ML19209C526

Answer to Sc Sholly 790820 Petition & 790904 Supplemental & Amended Petition to Intervene.Applicant Has No Objection to Intervention.Certificate of Svc Encl

ML19209C526
Person / Time
Site:	Crane
Issue date:	09/13/1979
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
References
NUDOCS 7910160080
Download: ML19209C526 (3)

Text

_

d 9-September 13, 1979

/

t

\\

is 4F s$# 'l j'*/ )-

2 c

UNITED STATES OF AMERICA g

NUCLEAR REGULATORY COMMISSION j

• S" I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

METROPOLITAN EDISON COMPANY

)

Docket No. 50-289

)

(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

LICENSEE'S ANSWER TO PETITION TO INTERVENE BY STEVEN C. SHOLLY j

On August 20, 1979, Steven C. Sholly (Petitioner) filed with the Secretary of the Nuclear Regulatory Commission a petition to intervene in this proceeding.

This petition was followed by a supplemental and amended petition dated September 4,

1979.

Copies of both documents were received simultaneously by counsel for Metropolitan Edison Company (Licensee) from the NRC Docketing and Service Section on September 12, 1979.

In accordance with the Board's Memorandum and Order, dated August 31, 1979, Licensee's answer is confined 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.

Petitioner's contentions, which are included in the petition, will be addressed at a sub-sequent time.

\\\\47

\\15 C,

10160 ()I 79

Petitioner apparently seeks intervention pursuant to Section 2.714 of the Rules of Practice "as a full participant by means of intervention" rather than a limited appearance pursuant to Section 2.715.

Licensee's position is that the petition adequately sets forth Petitioner's interes* in the proceeding.

Petitioner has not expressly responded to the requirement in the Commission Order and Notice of Hearing dated August 9, 1979, and in Sec-I tion 2.714 (a) (2) of the Rules of Practice that the petition set forth the specific aspace e "pects_of_the_ proceeding in-which-he desires to intervene.

Petitioner has, however, included in his petition a lengthy set of contentions.

While some of these are clearly outside the scope of the proceeding, others ade-quately identify aspects of the proceeding in which Petitioner is entitled to intervene.

Therefore, Licensee has no objection to the petition on grounds of interest or identification of aspects in which Petitioner wishes to intervene.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By b)

', jf4+4l *

./

GepgeF. Trowbridge /

Dated: September 13, 1979 1147 176 September 13, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

)

)

METROPOLITAN EDISON COMPA'-

)

Docket No. 50-289

)

(Three Mile Island "uclear

)

Station, Unit No. 1)

)

i CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Ar.swer to Petition to Intervene by-Stever-C-Sholly,' dated September 13, 1979, were served upon the following persons by deposit in the United States mail, postage prepaid, this 13th day of September, 1979.

Ivan W. Smith, Esqui '

Mr. Steven C.

Sholly Chairman 304 South Market Street Atomic Safety and Licensing Mec5anicsbu.'g, Pennsylvania 17055 t

Board Panel U.S. Nuclear Regulatory Commission James A. Tourtellotte, Esquire (4)

Washington, D.C.

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

20555 Dr. Linda W. Little Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 A/

M V

porge F. Trowbridge/

Dated: September 13, 1979 k