ML19249D343
| ML19249D343 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/15/1979 |
| From: | KNUPP & ANDREWS |
| To: | |
| Shared Package | |
| ML19249D342 | List: |
| References | |
| PELD-790815, NUDOCS 7909240184 | |
| Download: ML19249D343 (6) | |
Text
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BEFORE THE 9
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U.S. NUCLEAR REGULATORY COMMISSION g
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IN RE:
THREE MILE ISLAND A
the 8 9 PETITION TO INTERVENE AND NOW, this l_ % ay of August, 1979, comes Robert L.
Knupp, Assistant Solicitor for the County of Dauphin, 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 confines of Dauphin County.
3.
The rights and liabilities of the citizens of Dauphin County may be affected by any judgments or decisions made by the Nuclear Regulatory decision and hearing issues concerning Unit No. 1 and Unit No. 2 of the Metropolitan Edison Company located on said Island.
N 1001 276 790924 0 hfp
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, Harrisburg, 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:
h *N-Rdbert L. Kndpp W Assistant Solicitor County of Dauphin 3001 271
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=v UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSION f?
is-55 In the Matter of
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EE METROPOLITAN EDISON COMPANI, ET AL. ]
Docket No. 50-289
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EE2 (Three Mile Island Unit No. 1
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5 CERTIFICATE OF SERVICE EE 5E I hereby certify that I have this day served the foregoing document (s)
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upon each person designated on the official service list compiled by y
the Office of the Secretary of the Comission in this proceeding in Es accordance with the requirements of Section 2.712 of 10 CFR Part 2 -
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%1as of P7 sctice, of the Nuclear Regulatory Commission's Rules and ilegulation:
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'd Dated at Washington, D. C. this day of dlO-197
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J u L'~2 LMi, Gi Office <of the Secretary of the Ccmmission E
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UNITED STATES OF AMET.ICA f
NUCLEAR REGULATORY COMMISSION
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. M POLITAN EDISON COMPANY,
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s (Three Mile Island, Unit 1)
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SERVICE LIST Counsel for NRC Staff Honorable Maric Cohen Office of the Executive Legal Director 512 E-3 Main Capical Building U.S. Nuclear Regulatory Connission Harrisburg, Pennsylvania 17120
ashington, D.C.
20555 I
Metropolitan Edison Company George F. Trowbridge, Esq.
ATTN:
J.G. Ee.rbein Shaw, Pite=an, Potts & Trowbridge Vice Tresident
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13']O M Street, N.W.
P.O. Box 542 "ashington, D.C.
20006 Reading, Pennsylvania 19603
!*,arin ". Carter, Esq.
Assistant Attorney General Department of Environmental Resources 709 Health and Welfare Building Harrisburg, Pennsylvania 17120 Ellyn Weiss, Esq.
Sheldon, Har=on, Rois=an and t'eis s 1025 15th Street, N.W.
- 'ashington, D. C.
20005 n
Mr. Ronald Natalie President's Coc=ission on the Accident at Three Mile Island 2100 M Street, N.W.
Washington, D.C.
20037
- c Thot:as Gerusky Bureau of Radiation Protection Department of Environ = ental Resources P.O. Box 2063 Harrisburg, Pennsylvania 17120
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UNITED STATES OF AMEhtICA NUCLEAR REGULATORY CO)D11SSION In the Matter of
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METROPOLITAN EDISON COMPANY,
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(Three Mile Island Unit No. 2)
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CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregning document (s) upon each person designated on the official service lis compiled by the Office of the-Secretary of the Comission in this p,xoceeding in accordance with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Coc=ission's Rules and Regulations.'
Dated at k'ashington, D.C. this
' day of 66 8 197
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Office /of Ahe Secretary of the Commission I
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
__Jyll In the Matter of -
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METROPOLITAN EDISON COMPANT,
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Docket No. (s) 50-320
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U5 (Three Mile Island, Unit 2)
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!D SERVICE LIST
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Chauncey P. Kepford N
Atoxic Safety an'd Licensing Board 433 orlando Avenue f.g U.F. Nuclear Regulatory Comission State College, Pennsylvania 16801 gg Washington, D.C.
20555 Honorable Karin W. Carter
- N Mr. Gustave A. Linenberger Assistant Attorney General J+=
Atonic Safety and Licensing Board Department of Environental Resources 6
U.S. Nuclear Regulatory Comission 709 Health and Welfare Building
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Washington, D.C.
20555 Harrisburg, Pennsylvntda 17120 L
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Dr. Ernest O. Salo, Professor Miss Mary V. Southard
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Fisheries Research Institute, WH-10 Citizens for a Safe Environment College of Fisheries P.O. Box 405 University of Washington Harrisburg, Pennsylvania 17108 Seattle, Washington 98195 Dr. W. Reed Johnson
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Counsel for NRC Staff Atomic Safety and Licandng Appeal
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Officei of the Executive Legal Director Board m--@
U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Cor=nission
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Washington, D.C.
20555 Washington, D.C.
20555
- "7 George F. Trowbridge, Esq.
Metropolitan Edison Company Shaw, Pittman, Potts & Trowbridge ATTN:
J.G. Herbein 1800 "M" Street, N.W.
Vice President Washington, D.C.
20006 P.O. Box 542 g;.y Reading, Pennsylvania 19603
'Eir Alan S. Rosenthal, Esq., Chair =an QF.
Atomic Safety and Licensing Appeal
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Board U.S. Nuclear Regulatory Co= mission E.,J; Washington, D.C.
20555
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Jerome E. Sharfman, Esq.
Atonic Safety and Licensing Appeal Board
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U.S. Nuclear Regulatory Coccission Washington, D.C.
20555 200R OR.SINAt.
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