ML19254E426

Answer in Support of Ucs 790913 Petition to Intervene. Interest & Aspect of Proceeding for Which Intervention Is Sought Are Adequately Identified.Certificate of Svc Encl

ML19254E426
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 7911010087
Download: ML19254E426 (2)

Text

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Y NRc pUELIC September 17, 1979 4 , En W

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'/ e7 jI r ') DOCU3;ENT UNITED STATES OF AMERICA 003f C,) NUCLEAR REGULATORY COMMISSION

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?j 3  : BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s

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In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 -

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(Three Mile Island Nuclear )

Tation, Unit No. 1) )

LICENSEE'S ANSWER TO PETITION FOR LEAVE TO INTERVENE BY UNION OF CONCERNED SCIENTISTS Metropolitan Edison Company (Licensee) hereby submits its answer to the Petition for Leave to Intervene by Union of Concerned Scientists (Petitioner) , dated September 13, 1979, and re ived by Licensee's counsel on September 17, 1979. In accordance with the Board's Memorandum and Order, dated August 11, 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's position is that the petition adequately sets forth Petitioner's interest in the proceeding and the spe-cific aspe.t or aspects of the subject matter of the proceeding in which it wishes to intervene. ))g} { .

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE

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By . . n /f4/y' y ~ Gepf ge ' F. Trowbridgg Dated: September 17, 1979 7911010C h

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~ September 17, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE T12 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) )

CERTIFIC3TE OF SERVICE I hereby certify chat copies of " Licensee's Answer to Petition for Leave to Intervene by Union of Concerned Scientists," dated September 17, 1979, 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 Ellyn R. Weiss, Esquire Chairman Attorney for The Union of Con-Atomic Safety and Licensing Cerned Scientists Board Panel Sheldon, Harmon, Roisman & Weiss U.S. Nuclear Regulatory Commission Suite 506 1725 Eye Street, N.W.

Dr. Walter H. Jordan Washington, D.C. 20006 Atomic Safety and Licensing Board Panel James A. Tourtellotte, Esquire (4) 881 West Guter Drive Office of Executive Legal Director Cak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission Washington, D.C, 20555 Dr. Linda W. Little Atomic Safety and Licensing Docketing and Service Section (21)

Board Panel Office of the Secretary 5000 Hermitage Drive U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27612 Washington, D.C. 20555

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Dated: September 17, 1979 1282 ~ : '