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 LIGHT CO. )
and ) Docket Nos. 50-ALLEGHENY ELECTRIC COOPERATIVE, INC. ) -388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
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 ) , Docket Nos. 50-387 ALLEGHENY. ELECTRIC COOPERATIVE, INC. ) 50-388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
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.
Jay . S'lberg Dated: July 10,'.1979
~
UN ITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANiA POWER LIGHT COMPANY Docket Nos. 50-387 and 50-388 ALLGEHENY ELECTRIC COOPERATIVE, INC.
(Susquehanna Steam Electric Station, Uni"s 1 and 2)
SERVICE LIST Charles Bechhoefer, Esquire Docketing and Service Section Cha5.rman 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. Clenn O. Bright Environmental Coalition on Atomic Sa. ety and Licensing Nuclear Power Board Panel 433 Orlando Avenue J. S. Nuclear Regulatory Commission State College, Pennsylvan'a. 16801 Washington, D. C. 20555 Susquehanna Environmental Advocates Dr. Oscar H. Paris c/o Gerald Schultz, Esquire Atomic Sa ety and Licensing 50Q South River Street Board Panel Wilkes-Barre, Pennsylvania 18702 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 l1rs. Irene Lemanowicz, Chairman The Citizens Against 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 Atom'c Safety and Licensing Appeal 558 A, R. D. p4 Board Panel Mt. Top, Pennsylvania 18707 U. S . Nuclear Regulatory Commis sion Washington, D. C. 20555 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection James M. Cutchin, IV, Esquire Department of En'v'ironmental Resources Off'ce of the Executive Legal Commonwealth o f Pennsylvania Director P. O. Box 2063 U. S. Nuclear Regulatory Commis'sion Harrisburg, Pennsylvania 17120 Washington, D. C. 20555