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Category:Legal-Interrogatories and Response
MONTHYEARML0716202312007-06-0505 June 2007 Susquehanna - PPL Susquehanna'S Answer to Eric Epstein'S Petition for Leave to Intervene 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 ML18025A6891979-10-0909 October 1979 Motion for Protective Order and Reply to NRC Staff Motion ML18025A6841979-09-18018 September 1979 Correction to Ecnp Intervenors' Response to Board Memorandum and Orders ML18025A6831979-09-17017 September 1979 Responses of Ecnp Intervenors to Board Memorandum and Order Compelling Intervenors to Answer Applicant and Staff Interrogatories ML18025A6811979-09-17017 September 1979 Applicant'S Answer to Citizens Against Nuclear Dangers' Supplemental Appeal Regarding Discovery Request Number 18 ML18025A0391979-08-0606 August 1979 Applicants' Answer to Motion for Protective Order of Colleen Marsh Et Al ML18025A7371979-06-16016 June 1979 Citizens Against Nuclear Dangers' Replies to the Interrogatories of the NRC Staff and the Applicants and Other Matters ML18025A7231979-05-25025 May 1979 Applicant'S First Set of Interrogatories to Intervenor Susquehanna Environmental Advocates ML18025A7201979-05-25025 May 1979 Applicants' First Set of Interrogatories to Intervenor. ML18025A7221979-05-22022 May 1979 Letter Submitting to the Board Timely Request for Factual Information from the Applicants, and the Commonwealth of PA as the Interested State 2007-06-05
[Table view] 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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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensing Board In the Matter of )
)
PENNSYLVANIA POWER 6 LIGHT COMPANY )
and ) Docket Nos. 5 ALLEGHENY ELECTRIC'OOPERATIVE, INC. ) -38
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
APPLICANTS) ANSWER TO MOTION FOR PROTECTIVE ORDER OF COLLEEN MARSH ET AL In the introduction to their Answers to First Round Applicant Interrogatories (undated, but accompanied by an affidavit dated July 20, 1979), Colleen Marsh et al. ("Marsh" )
asked'hat the Licensing Board issue a protective order pur-suant to 10 CFR 52.740(c) addressed to those interrogatories which Marsh did not. answer.
Applicants have reviewed the answers which Marsh has submitted, both to Applicants'nterrogatories and to those of the Staff. Based upon that review, it appears to Applicants that Marsh has answered Applicants'irst round interrogatories to the extent of information currently available to her. Appli-cants therefore see no necessity for a motion to compel dis-covery. Similarly, the Marsh motion for protective order would appear moot.
Applicants assume that Marsh will supplement her answers to interrogatories as required by 10 CFR 52.740(e), i.e.
as to expert witnesses and their testimony (Interrogatory 19)
and as to matters which though correct when made are no longer true.
Respectfully submitted, SHAW I PZTTMANI POTTS 6 TROWBRXDGE By J y E. Silberg A an . Yuspeh 1800 M Street, N. W.
Washington, D. C. 20036 (202) 331-4100 Dated: August 6, 1979
4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safet and Licensin Board In the Matter of )
)
PENNSYLVANIA POWER 6 LIGHT COMPANY ) Docket Nos. 50-387 and ) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )
)
(Susquehanna Steam Electric Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Applicants'nswer to Motion for Protective Order of Colleen Marsh et al." were served by deposit in the U. S. Mail, first class, postage prepaid, this 6th day of August, 1979, to all those on'he attached Service List.
Jay Sha 1800
,'it f Sx) erg M
an, Street, Potts N. W.
6 T owbridge Washington, D. C. 20036 (202)331-4100 Dated: August 6,, 1979
t UN ITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
PENNSYLVANIA POWER LIGHT COMPANv ) Docket Nos. 50-387 and ) 50-388 ALLGEHENY ELECTRIC COOP ERAT IVE, INC . )
(Susquehanna Steam Electric Station, )
Uni"s 1 and 2) )
SERVICE LIST Charles Bechhoefer, Esquire Docketing and Service Section Chairman Office of the Secretary Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Board Panel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Judith H. Johnsrud Co-Director Mr. Glenn O. Bright Environmental Coalition on Atomic Safety and Licensing Nuclear Power Board Panel 433 Orlando Avenue J. S. Nuclear Regulatory Commission State College, Pennsylvan' 16801 washington; D. C. 20555 Susquehanna Env'onmental Advocates Dr. Oscar H. Paris c/o Gerald Schultz, Esquire Atonic Saf ety and Licensing 500 South River Street Board Panel Wilkes-Barre, Pennsylvania 18702 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mrs. Irene Lemanowicz, Chairman The Citizens Agains" Nuclear Danger Atomic Safety and Licensing Post Office Box 377 Board Panel R. D. 1 U. S. Nuclear Regulatory Commission Berwick, Pennsylvania 18603 Washington, D. C. 20555 Ms. Colleen Marsh Atomic Safety and Licensing Appeal 558 A, R. D. g4 Board Panel Mt. Top, Pennsylvania 18707 U. S. Nuclear Regulatory Commission Washing ton, D. C. 20555 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection James M. Cutchin, IV, Escuire Depar ment of Env'ironmental Resource Of 'ce of the Executive Legal Commonwealth of Pennsylvania Director P. O. Box 2063 U. S. Nuclear Regulatory Commission Harrisbu g, Pennsylvania .17120 Washing" on, D. C. 20555
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