ML19209C528
| ML19209C528 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/07/1979 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 7910160088 | |
| Download: ML19209C528 (3) | |
Text
September 7, 1979 l19#/
UNITED STATES OF AMERICA 6
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NUCLEAR REGULATORY COMMISSION h[/
t BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
{2 cf dy V In the Matter of IIETROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Three Mile Island Nuclear Station, )
Unit Mc., 1)
)
LICENSEE'S ANSWER TO PETITION FOR LEAVE TO INTERVENE BY ANTI-NUCLEAR GROUP REPRESENTING YORK, DATED AUGUST 29, 1979 Metropolitan Edison Company (Licensee) hereby submits its answer to the Petition for. Leave to Intervene by Anti-Nuclear Group Representing York (Petitioner) dated August 29, 1979, and' received by Licensee's counsel on August 31, 1979.
In accordance with the the Board's Memorandum and Order, dated August 31, 1979, Licensee's answer is confined to the adequacy of the petition from the standpoint of Petitioner's showing of interest and iden-tification of the aspect or aspects of the proceeding as to which intervention is sought.
Licensee's position is that the petition adequatel; sets forth Petitioner's interest in the proceeding and the specific aspect or aspects of the subject matter of the proceeding in which it wishes to intervene.
Counsel for Licensee is advised by Holly S. Keck, who signed the petition as Legislation Chairman for ANGRY, that she is a member of that organization and resides within 15 1147 192 791016006
miles of Three Mile Island.
Thus the petition on its face iden-tifies by name one individual member with an interest in the proceeding who has implicitly authorized Petitioner to represent that interest in the proceeding.
Respectfully submitted, SHAW, PI
, POTTS & TROWBRIDGE M
By f
j s, M
- j
/g feorge F.'Trowbridge Dated:
September 7, 1979 i
1147 193 September 7, 1979 LNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Three Mile Island Nuclear Station, )
Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answer to Petition for Leave to Intervene by Anti-Nuclear Group Representing York, Dated August 29, 1979," dated September 7, 1979, were served upon the fol-lowing persons by deposit in the United States mail, postage prepaid, this 7th day of September, 1979.,
Ivan W.
Smith, Esquire Ms. Holly S. Keck Chairman Legislation Chairman Atomic Safety and Licensing Anti-Nuclear Group Representing York Board Panel 245 West Philadelphia Street U.S. Nuclear Regulatory Commission York, Pennsylvania 17404 Washington, D.C.
20555 James A. Tourtellotte, Esquire (4)
Dr. Walter H. Jordan Office of Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C.
20555 881 Welt Outer Drive Oak Ridge, Tennessee 37830 Docketing and Service Section (21)
Office of the Secretary Dr. Linda W. Little U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C.
20555 Board Panel 5000 He!mitage Drive Raleigh, North Carolina 27612
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M./
M/
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GeoyQe F.
Trowbridge
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47 jg4 Dated: September 7, 1979