ML19211A413
| ML19211A413 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/03/1979 |
| From: | Cohen W, Kennard N PENNSYLVANIA, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7912180162 | |
| Download: ML19211A413 (6) | |
Text
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h UNITED STATES OF AMERICA y
d BEFORE THE NUCLEAR REGULATORY COMMISSI0hc 67 QpA
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OP In The Matter of METROPOLITAN N_
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EDISON COMPANY, et al.
Docket No. 50-289 (Three Mile Island Unit 1)
(Restart)
PETITION FOR LEAVE TO FILE A BRIEF ADDRESSING ISSUES RAISED BY THE RESPONSE OF NRC STAFF TO THE CONSUMER ADVOCATE'S PETITION FOR NRC FUNDING OF INTERVENOR WITNESSES The Consumer Advocate of Pennsylvania, participating in the above-captioned action as an interested state agency, hereby petitions this Honorable Commission and the Secretary thereof for leave to file a Brief of issues raised by the NRC staff in its Response to the Petition of the Consumer Advocate requesting funding for intervenor witnesses in the above-captioned action and in furtherance thereof avers as follows:
1.
The Consumer Advocate of Pennsylvania has filed with this Honorable Commission a " Petition To Seek NRC Funding For Consumer Intervenors To Finance Witness Expenses."
2.
On November 21, 1979 the legal staff of the NRC filed a Response to the above-described Petition of the Consumer Advocate, which raises issues which could not have been anticipated by the Consumer Advocate when he filed his original Petition.
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3.
The issues to be adjudicated in the above-captioned action are newel and of first impression, and may necessitate a modification of this lionorable Commission's general policy against the intervenor funding.
The Consumer Advocate, therefore, believes that all issues presented by his Petition should be fully briefed and brought to this Commission's attention.
4.
The Consumer Advocate has prepared, for consideration by this Honorable Commission, and filed simultaneously with this Petition a Brief addressing issues raised by the Staff in its Response to the Petition of the Consumer Advocate for funding of intervenor witnesses.
5.
Section 2.730(c) of 10 CFR provides that a moving party has no right to reply to an answer to its motion, except as permitted by the Secretary or the Assistant Secretary of the NRC. The Consumer Advocate is, therefore, filing this Petition for leave to file in the belief that such Petition may be necessary to invoke the discretion of
..is Honorable Commission and the Secretary thereof.
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WHEREFORE, the Consumer Advocate of Pennsylvania respectfully requests that he be granted leave to file a Brief of Issues raised by the staff in its Response to the Petition of the Consumer Advocate for funding of intervenor witnesses.
Respectfully submitted,
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.I' Walter W. Cohen Consumer Advocate
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/Ngiman J. Kennard' / '
Assistant Consudef Advocate
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Date:
December 3, 1979 1599 077 3
UNITED STATES OF AMERICA NUCLEAR REGUIA'IORY COMISSIQ1 BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD In the Matter of MEI'ROPOLITAN EDISON COMPANY, et al.
Ibcket No. 50-289 (Restart)
('Ihree Mile Island, Unit 1)
Lt.tuwICATE OF SERVICE I, Walt.er W. Gohen, hereby certify that I have this 3rd day of December,1979 served copies of the attached statanent of the Pennsylvania Office of (bnsumer Advocate's Petition For Inave 'Ib File A Brief Addressing Issues Raised By The Response Of NFC Staff To The Consumer Advocate's Petition For NPC Funding Of Intervenor Witnesses on each of the persons named in the attached service list by causing the same to be deposited in envelopes addressed to said persons, first class, postage prepaid, and deposited with the United States Postal Service at 813 bhrket Street, Harrisburg, Pennsylvania 17105.
Respectfully subnitted, 1J;
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Walter W. Cohen Consumer Advocate 1599 078
UNITED STATES OF AMERICA NUCLEAR REGUIJdORY COMMISSION BEFORE THE ATOMIC SAFEIY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY, et al.
Docket No. 50-289 (Restart)
(Three Mile T land, Unit 1)
Ivan W. Smith, Esq.
Ms. Frieda Berryhill, Chairman Atcmic Safety & Licensing Board Oaalition for Nuclear Power U.S. Nuclear Regulatory (bmmission Plant Postponement Washington, DC 10555 2610 Grendon Drive Wilmington, DE 19808 Dr. Walter H. Jordan Atcmic Safety & Licensing Board Mr. Ibbert Q. Pollard 881 W. Outer Drive Chesapeake Energy Alliance Chk Ridge, 'IN 37830 609 bbntpelier Street Baltimore, MD 21218 Dr. Linda W. Little 5000 Hermitage Drive Karin W. Carter, Esq.
Raleigh, NC 27612 Assistant Attorney General 505 Executive Ibuse Secretary P.O. Box 2357 Nuclear Pegulatory Conmission Harrisburg, PA 17120 Washington, DC 20555 Ellyn P. Weiss, Esq. (UCS)
George F. Trowbridge, Esq.
Sheldon, Harnon, Ibisman & Weiss Shaw, Pittman, Potts & Trowbridge 1725 I Street, hW, Suite 506 1800 M Street, N.W.
Washington, DC 20006 Washington, D.C.
Chauncey Kepford, Esq.
Counsel for NRC Staff Environmental Coalition on Office of Executive Legal Director htclear Power U. S. Nuclear Regulatory Conmission 433 Orlando Avenue Washington, D.C. 20555 State College, PA 16801 Ms. Marjorie M. Aanodt Ibbert L. Knupp, Esq.
R.D. #5 Assistant Solicitor Coatesville, PA 19320 County of Dauphin P.O. Box P, 407 N. Front Street Ms. Iblly S. Keck, Icg. Chairman Harrisburg, PA 17108 Anti-Nuclear Group Representing York (ANGRY)
Mr. Marvin I. IEwis 245 W. Philadelphia Street 605 Bradford Terrace York, PA 17404 Philadelphia, PA 19149 1599 079
e Jordan D. Cunningham, Esq.
Fox, Farr & Cunningham 2320 North Second Street Harrisburg, PA 17110 Karin P. Sheldon, Esq. (PANE)
Sheldon, Harmon, Ibisman & Weiss 1725 I Street, NW, Suite 506 Waslungton, DC 20006 John A. Levin, Esq.
Assistant Counsel Pa. Public Utility Commission Ibom G-28, North Office Building Harrisburg, PA 17120 Mr. Steven C. Sholly 304 South Market Street Mechanicsburg, PA 17055 Theodore Mler, Esq.
Attorney for Three Mile Island Alert, Inc. ('IMIA)
P.O. Box 1547 Harrisburg, PA 17105 Hon. Mark Cohen 512 E-3,bhin Capitol Building Harrisburg, PA 17120 Mr. Thomas Gerusky Bureau of Radiation Protection Department of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 J. G. Herbein, Vice President Metropolitan Edison Company P.O. Box 542 Reading, PA 19603 1599 080