ML18023B153

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Applicants' Answer to Petition for Leave to Intervene Submitted by Citizens Against Nuclear Dangers.
ML18023B153
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 09/21/1978
From: Silberg J
Allegheny Electric Cooperative, Pennsylvania Power & Light Co, Shaw, Pittman, Potts & Trowbridge
To:
Office of Nuclear Reactor Regulation
References
Download: ML18023B153 (3)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI N In the Matter of g/u m

)

PENNSYLVANIA POWER 6 LIGHT COMPANY )

and ) Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) 50-3 (Susquehanna Steam Electric Station, ).

Units l. and 2) )

E APPLICANTS'NSWER TO PETITION FOR LEAVE TO INTERVENE SUBMITTED BY "CITIZENS AGAINST NUCLEAR DANGERS" On August 9, 1978, the Nuclear Regulatory Commission ("NRC")

published in the Federal Register a "Notice of Receipt of Appli-cation for Facility Operating Licenses; Availability of Appli-cant's Environmental Report; and Consideration of Issuance of Facility Operating Licenses Opportunity for Hearing". 43 Fed. Reg. 35406. This Notice stated that the NRC, following completion of specified actions, will consider the issuance of operating licenses to Pennsylvania Power & Light Company and Allegheny Electric Coop-erative, Inc. (collectively "Applicants" ) for the Susquehanna Steam Electric Station, Units 1 and 2 ("SSES"). The Notice pro-vided that any person whose interest may be affected by. Khe pro-ceeding may file, by September 8, 1978, a petition to intervene.

In a mailgram dated September 7, 1978, Citizens Against Nuclear Dangers ("CAND") requested a hearing and petitioned for leave to intervene.

The tests for petitions for leave to intervene are set forth in 10 CFR 52.714 and were described in the NRC's August 9, 1978

Federal Register notice. The petition must set forth with par-ticularity the petitioner's interest in the proceeding, how that interest may be affected by the results of the proceeding, and the specific aspect, or aspects of the subject matter of the pro-ceeding as to which the petitioner wishes to intervene. The petition should also address the nature of the petitioner's right under the Atomic Energy Act to be made a party, the nature and extent of the petitioner's interest in the proceeding, and the possible effect of any order which may be entered in the pro-ceeding on petitioner's interest. Under the recent, revisions to 10 CFR 52.714, 43 Fed. Reg. 17801 '(April 26, 1978), a petitioner has until 15 days prior to the first prehearing conference to sub-mit the contentions which he seeks to litigate.

CAND's petition would appear to satisfy these requirements at least marginally. Applicant thus would agree that CAND has adequately demonstrated its interest in this proceeding.

Respectfully submitted, SHAW, PITTMAN, POTTS 6 TROWBRIDGE

'I BY 4 i \ 5 9L Silberg Jayj E)

Counsel for Applicants 1800 M Street, N. W.

Washi'ngton, D. C. 20036 (202) 331-4100 Dated: September 21, 1978

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of PENNSYLVANIA POWER 6 LIGHT COMPANY and Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE~ INC 50-388 (Susquehanna Steam Electric Station, Units 1 and 2)

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Applicants'nswer to Petition for Leave to Intervene Submitted by 'Citizens Against Nuclear Dangers'" were served by deposit in the U. S.

mail, first class, postage prepaid, this 21st day of September, 1978, to:

Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 James M. Cutchin, IV, Esquire Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mrs. Irene Lemanowicz, Chairman The Citizens Against Nuclear Dangers Post Office Box 377 R- D. 1 Berwick, Pennsylvania 18603

/ / J Jay E Silberg I

Dated: September 21, 1978