ML18025A039

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Applicants' Answer to Motion for Protective Order of Colleen Marsh Et Al
ML18025A039
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/06/1979
From: Silberg J
Pennsylvania Power & Light Co, Shaw, Pittman, Potts & Trowbridge
To:
Atomic Safety and Licensing Board Panel
References
Download: ML18025A039 (5)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensing Board In the Matter of )

)

PENNSYLVANIA POWER 6 LIGHT COMPANY )

and ) Docket Nos. 5 ALLEGHENY ELECTRIC'OOPERATIVE, INC. ) -38

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

APPLICANTS) ANSWER TO MOTION FOR PROTECTIVE ORDER OF COLLEEN MARSH ET AL In the introduction to their Answers to First Round Applicant Interrogatories (undated, but accompanied by an affidavit dated July 20, 1979), Colleen Marsh et al. ("Marsh" )

asked'hat the Licensing Board issue a protective order pur-suant to 10 CFR 52.740(c) addressed to those interrogatories which Marsh did not. answer.

Applicants have reviewed the answers which Marsh has submitted, both to Applicants'nterrogatories and to those of the Staff. Based upon that review, it appears to Applicants that Marsh has answered Applicants'irst round interrogatories to the extent of information currently available to her. Appli-cants therefore see no necessity for a motion to compel dis-covery. Similarly, the Marsh motion for protective order would appear moot.

Applicants assume that Marsh will supplement her answers to interrogatories as required by 10 CFR 52.740(e), i.e.

as to expert witnesses and their testimony (Interrogatory 19)

and as to matters which though correct when made are no longer true.

Respectfully submitted, SHAW I PZTTMANI POTTS 6 TROWBRXDGE By J y E. Silberg A an . Yuspeh 1800 M Street, N. W.

Washington, D. C. 20036 (202) 331-4100 Dated: August 6, 1979

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensin Board In the Matter of )

)

PENNSYLVANIA POWER 6 LIGHT COMPANY ) Docket Nos. 50-387 and ) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Applicants'nswer to Motion for Protective Order of Colleen Marsh et al." were served by deposit in the U. S. Mail, first class, postage prepaid, this 6th day of August, 1979, to all those on'he attached Service List.

Jay Sha 1800

,'it f Sx) erg M

an, Street, Potts N. W.

6 T owbridge Washington, D. C. 20036 (202)331-4100 Dated: August 6,, 1979

t UN ITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER LIGHT COMPANv ) Docket Nos. 50-387 and ) 50-388 ALLGEHENY ELECTRIC COOP ERAT IVE, INC . )

(Susquehanna Steam Electric Station, )

Uni"s 1 and 2) )

SERVICE LIST Charles Bechhoefer, Esquire Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Board Panel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Judith H. Johnsrud Co-Director Mr. Glenn O. Bright Environmental Coalition on Atomic Safety and Licensing Nuclear Power Board Panel 433 Orlando Avenue J. S. Nuclear Regulatory Commission State College, Pennsylvan' 16801 washington; D. C. 20555 Susquehanna Env'onmental Advocates Dr. Oscar H. Paris c/o Gerald Schultz, Esquire Atonic Saf ety and Licensing 500 South River Street Board Panel Wilkes-Barre, Pennsylvania 18702 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mrs. Irene Lemanowicz, Chairman The Citizens Agains" Nuclear Danger Atomic Safety and Licensing Post Office Box 377 Board Panel R. D. 1 U. S. Nuclear Regulatory Commission Berwick, Pennsylvania 18603 Washington, D. C. 20555 Ms. Colleen Marsh Atomic Safety and Licensing Appeal 558 A, R. D. g4 Board Panel Mt. Top, Pennsylvania 18707 U. S. Nuclear Regulatory Commission Washing ton, D. C. 20555 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection James M. Cutchin, IV, Escuire Depar ment of Env'ironmental Resource Of 'ce of the Executive Legal Commonwealth of Pennsylvania Director P. O. Box 2063 U. S. Nuclear Regulatory Commission Harrisbu g, Pennsylvania .17120 Washing" on, D. C. 20555

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