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Category:Legal-Correspondence
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Text
March 9, 2007
Ann Marshall Young, Chair Dr. Kaye D. Lathrop Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulator Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. William W. Sager
Administrative Judge
Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
In the Matter of PPL Susquehanna, LLC (Susquehanna Steam Electric Station, Units 1 and 2) Docket Nos. 50-387-LR & 50-388-LR
Dear Administrative Judges:
In response to the Board's request during the March 8, 2007 pre-hearing
telephone conference, please find below the NRC Staff's case citations regarding the
applicability of the proximity presumption.
Private Fuel Storage, L.L.C (Independent Spent Fuel Storage Installation), CLI-99-10, 49 N.R.C. 318, 323-325 (1999).
Tennessee Valley Authority (Sequoyah Nuclear Plant, Units 1 & 2; Watts Bar Nuclear Plant, Unit 1), LBP-02-14, 56 NRC 15, 25-26 (2002).
Respectfully submitted,
/RA/ Jody C. Martin Counsel for the NRC Staff
cc: Marcia Carpentier, Esq.
David R. Lewis, Esq.
Eric Joseph Epstein
Office of Commission Appellate
Adjudication
Office of the Secretary
ATTN: Docketing and Service
