ML20074A481

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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
ML20074A481
Person / Time
Site: Marble Hill
Issue date: 05/12/1983
From: Voigt H
LEBOEUF, LAMB, LEIBY & MACRAE, PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA, WABASH VALLEY POWER ASSOCIATION, INC.
To:
NRC COMMISSION (OCM)
References
NUDOCS 8305130098
Download: ML20074A481 (4)


Text

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

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PUBLIC SERVICE COMPANY ) Docket Nos. STN 50-546 OF INDIANA, INC. ) STN 50-547 WABASH VALLEY POWER ) c '%

ASSOCIATION, INC. )

(Marble Hill Nuclear ) \

Generating Station, ) xf e', 4 \

Units 1 & 2) ) g "@- %j?g

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APPLICANT'S ANSWER TO PETITIO

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FOR LEAVE TO INTERVENE FILED'BK, 7 SAVE THE VALLEY g, y

1. Public Service Company of Indiana, Inc. and Wabash Valley Power Association, Inc. (" Applicants") were served on April 27, 1982, with the petition for leave to intervene of Save The Valley (" Petitioner"). -
2. Applicants recognize that Petitioner has an interest that may be affected by these proceedings and thus meets the standing requirements contained in section 189 of the Atomic Energy Act of 1954. 42 U.S.C. S 2239 (1976).
3. Applicants, however, reserve their right to object to the contentions that Petitioner seeks to have litigated in this proceeding and to Petitioner's right to a hearing until after Petitioner files t.5e supplement to its petition, which must contain such contentions. See 10 C.F.R. S'
2. 714 (b) (1982).

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4. For the foregoing reasons, Applicants do not oppose the petition for leave to intervene filed by Save The Valley, so long as Applicants may object to Petitioner's contentions and to Petitioner's right to a hearing after Petitioner files the supplement to its petition.

Respectfully submitted,

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LeBOEUF, LAMB, LEIBY & MacRAE By hr Rh 1333 Ne Hampshire Ave., NW Suite 1100 Washington, D.C. 20036 (202) 457-7500 Attorneys for Public Service Company of Indiana, Inc. and Wabash Valley Power Associa-tion, Inc.

Of Counsel:

KEITH R. ANDERSON JON D. NOLAND JAMES R. POPE j Public Service Company of Indiana, Inc.

I 1000 East Main Street Plainfield, Indiana 46168 l

l May 12, 1983 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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 12th day of May, 1983, served copies of the foregoing document, entitled

" Applicant's Answer to Petition for Leave to Intervene Filed by Save the Valley," by hand delivering and by mailing first class, postage prepaid and properly addressed, copies there-of to the following:

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 Board Panel Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20553 (Hand Delivery) (Hand Delivery)

I

Mary Pat Lynch, President Tom Zeller The Indiana Sassafras Audubon Vice President Society Valley Watch, Inc.

605 South Fess Avenue, Apt. 6 P. O. Box 2262 Bloomington, Indiana 47401 Evansville, Indiana 47714 (By Mail) (.y B Mail)

Dr. Harold G. Cassidy Fred Hauck Save the Valley Save the Valley 605 West Second Street R.R. #3, Tower Heights Madison, Indiana 47250 Shelbyville, Kentucky 40065 (By Mail) (By Mail)

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Keith' R. Anderson LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, DC 20036 (202) 457-7500 Attorneys for Public Service Company of Indiana, Inc.

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