ML19254E425

Answer in Support of People Against Nuclear Energy 790917 Petition to Intervene.Specific Interest & Aspect of Proceeding Related to Intervention Are Adequately Identified.Certificate of Svc Encl

ML19254E425
Person / Time
Site:	Three Mile Island
Issue date:	09/17/1979
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911010080
Download: ML19254E425 (3)

Text

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NRC PUBLIC DOCUMENT ROOM

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UNITED STATES OF AMERICA  ;- V-NUCLEAR REGULATORY COMMISSION W r -.

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .

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In the Matter of )

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METROPOLITAN EDISON COhPANY ) Docket No. 50-289

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(Thrt_ Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S ANSWER TO PETITION FOR LEAVE TO INTERVENE BY PEOPLE AGAINST NUCLEAR EFERGY Metropolitan Edison Company (Licensee) hereby submits its answer to the Petition for Leave to Intervene by People Against Nuclear Energy (Petitioner) , dated September 14, 1979, and received by Licensee's counsel on September 17, 1979. In accordance with 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 identification of the aspect or aspects of the proceeding as to which intervention is sought.

Licensee agrees that the petition adequately sets forth Petitioner's interest in the proceeding and the specific aspect or aspects of the subject matter of the proceeding in which Petitioner wishes to intervene.

Since the only aspects of the proceeding set forth in the petition relate to the psychological impacts associated with the resumption of ;peration of Three Mile Island Nuclear Station, 1282 Ea 79110106 80

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Unit No. 1 and resulting impacts on the stability and health of the area, the Board's ultimate determination of the allowability of the petition must await the filing of contentions by Petitioner and resolution by the Commission, in accordance with the proce-dures specified in its 0; der and Notice of Hear ng, dated August 9, 1979, as to whether the issues sought to be raised by Peti-tiener are legally relevant to this proceeding.

Respectfully submitted, SHAW, PI T EN, POTTS & TROWP'*.IDGE By

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gedrge F."Trowbridge Dated. September 17, 1979 1282 E' e

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September 17, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE N SERVICE I hereby certify that copies of " Licensee's Answer to Petition for Leave to Intervene by People Against Nuclear Energy," dated September 17, 1978, were served upon the following persons by deposit in the United States mail, postage prepaid, this 17th day of Septem-ber, 1979.

Ivan W. Smith, Esquire Karin P. Sheldon, Esquire Chairman Attorney for People Against Atomic Safety and Licensing Nuclear Energy Board Panel Sheldon, Harmon, Roisman & Weiss U.S. Nuclear Regulatory Commission Suite 506 Washington, D.C. 20555 1725 Eye Street, N.W.

Washington, D.C. 20006 Dr. Walter H. Jordan Atomic Safety and Licensing James A. Tourtellotte, Esquire (4)

Board Panel Office of Executive Legal Director 881 West Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Dr. Linda W. Little Docketing and Service Section (21)

Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory Commission 5000 Hermitage Drive Washington, D.C. 20555 Raleigh, North Carolina 37612 P

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Dated: September 17, 1979 -

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