ML20099L373
| ML20099L373 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/15/1985 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-144 OL, NUDOCS 8503200574 | |
| Download: ML20099L373 (8) | |
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March 15, 1985 U3NRC
'85 rd 20 Ni:i8 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION cFr!cg :: j cag ggy COCH U U ; SEavtN, Before the Atomic Sorety and Licensing Board 32 F>
In the Motter of
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i THE CLEVELAND ELECTRIC
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D o.c k.e t_),o s,d O,44 0 g 0,L~
ILLUMINATING CO. ETiAL.
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50-441 OL
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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MOTION FOR C CONTINUANCE Intervenor Ohio Citizens for ResFonsible Energy ('0CRE')
hereby moves that the Licensing Board continue the heoring on Issue M8 until June 3, 1985, for the reasons outlined below.
The Licensing, Board has scheduled the evidentiary heoring to begin April 9.r Du'8ing the March 13 conference call, the Board kN i
outlined on order'oz hearing in which Issue #1, on emer.gency m
Planning, will be heard first, followed by Issue M16, on diesel generators,'ond f i n'a l l y Issue W8, on hydrogen control.
OCRE has the burden of two complex, technical issues, Issues 8 and 16.
Which apparently will be heard within the some 2-3 week period, without any break between hearings.
It is virtually impossible, i
o with~OCRE's 12mited' resources, to odequately prepare o case on 2 diverse, complex, and technicol issues without a creak-between hearings.
'There is oiso odditional information needed before Issue M8
-con go to hearing.
Applicants and OCRE ogreed to defe,r-further 8503200574 850315 T
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negotiations on OCRE's 13th set or Interrogotcries until the Board, ruled on the motions offecting Issue MS.
Since the Board i
has now ruled. OCRE hos initiated discussions with Applicants' a
f counsel for.the purpose of inspecting and copying voluminous r
documents related to'the ability'of the Perry containment to withstand the effects of hydrogen' combustion.
It will take time
.to-inspect, receive, and analy:e these documents.
It is very
' doubtful that this could be accomplished ~before the April 9 t
hearing date.
OCRE also hos 4 Freedom of.Information Act requests (ottoched hereto) pertaining to Issue M8 pending with the NRC.
The information to be-gained through the FOIA requests is vital for OCRE's=cose Preparation on this issue.
It is not known when the FOIA requests will be answered, or how voluminous the i
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information provided will be.
' kr l
There is inkhd4 tion to these documents other itemE recently N!
obtained from the Public Document Room Pertaining to Issue MS.
These items are voluminous and require extensive study, which connot be accomplished before the set hearing d a te..
-It must 0150 be.recolled that the Stoff's.5ER on this-issue
- Will not be ovoilable until April.
See letter dot.ed March 11, 1985'to the' Board-fhom Stoff counsel.
Finally,-0CRE is negotiating with potential-witnesses on Issue-N8..Because of current commitments, one potential expert witness will not be ovoilable in April, but may be available later.
In addition, OCRE'needs time to negotiate with other I'
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' 9 Witnesses who have recently been identified to OCRE.
It.is the policy of this agency to be solicitous of intervenors' desires for odditional time for cose preparation,
~given the disparity of resources between Applicants and Staff, on'one hand ond,intervenors, on the other.
Southern Californio s
Edison (Son Onofre Nuclear Generating Station, Units.2 & 3),
ALAB-212, 7 AEC'986, 992-3 (1974).
Any delay resulting from the continuance sought will not a
harm any party, includin9 APPliconts, os the Comniission's new hydrogen rule. 10 CFR 50. 44 (c) (3) (vii) (B), coes not require compliance os a condition of fuel load, but rather for operation above 5% power.
Thus, granting the relief sought is Just and proper and is necessary to ensure o fair hearing and complete record.
OCRE the Boob -isfso moved.
prays kT,.,q0 I
Respectfully submittee, i
Susan L.
Hiott OCRE Representative C275 nunson Rd.
Mentor, OH 44060 A
(216) 255-2158 l
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January 28, 1985 Mr.
J.M.
Felton, Director Division of Rules and Records Orrice or'Administroeion U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 FREEDOM OF INFORMATION ACT REQUEST Deor Mr. Felton:
T Pursuant-to the Freedom of Information Act, 5 USC 552, as
.omended, and the provisions or 10 CFR Port 9, the undersigned hereby requests the rollowing:
all Plant Emergency Instructions or Procedures for the Perry Nuclear Power Plant, or generic BWR Hork III Emergency Procedure
' Guidelines, draft or final, concerning containment hydrogen control, the maintenance or containment integrity, or
. containment purge or venting.
In accordance with your policy on fee waivers, I hereby request that 75% or the rees for the search and production or these items be waived.as they relate to Issue #8, on hydrogen control, admitted in the Perry OL proceeding.
I agree to accept the remaining (25%)- charges.
sincerely, y
hs. ll1 Suson L.
Hiott OCRE Representativej 8275 Munson Rd.
p Mentor, OH 44060 (216) 255-3158 6
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February 6, 1985 Mt. Lindo L.
Robinson, Chief FOI and Privacy Acts Bronch Division of Rules and Rec,ords Office of Administrotion U.S.
Nuclear Regulatory Commission FREEDOM OF INFORMAIgyi Woshington, D.C.3 20555 ACT REQUESI N(( g g
FREEDOM OF INFORMATION ACT REQUEST Deor Ms. Robinson:
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Pursuont to the Freedom or Information Act, 5 USC 552, as omendeg, and the provisions or 10 CFR Port 9, the undersigned hereby' requests the following:
All notes, minutes, transcripts, ottendance lists, memos, hondouts, or other documents from or concerning the meeting between the NRC and the Hydrogen Control Owners Group held Februory 6, 1985, or anytime during the week of February 4.
In accordonce with your policy on fee woivers. I hereby request that 75% of the rees for the search and production of these items be woived os they relate to Issue M8, on hydrogen control, admitted in the Perry OL proceeding.
I ogree to accept the remaining (25%) charges, 1.
Sincerely.
N' i
l Suson L.
Hiatt OCRE Representative 8275 Munson Rd.
Mentor, OH 44060 (216) 255-3158 le l
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Februory 12, 1985 Ms. Lindo L.
Robinson, Chief FOI and Provtcoy Acts Branch Division of Rules one Records Orrice of Administration FRE0DOW OF INFORMATION U.S.
Nucleor Regulatory Commission Washsngton, D.C.
20555 ACT REQUEST f0%)Q ~$ $ ~//)
FREEDOM OF INFORMATION ACT REQUEST gA b a y )f-fj l l
Dear Ms. Robinson:
Pursuont to the Freedom or Information Act, 5 USC 552, os amended, and the provisions or 10 CFR Port 9, the undersigned nereby requests the follousng:
all minutes, notes, eronscripts, ottendonce lists.
correspcncence, hondouts, or other documents from or ccncernir.9 the February 12, 1985 meeting between the NRC and the Hydrogen Control Owners Group.
In occorconce with your policy on fee woivers, I hereby request that 75% of the fees for the search and production of these items be woived as they relate to Issue MG, on hydrogen control, admitted in the Perry OL proceeding.
I agree to accept ene remainzng (25%) Chor9es.
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Sincerely, l ','
ta f
Susan L.
Hzott CCRE Representatsve!
827* tivnson cd, Mentor. O'n 44060 '
(216) 255-3158
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February 20, 1995
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Mr.
J.M.
Felton, Director
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Division of Rules and Records Office of Administration FhEEDOM OFINFORM U.S.
Nuclear Regulatory Commissien Washington, D.C.
20555 ACT REQUEST Fora-85-127 FREEDOM OF INFORMATION ACT REGUEST
Dear Mr. Felton:
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- ursuant-to the Freedom of Information Act, 5 USC 552, os a m e n t'e d, and the Provisions of 10 CFR Port 9, ene undersigned nereby requests the following:
all notes, minutes, transcripts, ottendance lists, hondouts, correspondence Cr any other documents from or concerning the meeting helo Feoruary 20, 1955 setween the NRC and the Hyerogen Control-Owners Group.
In accordance with your policy on fee waivers, I hereby request that 7 5 7.'
o f the fees for the search and procuction of these items be woived as they relate to Issue M8, on hydrogen control, admitted in the Ferry OL proceeding.
I agree to accept ene remainzng (25%) chorses, t'I 5:r,cerely, 9,'
N O,$
wtw x.
A 5Wson L.
Hiott CORE Representotzve" 5:75 Munson Rd.
Mentor, OH 44060 (214) 255-3152
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'J 5NRC d,.85 ;9R 20 All:18 CERTIFICATE OF SERVICE This is to certi'fy that copies of the foregoing were served by dep/fosjpintheU.S. Mail, first class, postage pigpaid,s thi's b.EY -
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day of' //52cN
,1986 to thoseC6figgh[.
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service list b.elow.
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Susan L.
Hiatt.
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SERVICE. LIST I
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JAMES P. GLERSON, CHAIRMAN
. Terry Lodge, Esq.
) ATOMIC SAFETY & LICENSING BORRD 618 N. Michigan St.
-1513 GILHOURE DR.MD 20901-l-
Suite 105
'}5ILUER SPRING,
.}, Toledo,OH 43624 s
Dr. Jerry'R..Kline Atomic Safety.& Licen. sing Board.
U.S. Nuclear. Regulatory Commission i-Washirigton,[D.C.
20555
.Ijh"fBright 1.
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Mr..Glend'd Atomic, Safe y &. Licensing Board U.S. Nuclear: Regulatory Commission Washington, D.C.
20555
, Colleen P.'Woodhead, Esq.
. Office of'the' Executive Legal-Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 I,, -
Jay.Silberg, E'sq.
Shaw, Pittmah; Potts, & Trowbridge
's 1800 M Stree't, NW
. Washington, D.C.
20036
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' ;i Docketing'& Service Branch 2
.Offi'ce'of'the Secretary U.S.. Nuclear Regulatory. Commission Washington, D.C.
20555-
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Atomic. S'afety. &, Licensing. Appeal. Board Panel U.S. Nuclear Regulatory Commission-Washington, D.C.
20555 f
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