ML19254E429

Answer in Opposition to Mm Aamodt 790912 Petition to Intervene as Full Participant.Specific Interest & Aspect of Proceeding Related to Intervention Have Not Been Identified. Limited Appearance May Be Granted.Certificate of Svc Encl

ML19254E429
Person / Time
Site:	Three Mile Island
Issue date:	09/18/1979
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911010094
Download: ML19254E429 (3)

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September 18, 1979 No UNITED STATES OF AMERICA s-o NUCLEAR REGULATORY COMMISSION

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W BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,,- ,g$ 21

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S ANSWER TO PETITION TO INTERVENE BY MARJORIE M. AAMODT By letter dated September 12, 1979, addressed to the Secretary of the Commission, Marjorie M. Aamodt (Petitioner) has submitted a petition to intervene in this proceeding. A copy of the petition was received by Licensee's counsel from the Docketing and Service Section on September 17, 1979.

Petitioner expresses a preference for attendance as a full intervenor but would, alternatively, attend on a limited appearance basis.

Petitioner has not identified a specific interest in the proceeding. To the extent that interest may be based on proximity to Three Mile Island, such interest at a distance of 45-50 miles from the plant is at best marginal. Further, Peti-tiener has not set forth the specific aspects of the proceeding in which she wishes to intervene. With respect to issues of cost raised by the petition, these are outside the scope of the proceeding. With respect to Petitioner's enumerated safety _

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concerns, none are specifically tied to the hearing issues specified by the Commission in its Order and Notice of Hearing dated August 9, 1979. Accordingly, Licensee proposes that the petition to intervene not be granted but that Petitioner be granted <..cus as a limited appearance.

Respectfully submitted, SHAW, PImTMAN, POTTS & TROWBRIDGE By fMj '

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'g"GgorcjeF.'Trowbri e Dated: September 18, 1979 1283 ')63 6 .

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September 18, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAPI 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 OF SERVICE I hereby certify that copies of " Licensee's Answer to Petition to Intervene by Marjorie M. Aamodt," dated September 18, 1979, were served upon the following persons by deposit in the United States mail, postage prepaid, this 18th day of September, 1979.

Ivan W. Smith, Esquire Ms. Marjorie M. Aamodt Chairman R.D. #5 Atomic Safety and Licensing Coatesville, Pennsylvania 19320 Board Panel U.S. Nuclear Regulatory Commission James A. Tourtellotte, Esquire (4)

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

Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 b) sW w

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Dated: September 18, 1979 _

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