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Category:INTERVENTION PETITIONS
MONTHYEARML20082R6581983-12-0808 December 1983 Pp 11 of Response to Sassafras Audubon Soc & Valley Watch, Inc Contentions ML20082K2541983-11-30030 November 1983 Response to Save the Valley,Inc 831021 Provisional Contentions.Contention 2 Should Be Deferred & Contentions 1 & 3-15 Should Not Be Admitted.Certificate of Svc Encl ML20081A5011983-10-21021 October 1983 Petition of Save the Valley for Leave to Intervene,Listing 15 Contentions Re Integrity of Concrete in safety-related Structures,Electrical Work,Evacuation Plans & Common Mode Failures.Certificate of Svc Encl ML20024E0511983-08-0808 August 1983 Answer Opposing Indiana Sassafras Audubon Soc 830722 Amended Petition to Intervene.Soc Failed to Particularize Group Interests or Member Interest & Failed to Satisfy Injury in Fact Requirement.Certificate of Svc Encl ML20077G0821983-07-26026 July 1983 Amend to Vally Watch,Inc Petition to Intervene & Request for Hearing Re Ol.Affidavits of Members to Establish Standing Encl ML20077C8481983-07-21021 July 1983 Amend to Petition to Intervene in OL Hearing.Petitioner Makes Requisite Showing That Members Have Standing & Have Authorized Petitioner to Represent Interests.Contentions to Be Litigated Identified.Certificate of Svc Encl ML20074A6481983-05-12012 May 1983 Response Opposing Valley Watch,Inc 820427 Petition for Leave to Intervene in Proceeding.Petitioner Fails to Estabish Sufficient Interest in Proceeding to Establish Standing as Matter of Right or Discretion.W/Certificate of Svc ML20074A4811983-05-12012 May 1983 Response W/O Objection to Save the Valley Petition for Leave to Intervene,Provided Applicant May Object to Contentions & Right to Hearing After Petition Suppl Filed. Certificate of Svc Encl ML20074A4561983-05-12012 May 1983 Answer to Indiana Sassafras Audubon Society (Isas) Petition for Leave to Intervene.Isas Fails to Establish Right to Intervene.Certificate of Svc Encl ML20073P9811983-04-25025 April 1983 Petition of Save the Valley to Intervene in OL Proceeding, Listing Contentions ML20073P9871983-04-19019 April 1983 Petition of Valley Watch,Inc to Intervene in OL Proceeding, Listing Contentions 1983-08-08
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20082R6581983-12-0808 December 1983 Pp 11 of Response to Sassafras Audubon Soc & Valley Watch, Inc Contentions ML20082K2541983-11-30030 November 1983 Response to Save the Valley,Inc 831021 Provisional Contentions.Contention 2 Should Be Deferred & Contentions 1 & 3-15 Should Not Be Admitted.Certificate of Svc Encl ML20081A5011983-10-21021 October 1983 Petition of Save the Valley for Leave to Intervene,Listing 15 Contentions Re Integrity of Concrete in safety-related Structures,Electrical Work,Evacuation Plans & Common Mode Failures.Certificate of Svc Encl ML20024E0511983-08-0808 August 1983 Answer Opposing Indiana Sassafras Audubon Soc 830722 Amended Petition to Intervene.Soc Failed to Particularize Group Interests or Member Interest & Failed to Satisfy Injury in Fact Requirement.Certificate of Svc Encl ML20077G0821983-07-26026 July 1983 Amend to Vally Watch,Inc Petition to Intervene & Request for Hearing Re Ol.Affidavits of Members to Establish Standing Encl ML20077C8481983-07-21021 July 1983 Amend to Petition to Intervene in OL Hearing.Petitioner Makes Requisite Showing That Members Have Standing & Have Authorized Petitioner to Represent Interests.Contentions to Be Litigated Identified.Certificate of Svc Encl ML20074A6481983-05-12012 May 1983 Response Opposing Valley Watch,Inc 820427 Petition for Leave to Intervene in Proceeding.Petitioner Fails to Estabish Sufficient Interest in Proceeding to Establish Standing as Matter of Right or Discretion.W/Certificate of Svc ML20074A4811983-05-12012 May 1983 Response W/O Objection to Save the Valley Petition for Leave to Intervene,Provided Applicant May Object to Contentions & Right to Hearing After Petition Suppl Filed. Certificate of Svc Encl ML20074A4561983-05-12012 May 1983 Answer to Indiana Sassafras Audubon Society (Isas) Petition for Leave to Intervene.Isas Fails to Establish Right to Intervene.Certificate of Svc Encl ML20073P9811983-04-25025 April 1983 Petition of Save the Valley to Intervene in OL Proceeding, Listing Contentions ML20073P9871983-04-19019 April 1983 Petition of Valley Watch,Inc to Intervene in OL Proceeding, Listing Contentions 1983-08-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20211P1421986-12-16016 December 1986 Order Terminating CPPR-170 & CPPR-171 for Marble Hill Nuclear Generating Station ML20215E6651986-12-16016 December 1986 Notice of Withdrawal of Application for OLs for Marble Hill Nuclear Generating Station,Per Util 850404 Motion to Terminate Proceedings.Aslb Issued Memorandum & Order LBP-86-37 on 861103,terminating OL Proceeding ML20215N6211986-11-0303 November 1986 Memorandum & Order LBP-86-37,terminating OL Proceeding,In Response to Applicant 850404 Motion.Served on 861104 ML20214K7331986-08-19019 August 1986 Response to Applicant 860702 Suppl to Motion to Terminate Proceedings & NRC 860721 Response to Board 860530 Memorandum & Order.Applicant Cannot Invoke Jurisdiction of NRC & ASLB W/O Accepting Conditions.Certificate of Svc Encl ML20214K7711986-08-12012 August 1986 Responds to NRC Staff Position on 860530 Memorandum & Order Re Facility Site Restoration.Opposes Any Decision Not Providing for clean-up of Site ML20205C3001986-08-11011 August 1986 Request for Extension of Time Until 860815 to File Response to Util 860702 Suppl to Motion to Terminate Proceeding & NRC 860721 Response to 860530 Memorandum & Order.Certificate of Svc Encl ML20203E3681986-07-21021 July 1986 Response to Board 860530 Memorandum & Order Re Util 850404 Motion to Terminate Proceeding & Util 860702 Suppl to Motion.In Absence of Issuance of Notice of Hearing,Util Motion Should Be Granted ML20203E4101986-07-21021 July 1986 Supplemental Affidavit of RB Samworth Re Termination of Const in Manner Favoring Reduction or Avoidance of Significant Environ Impacts,Per Util Motion for Withdrawal of Application.Certificate of Svc Encl ML20199L0521986-07-0202 July 1986 Suppl to Motion Supporting Terminating Proceeding.Argues That Board Has No Jurisdiction Over Surrender of Cps. Surrender of Permits to Director of NRR Should Render OL Proceeding Moot ML20206D5771986-06-18018 June 1986 Memorandum & Order Amending ASLB 860530 Order to Allow State of in Sassafras Audubon Soc to File Answer to Applicant Suppl to Motion to Terminate within 10 Days After Svc of Suppl.Encl Served.Served on 860619 ML20198K7291986-05-30030 May 1986 Memorandum & Order Directing That Applicants Suppl 850404 Motion to Terminate OL Proceeding within 30 Days of Svc of Order.Nrc May Respond to Applicants Suppl within 15 Days Following Svc of Suppl.Served on 860602 ML20140G0741986-03-28028 March 1986 Supplemental Answer Supporting Applicant 850404 Motion to Terminate Proceeding.Rb Samworth Affidavit Encl ML20140G1051986-03-27027 March 1986 Affidavit of RB Samworth Determining No Significant Detrimental Impact on or Offsite Resulting from Termination of Proceeding.W/Certificate of Svc ML20100G2871985-04-0404 April 1985 Motion to Terminate OL Proceeding.Cps Surrendered to NRC by .Certificate of Svc Encl ML20082R6581983-12-0808 December 1983 Pp 11 of Response to Sassafras Audubon Soc & Valley Watch, Inc Contentions ML20082K2541983-11-30030 November 1983 Response to Save the Valley,Inc 831021 Provisional Contentions.Contention 2 Should Be Deferred & Contentions 1 & 3-15 Should Not Be Admitted.Certificate of Svc Encl ML20078R6531983-11-10010 November 1983 Motion for Extension Until 831130 to Respond to Indiana Sassafras Audubon Soc & Valley Watch,Inc Amended Petitions to Intervene & Save the Valley Contentions.Certificate of Svc Encl ML20081M5501983-11-10010 November 1983 Motion for Extension to 831130 to Respond to Amended Petitions to Intervene & to Complete Technical Analysis of Numerous Contentions.Motion Granted by ASLB on 831114 ML20081A5011983-10-21021 October 1983 Petition of Save the Valley for Leave to Intervene,Listing 15 Contentions Re Integrity of Concrete in safety-related Structures,Electrical Work,Evacuation Plans & Common Mode Failures.Certificate of Svc Encl ML20024E0511983-08-0808 August 1983 Answer Opposing Indiana Sassafras Audubon Soc 830722 Amended Petition to Intervene.Soc Failed to Particularize Group Interests or Member Interest & Failed to Satisfy Injury in Fact Requirement.Certificate of Svc Encl ML20077G0821983-07-26026 July 1983 Amend to Vally Watch,Inc Petition to Intervene & Request for Hearing Re Ol.Affidavits of Members to Establish Standing Encl ML20077C8481983-07-21021 July 1983 Amend to Petition to Intervene in OL Hearing.Petitioner Makes Requisite Showing That Members Have Standing & Have Authorized Petitioner to Represent Interests.Contentions to Be Litigated Identified.Certificate of Svc Encl ML20090F6761983-07-0101 July 1983 Notices of Appearance in Proceeding.Certificate of Svc Encl ML20074A4561983-05-12012 May 1983 Answer to Indiana Sassafras Audubon Society (Isas) Petition for Leave to Intervene.Isas Fails to Establish Right to Intervene.Certificate of Svc Encl ML20074A4811983-05-12012 May 1983 Response W/O Objection to Save the Valley Petition for Leave to Intervene,Provided Applicant May Object to Contentions & Right to Hearing After Petition Suppl Filed. Certificate of Svc Encl ML20074A6481983-05-12012 May 1983 Response Opposing Valley Watch,Inc 820427 Petition for Leave to Intervene in Proceeding.Petitioner Fails to Estabish Sufficient Interest in Proceeding to Establish Standing as Matter of Right or Discretion.W/Certificate of Svc ML20073P9811983-04-25025 April 1983 Petition of Save the Valley to Intervene in OL Proceeding, Listing Contentions ML20073P9871983-04-19019 April 1983 Petition of Valley Watch,Inc to Intervene in OL Proceeding, Listing Contentions ML20073P9911983-04-16016 April 1983 Petition of Sassafras Audubon Soc of South Central in to Intervene in OL Proceeding,Listing Contentions ML20039B7421981-12-11011 December 1981 Commentary on Rc Deyoung 811208 Supplemental Decision Under 10CFR2.206.Hearing Necessary Since IE Action Allowing Resumption of Concrete Placement Violated Commission Criteria for Plant Reopening.Certificate of Svc Encl ML20062M6301981-12-11011 December 1981 Commentary on Rc Deyoung 811130 Supplemental Decision. Decision Lacks Candor Re Prior Commentary of Ofc of Policy Evaluation.Nrc Established Procedure Extremely Biased. Certificate of Svc Encl ML20140B2651981-08-31031 August 1981 Aug 1981 Official Newsletter of Save the Valley ML20009B2801981-07-10010 July 1981 Addendum to 810414 Petition for Commission Review of NRC 810327 Order to Resume Const at Facility.Independent Engineers Must Defend Determination of 95% Reliability. Certificate of Svc Encl.Related Correspondence ML19343D3821981-04-14014 April 1981 Petition & Supporting Memorandum for Review of NRC 810327 Order to Resume Const.No Written Findings or Conclusions Addressing Adequacy of License Investigation & Repairs of Concrete Placement Have Been Provided ML19323E4901980-05-14014 May 1980 Addl Comments on Intervenor 800507 Pleading Re Resumption of Work.Urges Commission to Consider Encl Affidavits Re Whether IE Should Have Confidence in QC Program & Whether New Madrid Seismic Zone Extension Should Be Made ML19305E5701980-05-0707 May 1980 Comments Re Reopening of Facility,Addressing Licensee 800305 Request for Insp of Safety Matls & Licensee Independent Exam of Concrete.Urges Positive Action Re QC Violations & Improperly Placed Concrete ML19316B1531980-04-29029 April 1980 Response to Save the Valley-Save Marble Hill 800423 Motion to Strike & Objections to Util Bill of Costs Re Civil Action 78-1369 on Appeal.Urges Assigning Costs to State of Ky & Intervenor.W/Certificate of Svc.Related Correspondence ML19211A9511979-12-10010 December 1979 Appeals for Review of Director'S Decision Under 10CFR2.206. Director Abused Discretionary Power in Denying Requests to Reopen Safety Hearings at Meaningful Point in Licensing Process ML19254F8161979-10-20020 October 1979 Motion in Opposition to NRC Motion for Denial of Audubon Society Request for Hearing on NRC 790815 Order Confirming Suspension of safety-related Const.Economic Injury Is Sufficient Status for Hearing ML19323E5131979-09-30030 September 1979 Affidavit Re Us Testing,Facility sub-contractors ML19208D5071979-09-24024 September 1979 Petition Calling for Revocation of Facility CP ML20136B4331979-09-0101 September 1979 Request to Suspend & Revoke CP & to Reopen Safety Hearings. Newspaper Articles Encl ML19207B4561979-08-29029 August 1979 Petition Objecting to Problems at Plant.Problems Include Poor Const & Qa,Nuclear Waste Storage & Lack of Demonstrated Need for Plant.Requests That CP Be Revoked,Safety Hearings Be Reopened & Congressional Hearings Be Initiated ML19259C8621979-08-12012 August 1979 Requests Revocation of Cp,Reopening of NRC Safety Hearings & Start of Planned Congressional Hearings ML19323E5171979-07-22022 July 1979 Affidavit Re Quality of Concrete Pours ML19323E5021979-07-0808 July 1979 Affidavit Re Glaring Concrete Workmanship Defects in & Around Containment & Alleged Improper Attitudes of Newberg- Marble Hill Const Co ML19323E4981979-07-0808 July 1979 Affidavit Re Glaring Concrete Workmanship Defects in & Around Containment & Alleged Improper Attitudes of Newberg-Marble Hill Const Co ML19323E4931979-07-0707 July 1979 Affidavit Re Glaring Concrete Workmanship Defects in & Around Containment & Alleged Improper Attitudes of Newberg- Marble Hill Const Co ML19323E5061979-05-0808 May 1979 Deposition Re Water Leaking,Patches & Honeycombs.Pp 2-22 ML19345B2591979-05-0808 May 1979 Statement of 790508 Appearance in Madison,In Re Const Deficiences.Pp 1-23 1986-08-19
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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-
-)
In the Matter.of' )
) !
PUBLIC SERVICE' COMPANY ) Docket Nos. STN 50-546 OF' INDIANA, INC. ) STN 50-547
)
WABASH VALLEY POWER ) !
ASSOCIATION, INC. )
)
1 (Marble Hill Nuclear )
Generating Station, )
Unita 1 & 2) )
, )
APPLICANTS' ANSWER-TO AMENDMENT TO 4
PETITION.FOR LEAVE TO INTERVENE FILED BY THE INDIANA SASSAFRAS AUDUBON SOCIETY i
j 1. . On July 22, .1983, the Indiana Sassafras i
j- Audubon Society of Lawrence, Greene, Monroe,-Brown, Morgan, and Owen Counties (" Petitioner") served'by mail an amendment j to its petition for leave to intervene on Public Service Company of Indiana, Inc. and Wabash Valley Power Association, Inc. (" Applicants").
- 2. Although Petitioner has amended its orignal i
i petition.as provided for in the Licensing Board's decision of June 30, 1983, Petitioner has failed to particularize its interests or the interests of one of its members that O
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a v , - - - - rmmar.-,,--*, maw -s , e. e4 e .-+ , w -sw ,, e , wi,#.w,-... -e.. - , .**r - -w,-.r,- . - , e +---.,...-w
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j
-m could be adversely.affected by the outcome of this proceed-
'ing. See lO.C.F.R. $$2.714(a)(2), 2.714(d).(1982). It'is well~ settled that no such interest shall be presumed; Petitioner must make a concrete demonstration ~that its interests may be harmed by the outcore of the proceeding.
Nuclear Engineering Co., Inc. (Sheffield, Illinois, Low-Level Radioactive Waste Disposal Site), ALAB-473, 7 N.R.C.
737, 743 (1978).
- 3. In its. amendment, Petitioner alleges both its institutional interests and interests of its individual members. Petitioner alleges that since its activities include educational outings and research in areas within fifty miles of Marble Hill, "there are demonstrable environmental, health, and recreational interests of the organization affected by the outcome of the proceeding."
Further, Petitioner asserts that the organization " suffers recreational and aesthetic-' injury in fact' because its programming includes, and its members use, the land in the potentially impacted area of the plant." As the representa-tive of the interests of three of its members, Petitioner alleges that-because these three members live just within a
-50 mile; radius:of'the plant, their " pursuit of normal
- and recreational activities could be affected." In the f
~a ffidavits of these members, each affiant states "[t] hat my i'
. ._ . .. . . . . _ . - _ , ~ . _ . .-._...- -_. _ . _ , . _ . - . . - _ . _ _ . _ _ - ~ . - - _ _ _ _ . - _ _ _ - . _ _ _
environmental, recreational, health,-and property interests !
are affected by the outcome of the Operating Licensing i
proceedings for Marble Hill Units 1 and 2."
l
- 4. It is well established that an organization can assert standing to intervene either as an institution or as a representative of its members. .Warth v._ Seldin, 422 U.S. 490, 511 (1975); Edlow International Co. (Agent for the Government of India on Application to Export Special Nuclear Material), CLI-76-6, 3 N.R.C. 563, 572-74'(1976).
In one capacity or the other, however, Petitioner must satisfy both the " injury in fact" test and " zone of interest" test to establish standing as a matter of right. Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 N.R.C. 610, 613-14 (1976). See Associa-tion of Data Processing Service Organizations v. Camp, 397 U.S. 150, 153 (1970).
- 5. Either as an institution and or as the representative of its members, Petitioner has failed to satisfy the injury in fact requirement of standing. To satisfy this requirement, "[a] plaintiff must allege that he has been or will in fact be perceptibly harmed by the challenged agency action, not that he can imagine circum-stances in which he could be affected by the agency's action." United States v. Students Challenging Regulatory
, t Agency Procedures (SCRAP), 412 U.S. 669, 688-89 (1973).
Petitioner-has not made the required concrete demonstration that harm will flow to it or its members from a1 result unfavorable to its position. See Nuclear Engineering Co.,
7 N.R.C. at 743. Petitioner's most complete allegation of any potential harm is that it suffers " recreational and aesthetic ' injury in fact'" because it and its members use land within fifty miles of the plant. Such general allegations are not a sufficient basis on which standing to intervene can be'found, because they present nothing more than generalized grievances that are shared in substantially equal measure by a large class of citizens.
See Warth v. Seldin, 422 U.S. at 4997 Edlow International Co., 3 N.R.C. at 576.
6 Since Petitioner has not alleged with particularity how its interests may be harmed by the outcome aof this proceeding, it has failed to demonstrate that it has a direct stake in the outcome of this proceeding and that it is not seeking merely to vindicate its own value prefer-ences. See Sierra Club v. Morton, 405 U.S. 727, 740 (1972);
Nuclear Engineering Co., 7 N.R.C. at 741-43; Allied-General Nuclear Services (Barnwell Fuel Receiving and Storage Station),
'ALAB-328, 3 N.R.C. 420, 421-23 (1976). As recommended in Allied-General Nuclear Services, 3 N.R.C. at 423, Petitioner should have supplied affidavits from its members that J
contained an explanation of specific interests and how they could be harmed by the outcome of this proceeding.
- 7. Petitioner's lack of any direct interest in this proceeding is underscored by the affidavits of.its individual members. Presumably, Petitioner has sought affidavits from individuals who live as close to Marble Hill as possible. It has submitted affidavits from three residents of Columbus, Indiana. According to our calculations, the city limits of Columbus is 47 miles from the Marble Hill site. Petitioner alleges that those three members' " pursuit of normal and recreational activities could be affected."
Such a general allegation is an insufficient basis for standing. Although a finding of standing has not been precluded when based upon residence 50 miles from a plant site, Tennessee Valley Authority (Watts Bar Nuclear Plant, Units 1 and 2), ALAB-413, 5 N.R.C. 1418, 1421 n.4 (1977),
Petitioner must still demonstrate how it or its members could be harmed by the outcome of this proceeding. A general allegation of residence within 50 miles of the site does not provide a basis for standing. Only when very close geographical proximity to the facility is demonstrated will such an allegation, without more, be found sufficient to establish standing. Virginia Electric and Power Co.
(North Anna Nuclear Power Station, Units 1 and 2), ALAB-522, J
9 N.R.C. 54, 55-56 (1979) (members resided "little more than a stone's throw" from the plant).
- 8. Until Petitioner satisfies the injury'in fact test, it is unnecessary to consider whether the interests it asserts are within the zone of interests protected or or. regulated by the. statutes governing the NRC. Public
' Service Company of. Indiana'(Marble Hill Nuclear Generating Station, Units 1 and 2), CLI-80-10, 11 N.R.C. 438, 439 (1980).
- 9. The history of Petitioner's participation at the construction permit stage of this proceeding causes further concern about whether Petitioner has a direct stake in this proceeding. At the construction permit stage, Petitioner was permitted to intervene, only after providing more specific allegations than presented herein, and was later consolidated with other intervenors as Joint Inter-venors. See Public Service Company of Indiana, Inc._(Marble.
l Hill Nuclear Generating Station, Units 1 and 2), LBP-77-52, 6 N.R.C. 294, 298 (1977). Joint Intervenors, however, failed to
( ' file any testimony in support of their contentions and did
(. not participate in any phase of the evidentiary hearing.
' Joint Intervencrs also failed to file any proposed findings i of fact or conclusions of law based on the record developed by the other parties. After repeatedly requesting Joint Intervenors to explain why they should be allowed to
I _
continue as parties, the Licensing Board dismissed Joint Intervenors as parties to the proceedings. Id. at 300-01.
Given that dismal record of prior participation, the Licensing Board must strictly scrutinize the allegations and intent of Petitioner. Being admitted as an intervenor cannot become an end in itself, but Petitioner must have specific interests at stake and must stand prepared to contribute meaningfully to the proceeding. Since Petitioner alleges only generalized grievances, it seems improbable that Petitioner will participate in, or contribute to, this proceeding to an extent greater than it did at the construc-tion permit stage.
- 10. If the Board determines that Petitioner's members residing within fifty miles of the plant may have some legitimate interest affected by this proceeding, it should not routinely grant intervention but require each of them to attend the first prehearing conference to
(
articulate the potential harm to his or her interest.
See, e.g., Virginia Electric and Power-Co., 9 N.R.C. at 55.
l Such a procedure would' allow the Board to probe the extent and genuineness of these interests.
- 11. . Applicants once again reserve their rights to object to the contentions-that Petitioner seeks to have l
litigated in this proceeding until after Petitioner's l
standing has been determined.
Conclusion For_the foregoing reasons, Applicants request that the amended petition for leave to intervene filed by the Indiana Sassafras Audobon Society be denied.
Respectfully submitted, LEBOEUF, LAMB, LEIBY & MacRAE By h . k 1333NehHampshireA ., N.W.
Suite 1100 Washington, D.C. 20036 (202) 457-7500 Attorneys for Public Service Company of Indiana, Inc. and Wabash Valley Power Associa-tion, Inc.
I Of Counsel:
KEITH R. ANDERSON JON D. NOLAND JAMES R. POPE LANA M. KRUSE Public Service Company of Indiana, Inc.
1000 East Main Street Plainfield, Indiana 46168 August 8, 1983 i
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY ) Docket Nos. STN 50-546 OF INDIANA, INC. ) STN 50-547
)
WABASH VALLEY POWER )
ASSOCIATION, INC. )
)
(Marble Hill Nuclear )
Generating Station, )
Units 1 & 2) )
)
CERTIFICATE OF SERVICE I hereby certify that I have this 8th day of August 1983, served copies of the foregoing document, entitled
" Applicants' Answer to Amendment to Petition for Leave to Intevene Filed by the Indiana Sassafras Audubon Society,"
by hand delivering and by mailing first class, postage prepaid and properly addressed, copies thereof to the following:
1 Ivan W. Smith, Chairman Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 (Hand Delivery) (Hand Delivery)
Dr. Oscar H. Paris Elaine I. Chan, Esq.
Atomic Safety and Licensing Office of Executive Legal l
l Board Panel Director l U.S. Nuclear Regulatory U.S. Nuclear Regulatory l Commission Commission l Washington, D.C. 20555 Washington, D.C. 20555 (Hand Delivery) (Hand Delivery) l I
Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (By Mail)
The Indiana Sassafras Audubon Tom Zeller Society Vice President c/o Mary Kay Moody Valley Watch, Inc.
6620 E. State Road 45 P. O. Box 2262 Bloomington, Indiana 47401 Evansville, Indiana 47714 (By Mail) (By Mail)
Dr. Harold G. Cassidy Fred Hauck Save the Valley Save the Valley 605 West Second Street R.R. 83, Tower Heights Madison, Indiana 47250 Shelbyville, Kentucky 40065 (By Mail) (By Mail)
Keith R. Anderson LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, D.C. 20036 (202) 457-7500 Attorneys for Public Service Company of Indiana, Inc.