ML18025A059
| ML18025A059 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 07/10/1979 |
| From: | Silberg J, Yuspeh A Shaw, Pittman, Potts & Trowbridge |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18025A059 (4) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensin Board In the Matter of PENNSYLVANIA POWER and ALLEGHENY ELECTRIC (Susquehanna Steam Units 1 and 2)
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LIGHT CO.
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COOPERATIVE, INC.
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Electric Station,
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Docket Nos.
50-
-388 APPLICANTS'OTION TO COMPEL DISCOVERY OF INTERVENOR SUSQUEHANNA ENVIRONMENTAL ADVOCATES Pursuant to 10 C.F.R.
$2.740(f), Applicants hereby move the Atomic Safety and Licensing Board ("the Board" ) to issue an order compelling Intervenor Susquehanna Environmental Advocates
("SEA")
to respond to "Applicants'irst Set of Interrogatories to Inter-venor Susquehanna Environmental Advocates" and "Applicants'irst Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents,"
both dated May 25, 1979, within ten (10) days from the date of issuance of such order by the Board.
In its Special Prehearing Conference
- Order, the Board pro-vided that responses to first round discovery requests were to be served no later than June 29, 1979.
SEA has filed neither responses nor objections to Applicants'ay 25, 1979 discovery requests; nor has SEA sought an extension of time to respond.
Applicants'iscovery is intended to determine whether SEA is aware of any new information or any information which is incon-sistent with that known to Applicants.
Without such knowledge, 1
Applicants cannot know which issues need to be addressed at the evidentiary hearings.
SEA's answers will help define the areas of dispute between the parties and avoid the needless wasting of time litigating issues over which there is no dispute.
Section 2.740(f) of the Commission's regulations provides that if a party upon whom interrogatories or a request for pro-duction of documents is served fails to respond or object to the
- request, or any part thereof, the party submitting the discovery requests may move the presiding officer for an order compelling a response in accordance with the request.
In light of SEA's failure to respond to Applicants'iscovery
- requests, Applicants have therefore moved the Board for an order pursuant to 10 C.F.R. 52.740(f) compelling SEA to respond to Applicants'iscovery re-quests within ten (10) days from the date of the Board's order.
Respectfully submitted, SHAW J P ITTMAN~
POTTS
& TROWBRIDGE By Ja 1berg Ala R.
uspeh 1800 N Street, N.
W.
Washington, D. C.
20036 (202)331-4100 Dated:
July 10, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensing Board In the Matter of PENNSYLVANIA POWER 6 LIGHT CO.
and ALLEGHENY. ELECTRIC COOPERATIVE, INC.
(Susquehanna Steam Electric Station, Units 1 and 2)
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, Docket Nos.
50-387
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50-388
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CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Applicants'otion to Compel Discovery of Intervenor Susquehanna Environmental Advocates" were served by deposit in the U. S. Mail, first, class, postage prepaid, this 10th day of July, 1979, to all those on the attached Service List.
Dated:
July 10,'.1979 Jay
. S'lberg
~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANiA POWER and ALLGEHENY ELECTRIC (Susquehanna Steam Uni"s 1 and 2)
LIGHT COMPANY COOPERATIVE, INC.
Electric Station, Docket Nos.
50-387 50-388 SERVICE Charles Bechhoefer, Esquire Cha5.rman Atomic Safety and Licensing Board Panel U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Mr. Clenn O. Bright Atomic Sa. ety and Licensing Board Panel J.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr. Oscar H. Paris Atomic Sa ety and Licensing Board Panel U.
S. Nuclear Regulatory Commission Washington, D. C.
20555 Atomic Safety and, Licensing Board Panel U,
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Atom'c Safety and Licensing Appeal Board Panel U.
S. Nuclear Regulatory Commis sion Washington, D. C.
20555 James M. Cutchin, IV, Esquire Off'ce of the Executive Legal Director U.
S. Nuclear Regulatory Commis'sion Washington, D.
C.
20555 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvan'a.
16801 Susquehanna Environmental Advocates c/o Gerald Schultz, Esquire 50Q South River Street Wilkes-Barre, Pennsylvania 18702 l1rs. Irene Lemanowicz, Chairman The Citizens Against Nuclear Danger Post Office Box 377 R.
D.
1 Berwick, Pennsylvania 18603 Ms. Colleen Marsh 558 A, R.
D.
p4 Mt. Top, Pennsylvania 18707 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of En'v'ironmental Resources Commonwealth of Pennsylvania P.
O.
Box 2063 Harrisburg, Pennsylvania 17120 LIST Docketing and Service Section Office of the Secretary U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555