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Category:CERTIFICATES OF SERVICE
MONTHYEARML20010C9701981-08-10010 August 1981 Certifies 810812 Svc of Commonwealth of PA Disaster Operations Plan,Annex E,Comments Re Contention 20,memorandum Responding to Util 810727 Ltr,& Luzerne County Facility Emergency Response Plan.Related Correspondence ML18026A5081980-10-27027 October 1980 Certifies Svc of Applicants' Motion for Summary Disposition of Contention 16 W/Supportive Statement of Matl Facts & Wj Rhoades Affidavit,On 801027 ML18030A1391980-08-22022 August 1980 Certifies Svc of Motion for Partial Summary Disposition of Contention 17,statement of Matl Facts as to Which No Genuine Issue of Fact Exists,Brief in Support of Motion & Rf Lehman Affidavit on 800822 1981-08-10
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20209H6691999-07-12012 July 1999 Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code ML20203G6131998-01-26026 January 1998 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Interim Rept 739459-97,dtd 971015 Be Withheld from Public Disclosure ML20203G6031997-12-0404 December 1997 Affidavit of RG Byram Justifying That Redacted Portions of Pp&L,Inc Corporate Auditings Rept 739459-1-97,dtd 971201 Be Withheld from Public Disclosure PLA-4330, Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control1995-06-0808 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control PLA-4193, Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety1994-08-31031 August 1994 Comment Opposing Petition for Rulemaking PRM-9-2 Submitted Ocre Requesting That NRC Revise Regulations to Provide Public Access to Info Held by Licensees But Not Submitted to Nrc.Urges NRC to Deny Ocre Petition in Entirety ML20046A9531993-07-20020 July 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20045F7971993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Supports Rule in Part & Opposes Rule in Part ML20045D7461993-06-21021 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Disagrees W/Maintaining 100% Rate for Contractor & Vendor Employees ML20044F8361993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rules ML20044F7511993-05-24024 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners1992-03-0909 March 1992 Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners PLA-3568, Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a1991-04-0808 April 1991 Comments Supporting Proposed Rule 10CFR50 Incorporating 1986 -1988 Addenda & 1989 Editions of ASME Boiler & Pressure Vessel Code,Section Iii,Div 1 & Section Xi,Div 1,by Ref Into 10CFR50.55a PLA-3462, Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants1990-10-15015 October 1990 Comment Supporting Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal.Proposed Rule,W/Enhancements Recommended by Numarc,Will Provide More Stable Basis for Util Planning & Development of Future Power Plants ML19332G5261989-12-0606 December 1989 Comments on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Industry Has Made Substantial Progress Re Maint Performance as Indicated by Respective Performance Indicators,Commission Insps & Plant Conditions PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants1989-03-29029 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235V4001989-03-0202 March 1989 Comment on Proposed Rule 10CFR50 Re Maint Program at Nuclear Plants.Proposed Maint Rule Has Potential to Significantly Undermine Util Initiatives & Direct Limited Resources Away from Real Improvements in Maint PLA-3157, Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained1989-02-24024 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Effectiveness of Maint Programs for Nuclear Power Plants.Proposed Rule Not Needed & Will Not Serve to Increase Commission Ability to Ensure Nuclear Plants Reliably Maintained PLA-3118, Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule1988-11-17017 November 1988 Comment Endorsing NUMARC Comments on Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons PLA-3019, Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking1988-04-15015 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Announcements of Inspectors.Nrc Does Not Fully Appreciate Impact of Rule as Written.Encourages Commission to Abandon Rulemaking PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift1986-09-25025 September 1986 Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift ML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20027D4471982-11-0101 November 1982 Affidavit of Wj Rhoades Correcting Response to Hearing Question on Leak Rates.Leak Rate Sys Capable of Detecting 1 Gpm Per Hour.Tech Specs Will Require Shutdown for Unidentified Leakage of 5 Gpm.Certificate of Svc Encl ML20069D8321982-09-0909 September 1982 Original Signature Page to Sh Cantone Affidavit.Svc List Encl ML20027B2291982-09-0909 September 1982 Stipulation of Withdrawal of Commonwealth of PA 820428 Exceptions Re Supply of TLD ML20065A9541982-09-0909 September 1982 Affidavit of Sh Cantone Re Dosimetry for Emergency Workers at Plant.Prof Qualifications Encl ML20027B2231982-09-0909 September 1982 Motion to Withdraw Commonwealth of PA 820428 Exceptions to Initial Decision,Contingent Upon Approval of Util & Commonwealth of PA 820909 Stipulation ML20027B2351982-09-0808 September 1982 Affidavit of AL Belser & Rj Hippert Responding to Questions in Aslab 820820 Order & Supporting Stipulation Withdrawing Exceptions.When Stipulated Number of Dosimeters Available, Emergency Workers Will Be Protected.W/Certificate of Svc ML20027B2331982-09-0808 September 1982 Affidavit of Ma Reilly Responding to Question in Aslab 820820 Order & Supporting 820909 Stipulation. TLD Necessary to Document Exposure of Officials Helping Contaminated Evacuees ML20063A4041982-08-18018 August 1982 Petition for Reconsideration of Commission 820809 Order Rendering ASLB Initial Decision Effective.Exceptions to Decision Require Resolution.Commission Order Premature. Certificate of Svc Encl ML20062J6391982-08-13013 August 1982 Order Directing Parties to Identify Person Presenting Arguments at 820908 Hearing in Bethesda,Md.Response Requested No Later than 820831 ML20058J6651982-08-0909 August 1982 Order Rendering ASLB 820412 Decision Authorizing OL Issuance Effective.Full Power OL Not Yet Authorized ML20054L5081982-07-0606 July 1982 Brief Opposing Commonwealth of PA 820428 & Citizens Against Nuclear Dangers 820421 Exceptions to ASLB 820412 Initial Decision.Pa Fails to Prove Dosimetry Issue Timely Raised. Citizens Failed to Comply W/Procedure.W/Certificate of Svc ML20054L2841982-07-0202 July 1982 Brief Opposing Commonwealth of PA 820428 Exceptions to ASLB 820412 Initial Decision Authorizing OL Issuance.Commonwealth Fails to Justify License Condition Imposition Re Availability of Dosimetry.Certificate of Svc Encl ML20054J5611982-06-25025 June 1982 Brief Opposing Citizens Against Nuclear Danger 820421 Exceptions to ASLB 820412 Initial Decision.Exceptions Fail to Comply W/Commission Regulations & Raise Issues Not Presented Before Aslb.Certificate of Svc Encl ML20053D0801982-05-28028 May 1982 Brief in Support of Exceptions to ASLB 820412 Initial Decision Authorizing Issuance of Ols.Shortage in Supply of Dosimeters for Emergency Workers Clear & Uncontroverted. Certificate of Svc Encl ML20053D2191982-05-28028 May 1982 Brief Supporting Commonwealth of PA Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052B7461982-04-28028 April 1982 Exceptions to ASLB 820412 Initial Decision.Certificate of Svc Encl ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20054C6551982-04-15015 April 1982 Response Opposing Citizens Against Nuclear Dangers 820402 Proposed Findings of Fact & Conclusions of Law.Requirements for Reopening Record Not Met.No Showing That Allegations Raise Significant Safety Issues.Certificate of Svc Encl ML20050D4191982-04-0202 April 1982 Proposed Findings of Fact & Conclusions of Law Based on Important New Info & Recommendations to NRC Commissioners & Congress.Certificate of Svc Encl ML20042C2781982-03-26026 March 1982 Motion for Order That Applicants Conduct Complete Retest of Emergency Plan W/All 20 Communities Participating.Testimony on Contentions 6 & 20 Should Be Reviewed to Identify Perjury by Fema,Applicants & State of Pa.Certificate of Svc Encl ML20042C2701982-03-26026 March 1982 Proposed Findings of Fact & Conclusions of Law Re Emergency Evacuation Plan ML20069B0301981-12-22022 December 1981 Reply to Parties' Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20039B0791981-12-16016 December 1981 Proposed Transcript Corrections.Certificate of Svc Encl ML20062M2141981-12-0909 December 1981 Proposed Transcript Corrections ML20039A1951981-12-0909 December 1981 Proposed Findings of Fact & Conclusions of Law ML20038C0131981-12-0303 December 1981 Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20038A8891981-11-17017 November 1981 Motion to Take Official Notice of Existence & Content of Listed Documents Relevant to Contention 21.Validity of Info in Documents Could Be Subj to Dispute.Certificate of Svc Encl.Related Correspondence 1999-07-12
[Table view] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20138A9521985-10-0909 October 1985 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20027D4441982-11-0202 November 1982 Response to Aslab 821026 Order Requesting Info on RCS Leak Rate Detection.Util Preparing Tech Spec to Limit Increase in Unidentified RCS Leakage to 2 Gpm within 4-h Period ML20052A2751982-04-21021 April 1982 Exceptions to ASLB Initial Decision.Certificate of Svc Encl ML20011A2361981-09-29029 September 1981 Focus of cross-exam & Expert Witnesses.No Expert Witnesses Will Be presented.Cross-exam Will Be Limited to Contentions 4,9,14,20 & 21.Certificate of Svc Encl.Related Correspondence ML20011A2181981-09-29029 September 1981 Submittal of J Amory Affidavit Opposing Applicants' Motion for Summary Dispositon of Contention 17.Certificate of Svc Encl.Related Correspondence ML20010F3641981-08-31031 August 1981 Submission of Safe Energy Alliance List of Proposed Expert Witnesses,Per ASLB 810814 Order.Certificate of Svc Encl. Related Correspondence ML20010C9701981-08-10010 August 1981 Certifies 810812 Svc of Commonwealth of PA Disaster Operations Plan,Annex E,Comments Re Contention 20,memorandum Responding to Util 810727 Ltr,& Luzerne County Facility Emergency Response Plan.Related Correspondence ML18026A5081980-10-27027 October 1980 Certifies Svc of Applicants' Motion for Summary Disposition of Contention 16 W/Supportive Statement of Matl Facts & Wj Rhoades Affidavit,On 801027 ML18030A5161980-10-21021 October 1980 Notice of Address Change ML18030A1391980-08-22022 August 1980 Certifies Svc of Motion for Partial Summary Disposition of Contention 17,statement of Matl Facts as to Which No Genuine Issue of Fact Exists,Brief in Support of Motion & Rf Lehman Affidavit on 800822 ML19259B3121979-01-15015 January 1979 Provides Notice That Ba Snapp Will Represent Licensee in Proceedings ML19274D2501978-12-28028 December 1978 Provides Notice That AR Yuspeh Will Appear on Behalf of PA Power & Light in Proceedings.Certificate of Svc Encl ML19274D2431978-12-28028 December 1978 Provides Notice That Je Silberg Will Appear on Behalf of PA Power & Light in Proceedings.Certificate of Svc Encl 1985-10-09
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UNITED STATES OF AMERICA'cO Q".p(C NUCLEAR REGULATORY COMMISSION 0//Icy~0@BEFORE THE ATOMIC SAFETY AND LICENSING BO'g Zn the Matter of PE'HNSYLVANIA POWER&LIGHT COMPANY and ALLEGHENY ELECTRIC COOPERATIVE INC.F (Susquehanna Steam Electric Station, Units 1 and 2)88~)))Docket Nos.50-387)50-3))))CERTIFICATE OF SERVICE This is to certify that copies of the foregoing"Applicants'otion For Summary Disposition of Contention 16 (Cooling Tower Discharge)
","Applicants'tatement To Material Facts As To Which There Zs No Genuine Issue To Be Heard (Contention 16)" and ,"Affidavit, Of Walter J.Rhoades Zn Support of Summary Disposition Of Contention 16 (Cooling Tower Discharge)
" were served by deposit in the U.S.Mail, first class, postage prepaid, this 27th day of October, 1980, to all those on the attached Service List.Ja.rib g'ated: October 27, 1980 H UNITED STATES OF AME NUCLEAR REGULATORY
'COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of" PENNSYLVANIA POWER&LIGHT COMPANY and ALLEGHENY ELECTRIC COOPERATIVE,, INC.(Susquehanna Steam Electric Station, Units 1 and 2))))))Docket Nos.50-387)50-388),))).SERVICE LIST Secretary of the Commission U.S.Nuclear Regulatory Commission Washington, D.C.20555 Charles Bechhoefer, Esp.Chairman Atomic Safety and Licensing Board Panel U."S.Nuclear Regulatory Commission Washington, D.C.20555 Mr.Glenn O.Bright A'tomic Safety and Licensing Board Panel U.S.Nuclear Regulatory Commission Washington, D.C.20555 Dr.Oscar H.Paris Atomic Safety and Licensing Board Panel U.S.Nuclear Regulatory Commission Washington, D.C.20555 Atomic Safety and Licensing~Board PanelU.S.Nuclear Regulatory Commission Washington, D.C.20555, Docketing and Service Section Office of the Secretary U.S.Nuclear Regulatory Commission Washington, D.C.20555 Dr.Judith H.Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Susquehanna Environmental Advocates c/o Gerald Schultz, Esquire Pqst Office Box 1560 Wzlkes-Barre, Pennsylvania 18703 Mrs.Irene Lemanowicz,, Chairpez son The Citizens Against Nuclear Danger Post Office Box 377 R.D.1 Bezwick, Pennsylvania 18603 Ms.Colleen Marsh 558 A, R.D.N4 Mt., Top, Pennsylvania 18707
-2 James M.Cutchin, ZV, Esp.Office of the Executive Legal Director U.S.Nuclear Regulatory Commission Washington, D.C.20555 Karin W.Carter, Esp.Department of Environmental Resources Commonwealth of Pennsylvania 505 Executive House Post Office Box 2357 Harrisburg, Pennsylvania 17120 Mr.Thomas M.Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania Post, Office Box 2063 Harrisburg, Pennsylvania 17120 Atomic Safety and Licensing.Appeal Board Panel U."S.Nuclear Regulatory Commission Washington, D.C.20555 lj L' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
(/a(1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POWER ALLEGHENY ELECTRIC (Susquehanna Steam Units 1 and 2))AND LIGHT COMPANY;)COOPERATIVE, INC.))Electric Station,))Docket Nos.50-387 50-388~NRC STAFF'S ANSWER IN SUPPORT OF APPLICANTS'OTION TO ESTABLISH A DISCOVERY SCHEDULE FOR SAFETY ISSUES INTRODUCTION On October 7, 1980, Applicants filed"Applicants'otion to Establish-Discovery Schedule for Health and Safety Issues." Citing the significant reduction that has occurred in the predicted time period between issuance of the Final Environmental Statement (FES)and the Safety Evaluation Report (SER), the Applicants'tate that it no longer appears feasible to await completion of a hearing on environmental issues before restarting discovery on safety issues, and request that the Board"reinstate the discovery process." For the reasons discussed below the NRC Staff supports the Applicants'otion.
DISCUSSION In its"Memorandum and Order on Discovery Motions (II)" the Board suspended all discovery obligations with respect to safety and combined safety/environ-mental contentions until after the hearing of environmental issues is completed.
-The Board cited among its reasons for taking that action the fact that such a postponement would not adversely affect the ability of any party to prepare for hearing or prevent the coranencement of the hearing on a timely basis./Another of its purposes was to reduce what it viewed 3/to be the then heavy demands of the discovery process on Intervenors.-
As the Applicants point out, changed circumstances support reconsideration of the Board's decision to suspend discovery on safety contentions until the hearing of environmental issues is completed.
At the time the Board made its decision to suspend discovery on safety issues it appeared, based on the time period between issuance of the Final Environmental Statement (FES)and the Safety Evaluation Report (SER)and SER Supplement, that the hearing on safety issues could not begin until almost a year after the hearing on environmental issues had begun.~4/Based on more recent estimates of the schedule for issuing the FES and the SER it now appears that waiting until after completion of the hearing on environmental issues to reinstate discovery obligations on safety issues could result in unnecessary delays in both the start of the hearing on safety issues and completion 1/LBP-79-31, 10 NRC 597, 605.(October 30, 1979).2/Id.g3 Id.4/Id. of the entire proceeding.
-The currently predicted time span between 5/issuance of the FES and the SER is one month.The FES and the SER are scheduled to be issued on January 1 and February 1, 1981respectively.-
6/It would appear prudent to reinstate discovery obligations on safety issues now while the time demands of this proceeding on parties are relatively light.After completion of the hearing on environmental issues, the duty to prepare proposed findings and conclusions on environmental issues and the obligation to complete discovery and prepare for the hearing on safety issues would impose conflicting time demands on all parties to the proceeding.
CONCLUSION For the reasons set forth above the Staff believes that the Applicants'equest for the reinstatement of suspended discovery obligations on safety issues should be granted.Respectfully submitted,+~~Xi l James M.Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of October, 1980 5/See: Letter from Staff Counsel to Licensing Board Members dated July 10, 1980 (copy attached).
Q6"Interim Blue Book," NUREG-0580, (August 1, 1980), page 2-27.
~pa RICING c'4 0'i:.'~;:glftL
-+4t4+~'NITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C.20555 July 10, 1380 Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.20555 Dr.Oscar H.Paris Atomic Safety and Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.20555 Mr.Glenn 0.Bright Atomic Safety-and.l.icensing Board U.S.Nuclear Regulatory Commission Washington, D.C.-20555 Gentlemen:
In the Matter of Pennsylvania Power and Light Co.Allegheny Electric Cooperative, Inc.(Susquehanna Steam Electric Station, Units 1 and 2)Docket Nos.50-287, 50-388 At the Special Prehearing Conference held on January 29-31, 1979, I agreed to keep the Board and the parties advised of significant changes in estimated dates for issuance of certain Staff documents.(Tr.at 368.)I have been informed that the Staff's current estimated dates for issuance of the Final'nvironmental Statement (FES), Safety Evaluation Report (SER)and SFR Supplement are early December 1980, early February 1981 and late May 1981, respectively.
Thus the predicted time span between issuance of the FES and issuance of the SER continues to grow shorter.It is now about two months rather than seven months as was predicted when the Board issued its Discovery Order II on October 30, 1979.Based-on the longer time span the Board currently plans to wait until after completiorf of the environmental phase of the hearing to establish a schedule for discovery on safety contentions't now appears that the Board's current plan for scheduling discovery on safety contentions, when coupled with the time involved should intervenors file additional contentions based on"new information" in the FES as allowed by the Board's Order of June 24', 1980, could result in unnecessary delay in both the start of the safety phase of the hearing and the completion of the proceeding.
I will advise the Board and the parties of further significant changes, if any, in the estimated dates for issuance of the FES, the SER and the SER Supplement.
Sincerely, James M.Cutchin, IY Counsel for NRC Staff cc: Jay Silberg, Esq.Dr.Judith H.Johnsrud Mr.Thomas M.Gerusky Ms.Colleen Marsh Mrs.Irene Lemanowicz Susquehanna Environmental Advocates Bryan A.Snapp, Esq.Mr.Robert M.Gallo Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board Secretary UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POWER AND LIGHT CO.ALLEGHENY ELECTRIC COOPERATIVE, INC.(Susquehanna Steam Electric Station, Units 1 and 2))Docket Nos.50-387 50-388 CERTIFICATE OF SERVICE I hereby certify that copies of"NRC STAFF'S ANSWER IN SUPPORT OF APPLICANTS'OTION TO ESTABLISH A DISCOVERY SCHEDULE FOR SAFETY ISSUES," dated October 27, 1980, in the above-captioned proceeding, have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 27th day of October, 1980:*Charles Bechhoefer, Esq., Chairman Atomic Safety 8 Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.20555*Mr.Glenn 0.Bright, Member Atomic Safety 5 Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.20555*Dr.Oscar H.Paris, Member Atomic Safety 5 Licensing Board U.S.Nuclear Regulatory Commission Washington, D.C.20555 Jay Silberg, Esq.Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.Washington, D.C.20036 Bryan A.Snapp, Esq.Pennsylvania Power 8 Light Company Two North Ninth Street Allentown, Pennsylvania 18101 Dr.Judith H.Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr.Thomas M.Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P.0.Box 2063 Harrisburg, Pennsylvania 17120 Ms.Colleen Marsh Box 538A, RD84 Mountain Top, Pennsylvania 17120 Mrs.Irene Lemanowicz, Chairperson The Citizens Against Nuclear Dangers P.0.Box 377 RDPl Berwick, Pennsylvania 18503 *Richard S.Salzman, Esq., Chairman Atomic Safety 5 Licensing Appeal Board U.S.Nuclear Regulatory Commission Washington, D.C.20555*Dr.John H.Buck, Member Atomic Safety 8 Licensing Appeal Board U.S.Nuclear Regulatory Commission Washington, D.C.20555"Mr.Thomas S.Moore, Member Atomic Safety 8 Licensing Appeal Board U.S.Nuclear Regulatory Commission Washington, D.C.20555"Atomic Safety 5 Licensing Board Panel U.S.Nuclear Regulatory Commission Washington, D.C.20555+Atomic Safety&Licensing Appeal Board Panel U.S.Nuclear Regulatory Commission Washington, D.C.20555"Secretary U.S.Nuclear Regulatory Commission ATTN: Chief, Docketing 8 Service Branch Washington, D.C.20555 Susquehanna Environmental Advocates P.0.Box 1560 Wilkes-Barre', Pennsylvania 18703 Mr.Robert M.Gallo Resident Inspector P.0.Box 52 Shickshinny, Pennsylvania 18655 Karin W.Carter, Esq.Department of Environmental Resources 505 Executive House P.0.Box 2357 Harrisburg, Pennsylvania 17120 James M.Cutchin, IV Counsel for NRC Staff