ML19209C529

Answer to Joint Newberry Township TMI Steering Committee & 11 Residents of Township Undated Petition to Intervene. Petition Satisfies Criteria Re Intervention.Aslb Decision Should Await Contentions.Certificate of Svc Encl

ML19209C529
Person / Time
Site:	Three Mile Island
Issue date:	09/07/1979
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7910160091
Download: ML19209C529 (3)

Text

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.*... September 7, 1979 d Eli UNITED STATES OF AMERICA ph.

NUCLEAR REGULATORY COMMISSION g. $ A.

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 'g'f oi ,, , V '

In the Mhtter of ) .

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

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(Three Mile Island Nuclear Station, )

Unit N.o. 1.) )

LICENSEE'S ANSWER TO UNDATED PETITION FOR LEAVE TO INTERVENE BY NEWBERRY TOWNSHIP T.M.I. STEERING COMMITTEE ET AL.

Metropolitan Edison Company .(Licensee.' hereby submite its answer to an undated Petition for Leave to Intervene filed jointly by Newberry Township T.M.I. Steering Committee and eleven nameu residents of Newberry Township (Petitioners) . The certif- '

icate of service attached to the petition indicates that the peti-tion was mailed to undersigned counsel on August 31, 1979, and a copy of the petition was received by undersigned counsel on Sep-tember 4, 1979. In accordance with the Board's MeC randum and Order, dated August 31, 1979, Licensee's answer is confined to the adequacy of the petition from the standpoint of Petitioners' showing of interest and identification of the aspect or aspects of the proceeding as to which intervention is sought.

Licensee agrees that the petition adequately sets forth Petitioners' interest in the proceeding and the specific aspect or aspects of the subject matter of the proceeding in which Peti-tioners wish to intervene. W1.th respect to the Newberry Township k

$ 91016 0 () 7/

T.M.I. Steering Committee, an unincorporated association, one of the affidavits attached to the petition identifies Mr. Mickey Minnich as the Chairman of the Steering Committee and as a resi-dent of Newberry Township. Thus the petition on its face ident:-

fies by name at leasa one individual member of the Steering Com-mittee with an interest in the proceeding who has implicitly authorized the Steering Committee to represent that interest in the proceeding.

Since the only aspects of the proceeding set forth in the petition relate to the psychological impacts associated with the reactivation of Three Mile Island Nuclear Station, Unit No. 1 and resulting impacts on he health and economic welfare of citi-zens and businesses in Newberry Township, the Board's ultimate determination of the allowability of the petition must await the ,

filing of contentions by Petitioners and resolution by the Commis-sion, in accordance with the procedures specified in its Order and Notice of Hearing, dated August 9, 1979, as to whether the issues sought to be raised by Petitioners are legally relevant to this proceeding.

Respectfully submitted, SHAW, PI . N, POTTS & TROWBRIDGE By khj *

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Dated: September 7, 1979 gk7 \96 September 7, 1979 UNITED 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 Undated Petition for Leave to Intervene by Newberry Township T.M.I. Steering Committee Et A1.," 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 Jordan D. Cunningham, Esquire Chaire.n Attorney for Newberry Township Atomic Safety and Licensing T.M.I. Steering Committee Board Panel 2320 North Second Street i U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17110 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 West 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 Hermitage Drive Raleigh. North Carolina 27612

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