more recent February 1985 version.

As in the case of your other discovery requests, please contact Mr. Bradley S. Ferrell at Perry (216-259-3737, ext.

5520) to make any necessary arrangements.

Very truly curs La v

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8 UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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THE CLEVELAND ELECTRIC

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Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.

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50-441

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(Perry Nuclear Power Plant,

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Units 1 and 2)

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SERVICE LIST James P. Gleason, Chairman Atomic Safety and Licensing 513 Gilmoure Drive Appeal Board Panel Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission' Washington, D.C.

20555 Jerry R.

Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission; Washington, D.C.

20555 Washington, D.C.

20555 Glenn O. Bright Colleen Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing Terry Lodge, Esquire Appeal Board Suite 105 U.S. Nuclear Regulatory Commission 618 N. Michigan Street Washington,.D.C.

20555 Toledo, Ohio 43624 Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Lake County Administration l

U.S. Nuclear Regulatory Commission Center Washington, D.C.

20555 105 Center Street Painesville, Ohio 44077 Gary J. Edles, Esquire Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory CommiFafon U.S. Nuclear Regulatory Commissioa Washington, D.C.

20555 Washington, D.C.

20555 John G. Cardinal, Esquire Ms. Sue Hiatt Prosecuting Attorney 8275 Munson Avenue Ashtabula County Courthouse Mentor, Ohio 44060 Jefferson, Ohio 44047 i

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