Susquehanna LLC - Letter to Judges Young, Lathrop and Sager Responding to Judges Requests for Citations to Cases Addressing the Standing of Individuals Who Claim non-residential Activity in Proximity to a Nuclear FacilityML070740491 |
Person / Time |
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Site: |
Susquehanna |
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Issue date: |
03/09/2007 |
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From: |
Doris Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP, Susquehanna |
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To: |
Lathrop K, William Sager, Austin Young Atomic Safety and Licensing Board Panel |
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SECY RAS |
References |
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50-387-LR, 50-388-LR, ASLBP 07-851-01-LR, RAS 13244 |
Download: ML070740491 (2) |
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Category:Legal-Intervention Petition
MONTHYEARML18026A0622018-01-26026 January 2018 Petition for Intervention ML0725603582007-09-10010 September 2007 Susquehanna - Eric Joseph Epstein'S Notice of Appearance, Data Requests, and Motion to Postpone Final Determination of PPL Susquehanna, Llc'S Application for Surface Water Withdrawal Request to Modify Application 19950301-EPU-0572 ML0724203542007-08-22022 August 2007 Susquehanna - Eric Joseph Epstein'S Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments ML0716904712007-06-12012 June 2007 Susquehanna - Eric Joseph Epstein'S Reply to PPL Susquehanna LLC and the NRC Staff'S Responses to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearings and Contentions ML0716502202007-06-0505 June 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing, and Contentions. Notice of Appearance by Susan L. Uttal, OGC and Lloyd B. Subin, OGC ML0714305802007-05-11011 May 2007 Petition to Intervene with Respect to the Proposed Amendment Request for a Thermal Power Increase for the Susquehanna Steam Electric Station, Units 1 and 2 ML0709306092007-03-20020 March 2007 Susquehanna - Eric Joseph Epstein'S Response to the NRC Staff'S Motion to Strikes Portions of Eric Joseph Epstein Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707803052007-03-11011 March 2007 Susquehanna, LLC - Eric Joseph Epstein'S Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707404912007-03-0909 March 2007 Susquehanna LLC - Letter to Judges Young, Lathrop and Sager Responding to Judges Requests for Citations to Cases Addressing the Standing of Individuals Who Claim non-residential Activity in Proximity to a Nuclear Facility ML0707903652007-02-28028 February 2007 Susquehanna - Eric J. Epstein Letter to the Parties Notifying Them That U.S. Department of Homeland Security, Oig and OI Acknowledged Receipt of His 1-30-07 Motion ML0706101942007-02-23023 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Motion to Strike Portions of Eric Epstein'S Response to Answers to Petition to Intervene ML0705103632007-02-0505 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Answer and Petitioners Response to NRC Staff'S Response for Leave to Intervene, Request for Hearing and Contentions ML0703602822007-01-29029 January 2007 Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Petition for Leave to Intervene ML0703000522007-01-29029 January 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing and Contentions ML0703103302007-01-10010 January 2007 2007/01/10- Susquehanna- Email from Eric Epstein Service to Parties the Supplemental Filing Relating to SAMA Requirements ML0701704852007-01-0202 January 2007 2007/01/02- Susquehanna- Legal-Intervention Petition PPL Susquehanna LLC Application for Susquehanna Steam Electric Station'S Renewed Operating Licenses ML18025A0211979-10-13013 October 1979 Encp Response to Staff Motions Dated October 9, 1979 ML18025A0231979-10-12012 October 1979 Applicant'S Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding ML18025A6901979-10-12012 October 1979 Applicants' Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding and Attaching Contention to Be Dismissed ML18025A6841979-09-18018 September 1979 Correction to Ecnp Intervenors' Response to Board Memorandum and Orders ML18025A6811979-09-17017 September 1979 Applicant'S Answer to Citizens Against Nuclear Dangers' Supplemental Appeal Regarding Discovery Request Number 18 ML18025A6831979-09-17017 September 1979 Responses of Ecnp Intervenors to Board Memorandum and Order Compelling Intervenors to Answer Applicant and Staff Interrogatories ML18025A6791979-09-10010 September 1979 Ecnp Intervenors' Second Round Discovery Requests of the NRC Staff ML18025A6721979-08-30030 August 1979 Citizens Against Nuclear Dangers (Citizens) Appeal Before the NRC Appeal Board Panel Pertaining to the Licensing Board'S Memorandum and Order on Scheduling and Discovery Notions, August 24, 1979 ML18025A7341979-07-0909 July 1979 Applicant'S Response to Licensing Board Memorandum and Order of June 18, 1979 ML18025A7331979-07-0505 July 1979 Applicants' Answer to Citizens Against Nuclear Dangers' Motion for Board Ruling on Revision of Preliminary Timetable. ML18025A7281979-06-27027 June 1979 Applicant'S Motion to Compel Discovery of Intervenor Citizens Against Nuclear Dangers ML18025A7251979-06-0404 June 1979 Applicants' Answer to Motion of Citizens Against Nuclear Danger ML18025A7211979-05-25025 May 1979 Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents ML18025A0751979-01-17017 January 1979 in the Matter of the Application for an Operating License for the Susquehanna Nuclear Generating Station by PP&L - Amended Petition for Leave to Intervene ML18025A0761979-01-12012 January 1979 Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions ML18023B1541978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by the Susquehanna Environmental Advocates ML18026A0511978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by Susquehanna Environmental Advocates, Citizens Against Nuclear Dangers, and Colleen March and Elven Other Individuals ML18026A0521978-09-20020 September 1978 Applicant'S Answer to Request for an Operating License Hearing and Petition for Leave to Intervene Submitted by the Environmental Coalition on Nuclear Power 2018-01-26
[Table view] Category:Responses and Contentions
MONTHYEARML18026A0622018-01-26026 January 2018 Petition for Intervention ML0725603582007-09-10010 September 2007 Susquehanna - Eric Joseph Epstein'S Notice of Appearance, Data Requests, and Motion to Postpone Final Determination of PPL Susquehanna, Llc'S Application for Surface Water Withdrawal Request to Modify Application 19950301-EPU-0572 ML0724203542007-08-22022 August 2007 Susquehanna - Eric Joseph Epstein'S Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments ML0716904712007-06-12012 June 2007 Susquehanna - Eric Joseph Epstein'S Reply to PPL Susquehanna LLC and the NRC Staff'S Responses to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearings and Contentions ML0716502202007-06-0505 June 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing, and Contentions. Notice of Appearance by Susan L. Uttal, OGC and Lloyd B. Subin, OGC ML0714305802007-05-11011 May 2007 Petition to Intervene with Respect to the Proposed Amendment Request for a Thermal Power Increase for the Susquehanna Steam Electric Station, Units 1 and 2 ML0709306092007-03-20020 March 2007 Susquehanna - Eric Joseph Epstein'S Response to the NRC Staff'S Motion to Strikes Portions of Eric Joseph Epstein Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707803052007-03-11011 March 2007 Susquehanna, LLC - Eric Joseph Epstein'S Response to the Atomic Safety Licensing Board Panel'S Request for Information ML0707404912007-03-0909 March 2007 Susquehanna LLC - Letter to Judges Young, Lathrop and Sager Responding to Judges Requests for Citations to Cases Addressing the Standing of Individuals Who Claim non-residential Activity in Proximity to a Nuclear Facility ML0707903652007-02-28028 February 2007 Susquehanna - Eric J. Epstein Letter to the Parties Notifying Them That U.S. Department of Homeland Security, Oig and OI Acknowledged Receipt of His 1-30-07 Motion ML0706101942007-02-23023 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Motion to Strike Portions of Eric Epstein'S Response to Answers to Petition to Intervene ML0705103632007-02-0505 February 2007 Susquehanna - Eric Joseph Epstein'S Response to PPL Susquehanna'S Answer and Petitioners Response to NRC Staff'S Response for Leave to Intervene, Request for Hearing and Contentions ML0703602822007-01-29029 January 2007 Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Petition for Leave to Intervene ML0703000522007-01-29029 January 2007 Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Petition for Leave to Intervene, Request for Hearing and Contentions ML0703103302007-01-10010 January 2007 2007/01/10- Susquehanna- Email from Eric Epstein Service to Parties the Supplemental Filing Relating to SAMA Requirements ML0701704852007-01-0202 January 2007 2007/01/02- Susquehanna- Legal-Intervention Petition PPL Susquehanna LLC Application for Susquehanna Steam Electric Station'S Renewed Operating Licenses ML18025A0211979-10-13013 October 1979 Encp Response to Staff Motions Dated October 9, 1979 ML18025A0231979-10-12012 October 1979 Applicant'S Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding ML18025A6901979-10-12012 October 1979 Applicants' Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding and Attaching Contention to Be Dismissed ML18025A6841979-09-18018 September 1979 Correction to Ecnp Intervenors' Response to Board Memorandum and Orders ML18025A6811979-09-17017 September 1979 Applicant'S Answer to Citizens Against Nuclear Dangers' Supplemental Appeal Regarding Discovery Request Number 18 ML18025A6831979-09-17017 September 1979 Responses of Ecnp Intervenors to Board Memorandum and Order Compelling Intervenors to Answer Applicant and Staff Interrogatories ML18025A6791979-09-10010 September 1979 Ecnp Intervenors' Second Round Discovery Requests of the NRC Staff ML18025A6721979-08-30030 August 1979 Citizens Against Nuclear Dangers (Citizens) Appeal Before the NRC Appeal Board Panel Pertaining to the Licensing Board'S Memorandum and Order on Scheduling and Discovery Notions, August 24, 1979 ML18025A7341979-07-0909 July 1979 Applicant'S Response to Licensing Board Memorandum and Order of June 18, 1979 ML18025A7331979-07-0505 July 1979 Applicants' Answer to Citizens Against Nuclear Dangers' Motion for Board Ruling on Revision of Preliminary Timetable. ML18025A7281979-06-27027 June 1979 Applicant'S Motion to Compel Discovery of Intervenor Citizens Against Nuclear Dangers ML18025A7251979-06-0404 June 1979 Applicants' Answer to Motion of Citizens Against Nuclear Danger ML18025A7211979-05-25025 May 1979 Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents ML18025A0751979-01-17017 January 1979 in the Matter of the Application for an Operating License for the Susquehanna Nuclear Generating Station by PP&L - Amended Petition for Leave to Intervene ML18025A0761979-01-12012 January 1979 Letter Enclosing Supplement to Petition for Leave to Intervene of Colleen Marsh Et Al Outlining and Listing Contentions ML18023B1541978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by the Susquehanna Environmental Advocates ML18026A0511978-09-21021 September 1978 Applicant'S Answer to Petition for Leave to Intervene and Request for Hearing Submitted by Susquehanna Environmental Advocates, Citizens Against Nuclear Dangers, and Colleen March and Elven Other Individuals ML18026A0521978-09-20020 September 1978 Applicant'S Answer to Request for an Operating License Hearing and Petition for Leave to Intervene Submitted by the Environmental Coalition on Nuclear Power 2018-01-26
[Table view] |
Text
2300 N Street, N.W. Tel 202.663.8000 Washington, D.C. 20037-1128 Fax 202.663.8007
,'w.Npillsburvlaw.corn Pillsbury R. LEWIS DOCKETED Winthrop DAVID 202-663-8474 Shaw david~lewis@pillsburylaw.com USNRC Pittman,,
March 9, 2007 (10:38am)
March 9, 2007 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Administrative Judge Administrative Judge Ann Marshall Young, Esq., Chairman Dr. Kaye D. Lathrop Atomic Safety and Licensing Board Atomic Safety and Licensing Board.
Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 Dr. William W. Sager Atomic Safety and Licensing Board Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 In the Matter of PPL Susquehanna LLC (Susquehanna Steam Electric Station, Units 1 and 2)
Docket Nos. 50-387-LR & 50-388-LR: ASLBP-No. 07-851-01-LR
Dear Judges Young,
Lathrop and Sager:
During the prehearing conference call on March 8, 2007, the Board provided an opportunity for the participants in this proceeding to provide citations to cases addressing the standing of individuals who claim non-residential activity in proximity to a nuclear facility. In response, PPL Susquehanna refers to Board to the following principal decisions: Private Fuel Storage, LLC (Independent Spent Fuel Storage Installation), CLI-99-10, 49 N.R.C. 318; 324.
(1999); Private Fuel Storage, LLC (Independent Spent Fuel Storage Installation), CLI-98-13, 48 N.R.C. 26, 31-32 (1998).
Sincerely,,
David R. Lewis Counsel for PPL Susquehanna LLC cc: Service List
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March 9, 2007 Page 2 I hereby certify that copies of this letter were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, and where indicated by an asterisk by electronic mail, this 9 th day of March, 2007:
- Administrative Judge *Administrative Judge Ann Marshall Young, Esq., Chairman Dr. Kaye D. Lathrop Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 amyv(iinrc.gov klathrop@independence.net
- Administrative Judge *Secretary Dr. William W. Sager Att'n: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop 0-16 C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 secy@nrc~gov; hearingdocket@nrc.gov wsager@tamu.edu Office of Commission Appellate Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 Cl Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001
- Susan L. Uttal, Esq, *Mr. Eric J. Epstein
- Molly L. Barkman. Esq. 4100 Hillsdale Road
- Jody C. Martin, Esq. Harrisburg, PA 17112 Office of the General Counsel ericepstein(@comncast.net Mail Stop 0-15 D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 sILu(nrc.gov; rnlb9(@nrc.gov; jcm5@nrc.gov David R. Lewis 400540040VI Pillsbury Winthrop Shaw Pittman LLP