ML20063G886

Addl Answers to First Round Discovery Requests.Certificate of Svc Encl

ML20063G886
Person / Time
Site:	Perry
Issue date:	07/27/1982
From:	Willmore R CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	SUNFLOWER ALLIANCE
References
NUDOCS 8207290237
Download: ML20063G886 (5)

Text

m If July 27,198ZCMETED uwC UNITED STATES OF AMERICA s oi 2P f ii rndV NUCLEAR REGULATORY COMMISSION , _ ,

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Before the Atomic Safety and Licensing Board In the Matter of ) '"'

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THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et,al. ) 50-441

. )

, (Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ADDITIONAL ANSWERS

- ' TO SUNFLOWER ALLIANCE, INC.

FIRST ROUND DISCOVERY REQUESTS As stated in Applicants' Substantive Answer to Sunflower Alliance, Inc. et al.'s (" Sunflower") Motion to Compel Discovery, dated July 23, 1982, Applicants are submitting their answers to Interrogatories 40, 47 and 48 of Sunflower's First Round Dis-covery Requests. In response to these interrogatories, Appli-

! cants state as follows:

40. How is the emergency communications system powered?

Response: Sunflower's Motion to Applicant to Compel dated June 21, 1982, stated that

" Sunflower would like to know about how the off-site system is to be powered." The final design configurations for the off-site emergency communications systems have not yet been determined.

47. What are the specifications for torque-ing of cable tray bolts?

Response: 35 foot / pounds 15 foot / pounds.

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48. Was there any damage to the Unit I contain-ment building dome during placement?

Response: No.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By Jay E. Silberg, P.C.

Robert L. Willmore.

Counsel for Applicants 1800 M Street, N. W.

- - . Washington, D. C. 20036 (202)822-1000 Dated: July 2 7,1982 t __

CLEVELAND ELECTRIC ILLUMINATING COMPASY CCgi.LD l CLEVELAND, OHIO ~,

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Murray R..EdelrEan, being duly sworn according to las~"ddp'is$si-that he is Division Manager, Nuclear Engineering and Construction

! Department of Cleveland Electric Illuminating Company and that ,

the facts set forth in the foregoing Applicants" Answers to Sunflower Alliance Interrogatories 40,47,48 dated December 2,1981, are true and correct to the best of his knowledge, information and belief.

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Sworn to and subsc d before me thisf/ day -

of ylff3.

- s 1/ sf CAROLINE M. WILDE Notary Public. State et Ohio My Commission Expires April 17,1985 (Recorded in Lake County)

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o r, .~ dT U pp UNITED STATES OF AMERICA J2 2ij i' '

NUCLEAR REGULATORY COMMISSION - -

..U,.h I "F 2. ?Od Before the Atom'ic Safety and Licensing Board *~;Ter,Sf- C '?-

~

33M:CH In the Matter of ) '

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

, )

(Perry Nuclear Power Plant, )

Units 1 and 2) -

)

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Additional Answers to Sunflower Alliance, Inc. First Round Dis-covery Requests'" were served by deposit in the U.S. Mail, First Class, postage prepaid, this 27th day of July, 1982, to all those on the attached Service List.

t t. " m Robert L. Willmore Dated: July 27, 1982

NUCLEAR. REGULATORY COMMISSION "

s Before the Atomic Safety and Licensing Board" In the Matter of )

) >

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440

~ ILLUMINATING COMPANY, e _t _a _l . )

~50-441 '

)

~

(Perry Nuclear Power Plant, )

• Units 1 and 2 )

SERVICE LIST Peter B. Bloch, Chairman , Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board Panel.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. 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 Mr. Frederick J. Shon '5Eephen H. Lewis',_jsquire_ _.____. -

Atomic Safety and Licensing Board'~~ Office of;thecExecutive

~

U.S. Nuclear Regulatory Commission Legal Directc'r N ,

Wahsington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D,.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Elatt Appeal Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 8275 Munson Avenue Washington, D. C. 20555 Mentor, Ohio 44060 Dr. John H. Buck Daniel'D. Wilt, Esquire Atomic Safety and Licensing P. O. Bon '08159 Appeal Board ' Cleveland, Ohio '44108 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Donald T. Ezzone, Esquire Assistant Prosecuting Attorney Gary J. Edles, Esquire Lake County Administration Center Atomic Safety and Licensing 105 Center Street Appeal Board .

Painesville, Ohio 44077 U.S. Nuclear Regulatory Commission -

Washington, D.C. 20555 + . .

John G. Cardinal, Esquire Prosecuting Attorney Atomic Safety and Licensing s Ashtabula County Courthouse Board Panel U. S . Nuclear Regulatory Commsssion Jeffeyson, Ohio 44047 Washincton, D.C. 20555 s'

~

Terry Lodge, Esquire -

915 SpitEbr Building Tole d,o , Ohio 43604 -

DP*

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