ML19308B454
| ML19308B454 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/13/1979 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001030061 | |
| Download: ML19308B454 (5) | |
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November 13, 1979 l
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l 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,
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(EPICOR-II)
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81 JM (Three Mile Island Nuclear
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g Station, Unit 2)
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4 LICENSEES' ANSWER TO PETITION TO j
INTERVENE AND REQUEST FOR HEARING A
cg', sip' BY SUSQUEHANNA VALLEY ALLIANCE s
/s.'o' co In a Memorandum and Order issued in this docket on October 16, 1979, the Commission ordered Licensees to begin promptly the operation of a filtration and ion exchange system, known as "EPICOR-II," to decontaminate intermediate-level radio-active wastewater at Three Mile Island Nuclear Station, Unit 2
("TMI-2").
See Order 5 1, Memorandum and Order, October 16, 1979.
The Commission also directed Licensees to undertake cer-tain other activities, and imposed certain conditions, attendant to operation of the EPICOR-II system.
Id. at Order TV 2, 3.
The Commission provided, in Order paragraph 5, that i
within twenty days Licensees may file an answer to paragraphs 1, 2 and 3 of the Order, and that Licensees and any other person whose interest may be affected may request a hearing pursuant to 10 C.F.R. S 2.714 for the purpose of challenging all or any part l
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. of paragraphs 1, 2 and 3 of the Order.
The Commission-stated that "[i]n any hearing that may be requested, the issues will be those within the scope of whether (a) paragraphs 1, 2 and 3 of this Order are necessary and sufficient to protect health and safety or to minimi=e danger to life or property, and (b) actions directed under paragraphs 1, 2, and 3 would significantly affect the quality of the human environment."
The Commission further provided, in Order paragraph 5, that the Director of Nuclear Reactor Regulation had been instructed to prepare and issue an order for the modification of the TMI-2 operating license to augment the technical specifications and to include the provisions of paragraphs 1, 2 and 3 of the Order.
The Commission directed that the Director's order ".
shall state that within 20 days of the date of this Order the licensee i
and any other person whose interest may be affected may request a hearing on the proposed amendment pursuant to 10 C.F.R. S 2.714 to be held prior to the amendment of the license, i.e.,
not prior to operation of EPICOR-II but rather prior to the adoption of the formal amendment."
The Director's Order for Modification of License was issued on October 18, 1979.
See 44 Fed. Reg. 61276-8 (Oct. 24, 1979).
A clarifying mmendment to the Director's order was issued on October 26, 1979.
See 44 Fed. Reg. 62633 (Oct. 31, 1979).
The Commission directed that any hearing held pursuant to paragraph 6 of its Order shall be consolidated with any hearing u
, to supplement its petition as required by 10 C.F.R. S 2.714 (b).
Respectfully submitted, SHAW, PITT N, POTTS & TROWBRIDGE k,
=Vn George F. Trowbridge Thomas A.
Baxter 1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100 Counsel for Licensees Dated:
November 13, 1979 G
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UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD j
In the Matter of
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METROPOLITAN EDISON COMPANY,
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(EPICOR-II)
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(Three Mile Island Nuclear
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Station, Unit 2)
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i CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing
" Licensees' Answer to Petition to Intervene and Request for Hearing by Susquehanna Valley Alliance" were served by hand delivery upon those identified below with an aste' risk and upon all others listed below by deposit in the United States mail, first class, postage prepaid, this 13th day of November, 1979.
- Marshall E. Miller, Esqu, ire Iarry B. Selkowitz, Esquire Chairman Widoff, Reager, Selkowitz & Adler, P.C.
Atmic Safety and Licensing Board P.O. Box 1547 U.S. Nuclear Regulatory r - 4=sion Harrisburg, Pennsylvania 17105 Washington, D.C.
20555 Jean Ibyer Kohr, Esquire
- Dr. Richard F. Cole Minney, Meccm & Kohr Atmic Safety and Licensing Board Panel 121 E. King Street l
U.S. Nuclear Regulatory e - iasion Lancaster, Pennsylvania 17602 Washington, D.C.
20555 Albert J. Slap, Esquire Dr. Martin J. Steindler Public Interest Iaw Center of Pb41 Mal %
Atmic Safety and Licensing Board Panel 1315 Walnut Street, Suite 1600 Argonne National Iaboratory Phi 1 Mal %, Pennsylvania 19107 9700 South Cass Avanue Argonne, Illinois 60439 Docketing and Service Sm h.
Office of the Secretary
- Iawrence J. Chandler, Esquire U.S. Nuclear Regulatory re==4=eion Office of the Executive Iagal Dir.rua.
Washington, D.C.
20555 U.S. NLx: lear Regulatory cr==4==4rm Washington, D.C.
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held pursuant to paragraph 5 of the Order.
The Commission found that the public health, safety, and interest require that its order become effective immediately and remain effective notwith-standing the filing of any requests for a hearing.
Order 1 6, Memorandum and Order, October 16, 1979.
This Atomic Safety and Licensing Board was appointed to rule on any requests for hearing under paragraphs 5 or 6 of the Order, and to preside over any hearing that may be held upon those requests.
The Susquehanna Valley Alliance ("SVA"), a citizens group made up of residents of the Susquehanna River Valley, has filed a " Petition to Intervene and Request for a Hearing," dated November 5, 1979, pursuant to both paragraph 6 of the Commission's Order and the Director's Order of October 18, 1979 implementing paragraph 5 of the Commission's Order.
Licensees, in answer to the petition and request pur-suant to 10 C.F.R. S 2.714(c), submit that SVA adequately har I
set forth its interest in the proceeding and identified aspects of the subject matter of the proceeding as to which intervention is sought.
Licensees suggest that prior to any special prehearing conference held pursuant to 10 C.F.R.
S 2.751a, SVA be directed l
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