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| | number = ML18025A721 | | | number = ML18025A721 |
| | issue date = 05/25/1979 | | | issue date = 05/25/1979 |
| | title = Susquehanna Units 1 and 2 - Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents | | | title = Applicants' First Request to Intervenor Susquehanna Environmental Advocates for the Production of Documents |
| | author name = Silberg J E, Yuspeh A R | | | author name = Silberg J, Yuspeh A |
| | author affiliation = Pennsylvania Power & Light Co, Shaw, Pittman, Potts & Trowbridge | | | author affiliation = Pennsylvania Power & Light Co, Shaw, Pittman, Potts & Trowbridge |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:May25,1979UNITEDSTATESOFAMERICANUCLEARREGULATORYCOMMISSIONBEFORETHEATOMICSAFETYANDLICENSINGBOARDIntheMatterof))PENNSYLVANIAPOWERANDLIGHTCOMPANYand)ALLEGHENYELECTRICCOOPERATIVE,INC.))(SusquehannaSteamElectricStation,)Units1and2))DocketNos.50-38750-388APPLICANTS'IRSTREQUESTTOINTERVENORSUSQUEHANNAENVIRONMENTALADVOCATESFORTHEPRODUCTIONOFDOCUMENTSInaccordancewithSpecialPrehearingConferenceOrder,LBP-79-6,andpursuantto10CFR52.741,Applicantsrequ'estthatIntervenor,SusquehannaEnvironmentalAdvocates("Inter-,venor")respondinwritingtothefollowingrequestforproductionofdocumentsandproducetheoriginalorbestcopyofeachofthedocumentsrequestedbelow,onorbeforeJune29,1979,attheofficeofBryanSnapp,Esquire,PennsylvaniaPower6LightCompany,orataplacemutuallyconvenienttotherespectiveparties."Documents"meansallwritingsandrecordsofeverytypeinthepossession,controlorcustodyofIntervenor,includingbutnotlimitedtomemoranda,correspondence,reports,surveys,tabulations,charts,books,pamphlets,photographs,maps,bulletins,minutes,notes,diaries,speeches,articles,transcriptsandallotherrecords,writ-ten,electrical,mechanicalorotherwise. | | {{#Wiki_filter:May 25, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) |
| "Documents"shallalsomeancopiesofdocuments,eventhoughtheoriginalsthereofarenotinthepossession,custodyorcontrolofIntervenor.ApplicantsrequestthatIntervenorproduceeachandeverydocumentidentifiedordescribedintheanswerstoApplicants'irstRoundofInterrogatoriestoIntervenorSusquehannaEnvironmentalAdvocates.Respectfullysubmitted,SHAW,PITTMAN,POTTS6TROWBRIDGE(,QJay.SlbergAlan'.QuspehCounselforApplicants1800MStreet,N.W.Washington,D.C.20036(202)331-4100Dated:May25,1979}} | | ) |
| | PENNSYLVANIA POWER AND LIGHT COMPANY and) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388 |
| | ) |
| | (Susquehanna Steam Electric Station, ) |
| | Units 1 and 2) ) |
| | APPLICANTS'IRST REQUEST TO INTERVENOR SUSQUEHANNA ENVIRONMENTAL ADVOCATES FOR THE PRODUCTION OF DOCUMENTS In accordance with Special Prehearing Conference Order, LBP-79-6, and pursuant to 10 CFR 52.741, Applicants requ'est that Intervenor, Susquehanna Environmental Advocates (" Inter- |
| | ,venor") respond in writing to the following request for production of documents and produce the original or best copy of each of the documents requested below, on or before June 29, 1979, at the office of Bryan Snapp, Esquire, Pennsylvania Power 6 Light Company, or at a place mutually convenient to the respective parties. |
| | "Documents" means all writings and records of every type in the possession, control or custody of Intervenor, including but not limited to memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts and all other records, writ-ten, electrical, mechanical or otherwise. |
| | |
| | "Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of Intervenor. |
| | Applicants request that Intervenor produce each and every document identified or described in the answers to Applicants'irst Round of Interrogatories to Intervenor Susquehanna Environmental Advocates. |
| | Respectfully submitted, SHAW, PITTMAN, POTTS 6 TROWBRIDGE Jay . S |
| | (, |
| | lberg Q |
| | Alan'. Quspeh Counsel for Applicants 1800 M Street, N. W. |
| | Washington, D. C. 20036 (202)331-4100 Dated: May 25, 1979}} |
|
|---|
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
[Table view] |
Text
May 25, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER AND LIGHT COMPANY and) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-388
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
APPLICANTS'IRST REQUEST TO INTERVENOR SUSQUEHANNA ENVIRONMENTAL ADVOCATES FOR THE PRODUCTION OF DOCUMENTS In accordance with Special Prehearing Conference Order, LBP-79-6, and pursuant to 10 CFR 52.741, Applicants requ'est that Intervenor, Susquehanna Environmental Advocates (" Inter-
,venor") respond in writing to the following request for production of documents and produce the original or best copy of each of the documents requested below, on or before June 29, 1979, at the office of Bryan Snapp, Esquire, Pennsylvania Power 6 Light Company, or at a place mutually convenient to the respective parties.
"Documents" means all writings and records of every type in the possession, control or custody of Intervenor, including but not limited to memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, speeches, articles, transcripts and all other records, writ-ten, electrical, mechanical or otherwise.
"Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of Intervenor.
Applicants request that Intervenor produce each and every document identified or described in the answers to Applicants'irst Round of Interrogatories to Intervenor Susquehanna Environmental Advocates.
Respectfully submitted, SHAW, PITTMAN, POTTS 6 TROWBRIDGE Jay . S
(,
lberg Q
Alan'. Quspeh Counsel for Applicants 1800 M Street, N. W.
Washington, D. C. 20036 (202)331-4100 Dated: May 25, 1979
