ML19254E434

Answer in Support of TMI Alert,Inc 790912 Petition to Intervene.Interest & Procedural Requirements Are Met. Certificate of Svc Encl

ML19254E434
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 7911010101
Download: ML19254E434 (3)

Text

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September 17, 1979 NRC PUBLIC DOCMIENT ROOM g#1 ) mjf UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,-p

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In the Matter of ) h /

METROPOLITAN EDISON COMPANY'

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) Docket No. 50-289 RS

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S ANSWER TO PETITION FOR LEAVE TO INTERVENE BY THREE MILE ISLAND ALERT, INCORPORATED Metropolitan Edison Company (Licensee) hereby submits its answer to an undated Petition for Leave to Intervene by Three Mile Island Alert, Incorporated (Petitioner) . The certif-icate of service attached to the petition indicates that the petition was mailed to undersigned counsel on September 12, 1979, and a copy of the petition was received by undersigned counsel on September 14, 1979. In accordance with the Board's Memoran-dum and Order, dated August 31, 1979, Licensee's answer is con-fined 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 aspect or aspects of the subject matter of the proceeding in which it wishes to intervene. Counsel for Licensee is advised _

that Kathy McCaughin, who signed the petition as Authorized 1283 975 7911010(O{

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Representative of Three M!le Island Alert, Inc., is a member of that organization and resides within 20 miles of Three Mile Island. Thus the petition on its face identifies by name one individual member with an interest in the proceeding who has im-plicitly authorized Petitioner to represent that interest in the proceeding.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By /b/ *

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'fGegfrge F. Trowbridef Dated: September 17, 1979 1283 ')76 e

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September 17, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COI2iISSION 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 OF SERVICE I hereby certify that copies of " Licensee's Answer to Petition for Leave to Intervene by Three Mile Island Alert, Incorporated,"

dated September 17, 1979, were served upon the following persons by deposit in the United States mail, postage prepaid, this 17th day of September, 1979.

Ivan W. Smith, Esquire Kathy McCaughin Chairman Authorized Representative for Atomic Safety and Licensing Three Mile Island Alert, Inc.

Board Panel 23 South 21st Street U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17104 Washington, D.C. 20555 James A. Tourtellotte, Esquire (4)

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

Office of the Secretary Dr. Linda W. Little U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel 5000 Hermitage D;-ive -

Raleigh, North Carolina 27612

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' v'GeopJe F. Trowbridge/

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Dated: Septemter 17, 1979 1283 977