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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
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UNITED STATES OF AMERICA 5 7 NUCLEAR REGULATORY COMMISSION Before the Atomic Safet .and Licensin Board'n the Matter of )
)
PENNSYLVANIA POWER AND LIGHT CO. ).
and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
APPLICANTS'NSWER TO "CITIZENS AGAINST NUCLEAR DANGERS'OTION FOR BOARD RULING ON REVISION OF PRELIMINARY TIMETABLE" In a filing served on June 22, 1979, intervenor Citizens Against Nuclear Dangers (CAND) requested a revision of the preliminary timetable established by the Board in its Special Prehearing Conference Order for this proceeding.
Applicants oppose the CAND motion for the reasons set forth below.
First, CAND argues in its motion that it had not been presented with the preliminary timetable for comment or concurrence prior to the adoption of such timetable. See filing at l. At the Special Prehearing Conference, Applicants made several suggestions for a discovery schedule. See Tr. at 361-365. Other parties had the opportunity to comment on
Applicants'uggestions, and intervenor Environmental Coalition on Nuclear Power did in fact seek clarification regarding Appli-cants'uggestions. See Tr. at 364-365. CAND was free to comment on Applicants'roposals during the several weeks between the Special Prehearing Conference and the Licensing Board's March 6, 1979, Order. Thus, CAND had ample opportunity to comment on the licensing schedule.
Second, CAND states that there has been an "informal 90 day suspension on some licensing proceedings" at the NRC as a result of events at Three Mile Island, Unit 2. See filing at l.
Neither the Commission nor its staff has said anything which could be interpreted as halting licensing proceedings that are now underway before atomic safety and licensing boards. Even if the Commission has chosen not to issue new licenses for a three month period, which is presumably what CAND refers to, this provides no basis for delaying the prehearing procedures related to the Susquehanna plant.
Third, CAND mentions a "staff reorganization" at the NRC.
See filing at 2. While it is generally recognized that some staff of the NRC has been diverted to activities associated with the Three Mile Island accident, any delay in licensing
'activities for the Susquehanna plant which occurs as a result of this situation is implicitly accounted for by the present licensing schedule. This is due to the fact that subsequent rounds of discovery and the hearings themselves are tied to the staff's issuance of the Environmental impact Statement
Cw and the- Safety Evaluation Report. Thus, if the diversion of NRC staff to activities related to Three Mile Island .delays the completion of these staff reviews, the schedule for this proceeding will be appropriately (and automatically)"adjusted.
Fourth, CAND mentions ongoing NRC activities to-assess the lessons learned from events at Three Mile Island, and suggests that delay is necessary to take account of such lessons in pro-ceedings related to the Susquehanna facility. See filing at 2.
To the extent that they are applicable, these "lessons learned" will of course be factored into this proceeding. CAND's argument also overlooks the fact. that many of the contentions admitted in this proceeding. are unrelated to lessons that may be learned from the Three Mile Island reviews now underway.
Applicants therefore believe that none of the reasons set forth by CAND justify a delay in the licensing schedule for the Susquehanna facility. The schedule that has been established by the Board provides ample opportunity for all parties to meet their obligations as participants in the proceeding. Applicants respectfully request that CAND's motion be denied.
Respectfully submitted, A ~ P TTMANg POTTS 6'ROWBRIDGE Jay E. Silberg Alan R. Yuspeh 1800 M Street, N.W.
Washington, D. C. 20036 Dated: July 5, 1979
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. 50-387 ALLEGHENY ELECTRIC COOPERATIVE g INC ) 50-388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Applicants'nswer to 'Citizens Against Nuclear Dangers'otion for Board Ruling on Revision of Preliminary Timetable'" were served by deposit in the U. S. Mail, First class, postage prepaid, this 6th day of July, 1979, to all those on the attached Service List.
J '. Silberg Dated: July 6, 1979
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER 6 LIGHT COMPANY ) Docket Nos. 50-387 and ) 50-388 ALLGEHENY ELECTRIC COOPERAT IVE g INC )
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
SERVICE LIST Secretary of the Commission Docketing and Service Section U. S. Nuclear Regulatory Commission Office of .the Secretary Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Charles Bechhoefer, Esquire Chairman Dr. Judith H. Johnsrud Atomic Safety and Licensing Co-Director Board Panel Environmental Coalition on U. S. Nuclear Regulatory Commission Nuclear Power Washington, D. C. 20555 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Glenn O. Bright Atomic Safety and Licensing Susquehanna Environmental Advocates Board Panel c/o Gerald Schultz, Esquire U. S. Nuclear Regulatory Commission 500 South River Street Washington, D. C. 20555 Wilkes-Barre, Pennsylvania 18702 Dr. Oscar H. Paris Mrs. Irene Lemanowicz, Chairman Atomic Safety and Licensing The Citizens Against Nuclear Danger Board Panel Post Office Box 377 U. S. Nuclear Regulatory Commission R. D~ 1 Washington, D. C. 20555 Berwick, Pennsylvania 18603 Atomic Safety and Licensing Ms. Colleen Marsh Board Panel 558 A, R. D. g4 U. S. Nuclear Regulatory Commission Mt. Top, Pennsylvania 18707 Washington, D. C. 20555 Mr. Thomas M. Gerusky, Director Atomic Safety and Licensing Appeal Bureau of Radiation Protection Board Panel Department of Environmental Resources U. S. Nuclear Regulatory Commission Commonwealth of Pennsylvania Washington, D. C. 20555 P. O. Box 2063 Harrisburg, Pennsylvania 17120 James M. Cutchin, IV, Esquire Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555