ML20138N570

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Answer Supporting TMI Alert (Tmia) Request for Leave to Intervene in Hearing.Answer Does Not Foreclose Any Position to Be Taken in Future W/Tmia in Proceeding.Certificate of Svc Encl
ML20138N570
Person / Time
Site: Crane 
Issue date: 11/01/1985
From: Hensley M
HUNTON & WILLIAMS, HUSTED, C.A.
To:
Atomic Safety and Licensing Board Panel
References
CON-#485-059, CON-#485-59 CH, NUDOCS 8511050231
Download: ML20138N570 (4)


Text

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UNITED STATES OF AMEPICA Oj

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NUCLEAR REGULATORY COMMISSION 7

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BEFORE THE ADMINISTRATIVE LAW JUD E-G-

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IN THE MATTER OF:

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GENERAL PUBLIC UTILITIES NUCLEAR

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) Docket No. 50-289(CH)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

MR. HUSTED'S ANSWER TO TMIA'S REQUEST FOR LEAVE TO INTERVENE IN THE HEARING GRANTED CHARLES HUSTED 1.

Three Mile Island Alert, Inc. (TMIA) has an adequate interest in the proceeding and has adequately set forth how that interest may be af fected by the results of the proceeding.

2.

TMIA has adequately set forth the specific aspect or aspects of the proceeding as to which it wishes to intervene.

3.

As Mr. Husted views the Request for Leave to Intervene, TMIA has not set forth any contention that it seeks to have litigated in this proceeding. Under 10 C.F.R.

S 2. 714 (b), of course, TMIA need not have done so at this stage of the proceeding.

One might infer from TMIA's Request, however, that it may desire eventually to enlarge the issues in this proceeding beyond those specified in the 8511050231 851101 PDR ADOCK 05000289 G

PDR QSO3 Notice of Hearing.

Thus, Mr. Udsted wirhes it understood that, in submitting this Answer, he does not intend to foreclose any position that he may wish to take in the future with respect to any contention that TIiIA may raake in this proceeding.

Respectfully submitted, By s/ Maria C.

Hensley Counsel for Charles Husted Hunton & Williams P.O.

Box 1535 Richmond, Virginia 23212 Of Counsel Michael W.

Maupin Hunton & Williams P.O.

Box 1535 Richmond, Virginia 23212 Dated:

November 1, 1985

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

BEFORE THE ADMINISTRATIVE LAh' JUDGE IN THE MATTER OF:

)

GENEPAL PUBLIC UTILITIES NUCLEAR

)

) Docket No. 50-289(CH)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "Mr.

Husted's Answer to TMIA's Pequest for Leave to Intervene in the Hearing Granted Charles Husted," dated November 1, 1985, were served upon those persons on the following Service List by deposit in the United States mail, first class, postage prepaid, this 1st day of November, 1985 Secretary U.S.

Nuclear Regulatory Commission Washington, D.L.

20555 Attention:

Chief, Docketing and Service Section The Honorable Morton B.

Margulies Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 George E.

Johnson, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Board Panel U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555

I axine Woelfling, Esc.

Cffice of Chief Counsel Department of Environmental Resources 505 Executive House P.O.

Box 2357 Harrisburg, Pennsylvania 17120 Deborah B.

Bauser, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C.

20036 Louise Bradford Three Mile Island Alert 1011 Green Street Harrisburg, Pennsylvania 17102

/s/ Maria C.

Hensley Maria C.

Hensley Counsel for Charles Husted Dated:

November 1, 1985 i

l