ML20112C911
| ML20112C911 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/07/1985 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20112C914 | List: |
| References | |
| CON-#185-030, CON-#185-30 OL, NUDOCS 8501110477 | |
| Download: ML20112C911 (3) | |
Text
RELAT ED COiUw MUENC5 j.
January 7, 1R85 v3CKETED U56RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'85 JM 11 A!0:25 Before the Atomic Safety and Licensing Board In the Matter or
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EM 5 c4 THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 OL ILLUMINATING CO. ET AL.
)
50-441 OL
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
MOTION TO REOPEN DISCOVERY ON ISSUE W16 Intervenor Ohio Citizens for Responsible Energy (*OCRE')
hereby moves to reopen discovery on Issue #16 (on diesel generators) for the limited purpose of submitting its Fourteenth Set of Interrogatories to Applicants, attached.
Discovery on Issue M16 has been closed since June 1,
1984.
May 8, 1984 Memorondum and Order (Discovery-About Transomerico Delaval Diesels).
However, the Licensing Board did not close the door on further discovery, stating:
To the extent that discovery beyond that time CJune 1, 1984] is worronted, OCRE will need to'show good cause.
Should it seek
~
information that is ovoiloble to it for the first time, it should indicate that reason for wishing to obtain it.
'Similarly, should it seek previously avoilable information because newly available information has indicated the.importance of that information -thereby cierting OCRE to its importance-it should state its new basis for desiring the information.
OCRE hos met these good cause stondords.
This filing as triggered by new information contained in Applicants'.0ctober 31, 1984. responses to NRC_Stoff requests for information dated December 28, 1983.
This new information consists of Applicants' onnouncement that they will replace the AH-type piston skirts on
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khe diesel engines with type AE skirts and Applicant's 8501110477 850107 ~
gDRADOCK 05000440
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- 4 PDR-
' -f identification,or new documents.
This hos mode it necessary to seek information on AE Piston skirts (which was heretorore-irrelevant) and to request the production or the new documents.
Although Applicants' response to the Starr's requests was dated October 31, 1984, this motion is timely, os that submittal was-not made available to OCRE until recently.
OCRE, in its Interrogatory 10-34, riled January 6, 1984, specifically requested Applicants' responses (ond odditional information e
reloted thereto) to the Storr's questions.
Applicants toto 11y railed to ruiril their discovery obligation.
The first notice
.0CRE received or the existence of the document was in the Starr's letter to Applicants dated December 10, 1984.
(1)
OCRE then had to wait until the document was placed in the Local Public Document Room (ot,0CRE's request) on December 19, 1984 before examining it.
In light or these circumstances,.it is clear that there exists abundant good cause for reopening dis'covery for the limited purposes desired..0CRE Proys that the Board is so
. ~..,
' December 10, 1984 letter from'B.J. Youngblood, NRC, to (1)
Murtry R.
Edelmon, CEI.
Starr counsel provided this to the Board =by letter dated December 13, 1984.
- t
. moved.
Respectfully submitted.
4 4Wn Susan L.
Hiatt OCRE Representative 8275 Munson Rd.
Mentor. OH 44060 (216) 255-3158
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