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Category:Legal-Motion
MONTHYEARML0707500502007-03-15015 March 2007
Susquehanna - Motion to Strike Portions of Mrs. Epstein'S Response to the Board'S Request for Information
ML0705100312007-02-15015 February 2007
Susquehanna - NRC Staff Response to Eric Joseph Epstein'S Motion to Compel and Request for Schedular Exemption
ML0705204562007-02-13013 February 2007
Susquehanna - PPL Susquehanna'S Motion to Strike Portions of Eric Epstein'S Response to Answers to Petition to Intervene
ML0705206152007-02-13013 February 2007
Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Motion to Compel Application for License Transfer
ML0704705852007-02-0505 February 2007
Susquehanna - Eric Joseph Epstein'S Motion to Compel PPL Susquehanna, LLC to: (1) Apply for a Direct License Transfer (or Incorporate Modifications from an NRC Approved Transfer Into the Relicensing Application)
ML18025A6931979-12-11011 December 1979
Citizens Against Nuclear Dangers Petition for a Government Inquiry; Replies to Discovery Order; Motions on Interrogatories Before the Atomic Safety and Licensing Board
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
ML18025A0231979-10-12012 October 1979
Applicant'S Motion to Dismiss Environmental Coalition on Nuclear Power and Certain Contentions from This Proceeding
ML18025A0241979-10-10010 October 1979
Applicants' Answer in Support of Motion of NRC Staff for Dismissal of Citizens Against Nuclear Dangers from This Proceeding for Failure to Comply with the Licensing Board'S Order Dated August 24, 1979.
ML18025A6891979-10-0909 October 1979
Motion for Protective Order and Reply to NRC Staff Motion
ML18025A6801979-09-12012 September 1979
Motion for Extension of Time to Answer or Object to First Round Interrogatories of Applicant and NRC by Intervenor Sea
ML18025A0391979-08-0606 August 1979
Applicants' Answer to Motion for Protective Order of Colleen Marsh Et Al
ML18025A0561979-07-16016 July 1979
Applicants' Answer to Environmental Coalition on Nuclear Power Intervenors' Answers to First Round Applicant Interrogatories, and Motion to Compel Discovery
ML18025A0591979-07-10010 July 1979
Applicants' Motion to Compel Discovery of Intervenor Susquehanna Environmental Advocates
ML18025A0641979-07-0505 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
ML18025A7381979-06-22022 June 1979
Citizens Against Nuclear Dangers' Motion for Board Ruling on Revision of Preliminary Timetable
ML18023B0521977-04-0808 April 1977
Response of Florida Power & Light Company to Motion for Clarification of Procedures
ML18026A0551976-10-21021 October 1976
Pennsylvania Power & Light Company'S Response to Motion of Vermont Yankee Nuclear Power Corporation Dated September 27, 1976
ML18026A0571976-10-21021 October 1976
Pennsylvania Power & Light Company'S Response to Motion of Vermont Yankee Nuclear Power Corporation Dated September 27, 1976
2007-03-15
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Category:Legal-Party Contentions and Associated Pleading
MONTHYEARML18025A6801979-09-12012 September 1979
Motion for Extension of Time to Answer or Object to First Round Interrogatories of Applicant and NRC by Intervenor Sea
ML18025A7031979-01-12012 January 1979
Letter Enclosing the Supplement to Petition for Leave to Intervene
ML18026A0571976-10-21021 October 1976
Pennsylvania Power & Light Company'S Response to Motion of Vermont Yankee Nuclear Power Corporation Dated September 27, 1976
ML18026A0551976-10-21021 October 1976
Pennsylvania Power & Light Company'S Response to Motion of Vermont Yankee Nuclear Power Corporation Dated September 27, 1976
1979-09-12
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Text
September 12, 1979 UiiXTED STATES OF AMERICA NU~~< REGULATORY CQ~IMISS ION BEFORE THE ATCiMC SAFETY AND LI~SWG BOARD In the Hatter of: )
)
Pennsylvania Power and Light. ) u~
COHpany I ) KXXZET NOS.:
)
) 50-387
) 6 Allegheny Electric Cooperative ) 50-388 (Susquehanna Steam Electric )
Station Units 1 & 2) )
M7ZICN FOR EZIMSION OF TLK TO PiVSKR OR OB3ZCT TO FIRST ROUND INTERROGATORIES OF APPLIC'AVZ AND NRC BY INTERVENOR SEA Intervenor SEA ccmes now and @aves for an extension of tim to answer or object to the first round interrogatories of the applicant and the NRC for the following reasons which constitute, equal and anent to good cause, pursuant to 10 CFR 2.711(a):
- 1) Fourteen (14) days is simply not enough time to prepare answers or objections to such lengthy, burdensome, oppressive interrcgatories.
The applicant, staff, and the Board knew M.l well that it would take a full time staff, including an attorney, radiation physicist and engineer, at least six (6) months to adequately answer or object to these c;aasonian interro-gatories.
The applicant, staff and Board also know that SEA is a volunteer citizens organization without tl necessary full time staff and resources.
To allow SEA only 14 days to respond after denial of our motion for a protective order is punitive and offensive to any recruits of proca2ural due prccess and fairness that the Board might retain.
If the Board dces for not grant, a reasonable extension of time, pursuant SEA to respond, it vill only danonst ate that &~
to 10 C.F.R. 2.711(a),
BOARD, while giving lip se~ce to effective citizen participation, merely desires to rush through the hearings and grant an operating license.
- 2) SEA, and, to its kna~ledge, the other intervenors, =have not had, access to a copy of the prehearing conference transcript outside Ma local public decurrent rocm, in direct contravention of the Board's own Special Pre-hearing Conference Order (i~~>>ch 6, 1979) . The Staff has not lent one of its copies to the interverzors. The Staff make no ar angements for the use of the transcript outside th LPDR as r~~'red on pace 83 of the Order. Even these
pallid, condescending measures, far short of what the NRC, and the Board, should do, were not taken. This has further irrpeded SPA's ability to respond to the interrogatories.
NHEREPORE, SEA moves that the Board extend the tina limit to answer or object to the first round interrcgatories to the applicant and the NRC 180 days.
SUSQUEHANNA ENVIRCÃMENTAL ADVOCREH GERAZD R. S~TZ JCHN J. ROBINSON I hereby certify that a copy of the foregoing Yotion has been served on all parties to this action.
GERALD R. SCHULTZ
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