ML20076F596

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Response to Washington Legal Foundation 830819 Motion for Leave to File Motion to Disqualify Commissioner Gilinsky from Further Participation.Foundation Does Not Meet Intervention Requirements.Certificate of Svc Encl
ML20076F596
Person / Time
Site: Crane 
Issue date: 08/24/1983
From: Weiss E
UNION OF CONCERNED SCIENTISTS
To:
NRC COMMISSION (OCM)
References
NUDOCS 8308260091
Download: ML20076F596 (4)


Text

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DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 13 AW 25 A11:05 0FFCE OF SELqa m

DOCKEimG & SEpyn~;

BEFORE THE NUCLEAR REGULATORY COMMISSION BRANCH In the Matter of

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METROPOLITAN EDISON COMPANY )

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Docket No. 50-289 (Three Mile Island Nuclear

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(Restart)

Station, Unit No.1)

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UNION OF CONCERNED SCIENTISTS' RESPONSE TO MOTION FOR LEAVE OF.THE WASHINGTON LEGAL FOUNDATION TO FILE THE ATTACHED MOTION TO DISQUALIFY COMMISSIONER VICTOR GILINSKY FROM FURTHER PARTICIPATION IN THE ABOVE CAPTIONED PROCEEDINGS On August 19, UCS received a document entitled " Motion for Leave of the Washington Legal Foundation to File the Attached Motion to l

Disqualify Commissioner Victor Gilinsky from further participation in the Above captioned Proceeding." Therein, the Washington Legal Foundation, which has never participated in any fashion in this proceeding, moved the Commission to intervene four years late.

Its desire to intervene is for the sole purpose of advocating Commissioner Gilinsky's disqualification, j

l Since this group does not make even a passing stab at meeting the applicable regulations governing intervention (standing, admissible contentions) much less late intervention (good cause, aosence of other parties to protect its interest, etc.), one must assume that its l

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" motion" is not meant to be taken seriously as a legal document.

Its alternative request to make a limited appearance is equally preposterous. Limited appearers have no right to make motions to the 1

i 8308260091 830824 PDR ADOCK 05000289 G

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. presiding tribunal.

Presumably, however, the purposes of the group have already been met; the press widely reported the contents of its

" motion" several days before it was received by the parties.

Since the accompanying Motion of the Washington Legal Foundation to disqualify Commissioner Victor Gilinsky has no legal status in this c

proceeding, we make no comment on it except to note that a cursory reading indicates that the legal analysis presented therein is approximately on par with the above discussed motion to intervene.

Re trully submitted,

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1 Ellyn eiss Genera Counsel Union of Concerned Scientists l

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4 DOCKETED ussaC

'83 AUG 25 All :05 UNITED STATES OF AMERICA NUCLEAR REGULATORT COMMISSIOf0C IN c?

BRANCH BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of

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HETROPOLITAN EDISON COMPANY

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Docket No. 50-289

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(Restart)

(Three Mile Island Nuclear

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Station. Unit No. 1)

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CERTIFICATE OF SERVICE I hereby certify that copies o~f " UNION OF CONCERNED SCIENTISTS' RESPONSE TO MOTION FOR LEAVE OF THE yASHINGTON LEGAL FOUNDATION TO FILE THE ATTACHED MOTION TO DISQUALIFY COMMISSIONER VICTOR GILINSKY FROM FURTHER PARTICIPATION IN THE ABOVE CAPTIONED PROCEEDINGS" have been served on the following persons by deposit in the United States mail, first class postage, this 24th day of August, 1983.

Nunzio Palladino, Chairman Dr. Linda W. Little U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Wa3hington, D.C. 20555 Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 Frederick'M. B'ernthal Commissioner U.S. Nuclear Regulatory Co,mmission Washington, D.C. 20555 Professor Gary L. Hilhollin 4412 Greenuich Parkway James Asselstine Commissioner Washington,.D.C. 20007 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Judge cary.J. Edles, Chairman Atomic Safety and Licensing Victor Ctlinsky, Comissioncir Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission, Washington..D.C. 20555 Washington, D.C. 20555 i

Thomas Roberts, Commissioner Judge John H. Buck U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Ivan V. Sruith, Chairman Washington D.C. 20555 Atomic Safety and Licensing Board Panel

' Judge Reginald L. Gotchy U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Vashington. D.C. 20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Dr. Valter H.

Jordan Washington D.C. 20555 Atomic Sa fety and Licensing Dosed Panet Judge Christine N.

Kohl 881 Vest Outer Drive Atomic Sa fety and. Licensing Oak Ridge. Tennessee 37830 Appeat Board Panet U.S. Nuclear Regulatory Commission

h. D. C. 20355

4 Ms. Cail 0.

Phelps Mrs. Marjorie Aamodt 245 West Philadelphia Street R.D.

  1. 5 Coatsville. Pennsylvania 19320 York. Pennsylvania 17404 Steven C. Sholly Robert Adler. Esq.

Union of Concerned Scientists Assistant Attorney Cencral 1346 Connecticut Ave.. N.V.

505 Executive Ibuse Suite 1101 P.O. Dor 2357 Vashington, D.C. 20036 Harrisburg, Pennsylvania 17120 Joseph R. Gray Louise Bradford Office of Executive Legal Director Three Mlle Island Alert Nuclear Regulatory Commission U.S.

325 Perfer Street Vashington, D.C. 20555 Hrrrisburg, Pennsylvania 17102 Tliomas Baxter Es Shaw, Pittman, Pobts 1 Jordan D. Cunningham, Esq.

Trowbridge For, Farr & Cunningham 1800 H Street. H.V.

2320 North Second Street Va-hington, D.C. 20036 Herrisburg, Pennsylvania 17110

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Docketing and Service Section Dr. Judith H. Johnsrud Office,of the Se,cretary Dr. Chauncey Kepford U.S. Nuclear Resulatory Commission Environmental Coalition on Vashington, D.C. 20555 Nuclear Power 433 Orlando~ Avenue State College, PA 16801 Villiam S. Jordan, III

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Hrraon & Veiss 1725 I Street N.V.

Suite 506

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Washington, D.C. 20006 John A. Levin. Esq.

Assistant Counset l

Pennsylvania Public Utility Commission P.O. Bor 3265.

Harrisburg, Pennsylvania 17320 l

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