ML19275A666
| ML19275A666 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/13/1979 |
| From: | Field M AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 7910180089 | |
| Download: ML19275A666 (4) | |
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o UNITED STATES OF AMERICA h
NUCLEAR REGULATORY COMMISSION 7
to S
In the Matter of METROPOLITAN EDISON COMPANY (Three Mile Island Nuclear Docket No. 50-289 Station, Unit No. 1)
PETITION TO MAKE A LIMITED APPEARANCE ON BEHALF OF THE MANUFACTURERS' ASSOCIATION OF BERKS COUNTY The Manufacturers' Association of Berks County moves, pursuant to the Commission's Rules of Practice, 10CFR 2.715(a), to make a limited appearance in the above captioned proceeding.
It has an interest in the subject matter of this action and is so situated that disposition of it may, as a practical matter, impede or impair its ability to protect the interests of its members.
In support of its Petition, Petitioner states the following:
1.
Petitioner is a trade association maintaining its offices at the Abraham Lincoln Motor Inn, P.O.
Box 1178, Reading, Pennsylvania. 19603.
2.
Petitioner was organized in 1919 for the purpose of providing a better business climate for its members.
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3.
Petitioner's membership is presently composed of 275 manufacturing companies located within Berks County.
4.
Petitioner's members employ 47,240 persons which constitutes approximately 15.7% of the total population of Berks County.
5.
The licensee and partial owner of Three Mile Island Nuclear Station, Unit No. 1 (TMI-1), supplies Berks County with 90% of its industrial electrical energy needs and 80% of its residential electrical energy needs.
6.
Petitioner believes the aforesaid facts demon-strate that it is a " person whose interest may be affected by the proceeding" in accord.with the Atomic Energy Act, specifically 42 U.S.C. A.S2239 (a) (1973).
7.
Petitioner's members have compelling property and financial interests in this proceeding.
8.
The present shut down of TMI-l has resulted in and is expected to continue to result in greatly increased energy costs to its members.
Petitioner believes that if these disproportionate increased costs become permanent, some of its members will be forced to curtail operations or relocate manufacturing facilities outside of Berks County.
Petitioner believes.that under these conditions no new manufacturing businesses will locate in Berks County.
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9.
Petitioner notes that one company headquartered in the area has planned a major expansion estimated to cost
$50,000,000.00 annually over a five to eight year period.
It has announced that a decision on whether to locate the expansion within Berks County or at a plant outside of the Commonwealth will be based on a study of availability and costs of energy now and in the future.
- 10. Any order entered in this proceeding which does not permit the return of energy costs in Berks County to the level established prior to July 2, 1979, exclusive of normal increases, will have continuing and detrimental effects on its membership.
- 11. Petitioner wishes to present information concern-ing the property and financial effects on its membership as the result of the continued shut down of TMI-1.
For the foregoing reasons, it is requested that the within Petition be granted.
Respectfully Submitted bb (00, C
Myrca P.
Field ~
Counsel for Manufacturers' Association of Berks County Mid-Atlantic Legal Foundation 1521 Locust Street P h i l a d '_ : p h i a, Pa. 19102 1-(215; 545-1913 Date: September 13, 1979 1184 339
Certificate of Service I hereby certify that a copy of the attached Petition to make a Limited Appearance was mailed, postage prepaid, this 13th day of September, 1979 to the following persons:
Executive Legal Director U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555 George F. Trowbridge Shaw, Pittman, Potts & Trowbridge 1800 M.
Street N.W.
Washington, D.C.
20036 LD16
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