ML19209C073

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Request to Intervene Submitted by Dauphin County,Pa.Nuclear Facility Is Located within County.Rights & Liabilities of Citizens of Dauphin County May Be Affected by NRC Judgments & Decisions in Proceeding
ML19209C073
Person / Time
Site: Crane Constellation icon.png
Issue date: 08/15/1979
From: Knupp R
KNUPP & ANDREWS
To:
Shared Package
ML19209C064 List:
References
NUDOCS 7910110471
Download: ML19209C073 (1)


Text

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BEFORE THE Sei,c U.S.

NUCLEAR REGULATORY COMMISSION

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THREE MILE ISLAND

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\\j PETITION TO INTERVENE AND NOW, this_l,%

day of August, 1979, comes Robert L.

Knupp, Assistant Solicitor for the County of Dauphi'n, and respectfully petitions to intervene in proceedings before the Nuclear Regulatory Commission involving Three Mile Island, for the following reasons:

1.

The Dauphin County Commissioners are the elected representatives of all of the citizens of Dauphin County and have a statutory duty to protect the health, welfare and safety of the citizens of Dauphin County.

2.

Three Mile Island and the nuclear power station located thereon are physically located within the confiner of Dauphin County.

3.

The rights and liabilities of the citizens of Dauphin County may be af fected by any judgments or decisions made by the Nuclear Regulatory decision and heari.1g issues concerning Unit No. 1 and Unit No. 2 of the Metropolitan Edi o C

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WHEREFORE, Commissioners of Dauphin County respectfully request that the following relief be granted:

(a) That all notices pertaining to any hearings be sent to Assistant Solicitor Robert L. Knupp, Applicant herein, at his office address located at PO Box "P",

407 North Front Street, Harr!sburg, Pennsylvania, 17108.

(b) That copies of notices be sent to John E.

Minnich, Chairman, Dauphin County Board of Commissioners, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania, 17101.

(c) That the Dauphin County Commissioners be allowed to appear and be represented by counsel at any hearings scheduled by the Nuclear Regulatory Commission or any panel appointed by the said Commission relative to Three Mile

Island, the nuclear electrical generating units
thereon, the rights and liabilities of Metropolitan Edison Company, the rights and liabilities of Babcock &

Wilcox, Inc., and any other matters pertaining thereto.

Respectfully submitted:

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Rdbert L. Kndpp W Assistant Solicitor County of Dauphin loQo %6