ML19199A600
| ML19199A600 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/28/1975 |
| From: | Sager S SAGER & SAGER ASSOCIATES |
| To: | |
| References | |
| NUDOCS 7905040315 | |
| Download: ML19199A600 (1) | |
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UNITED STATES OF AMERICA k
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NUCLEAR REGULATORY COMMISSION q
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In the Matter of
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METROPOLITAN EDISON COMPANY.
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(Three Mile Island Unit No. 2))
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INTERROCATORIES AND REOUEST FM PRODUCTION OF DOCUMENTS Rules of Practice, please Pursuant to the Commission's,
file Answers to the enclosed Int rogatories and produce copies of all documents pursuant to the request for production of documents.
t 1.
State whether the Bechtelsville-Hosensak (hereinafter "Bechtelsville line") is the subject of any agreements.
If so, j
identify said agreements and produce copies of same.
2.
Was the Bechtelsville line originally planned to be initially constructed as a 230 kv line?
If so, state and explain fully the reasons for changing the same to a 500 kv line.
3.
Who shall own the Bechtelsv111e line?
State fully the method of ownership and what ownership agreements there are concerning the same.
Identify such agreements and produce copics of same.
4.
Prior to the final design of the Bechtelsville line, what alternatives were cons ide re d?
Identify all alternative routes analyzed or investigated.
Set forth the reasons, fully explaining
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the same in a detailed answer, why the final design route for the Bechtelsville line was eventually acec7ted as the final design by the applicants.
5.
State the name of the person or persons and by whom that parson or persons are employed who were in charge of the supervision of the final design of the Bechtelsville line.
6.
Set forth the names and addresses of all witnesses you propose to call at the time of hearing of this matter concerning the issues in controversy.
7.
Produce copies of all alternative design plans to the final design.
If there were no alternative design plans but the route of the final design was in some way changed or i
modified (with reference to the Bechtelsville line), produce copies of said plans and designs.
8.
Detail in full and explain fully with reference to i
the final design plans and any modification of preliminary plans, what considerations of aesthetics were incorporated in the final design with reference to the placement of towers and avoiding the view of the transmission lines and towers in the vicinity of the area in which said transmission line would be placed.
9.
Detail and idencify what studies were made in order to interconnect Unit 2 with the PJM system by alternative transmission line routes that would not cause the erection and creation of the Bechtelsville line.
Produce copies of all such studies.
10.
What studies were mad (
and/or design considerations j ')
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made in the Bechtelsville line with reference to the placement t
l of the line and towers in order to avoid encroachment on agricultural land and to minimize the impact of the line across any and all agricultural land that said line would transve rse.
Produce copies of same.
Set forth revision dates of the intial plan concerning the Bechtelsv111e line.
For each revision date, set forth and detail in full any modification concerning the initial plan and the final engineer design plan.
By initial plan, intervenors do not necessarily mean a fully engineered plan, I
but the initial "inhouse" plan for the Bechtelsville line.
11.
Set forth whether applicants assert that the proposed Bechtelsville line is necessary for the direct service of customers in the Metropolitan Edison service area.
2 Explain fully your answer.
By direct service, intervenors mean that the line is necessary to bring energy directly to customers in the service area rather than assuring service by i
" reliability" and interconnection agreenents.
12.
Prior to the design of the Bechtelsville line or p'rior to the final design of the Bechtelsville line, was a I
cos t /b e.te fit made of the Bechtelsville line or the whole transmission line from Unit 2 to Hosensak?
Was a cost / benefit made to compare the cost / benefits of the proposed line with any alternative route lines?
If your answer is affirmative to either port of this question, please set produce copies of said studies and detail fully the results of said studies.
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13.
Set forth in detail and with particularity any and i
all engineering reasons and considerations for establishing the transmission line that gave rise to the Bechtelsville sector.
With respect to each reason and consideration, detail fully what alternative considerations were reviewed.
As to all such reviews, set forth copies of any and all documents, studies and reports concerning thc'same and produce copies of same.
14.
Is it not so that the applicant (meaning one or more of the utilities who are parties to this action) owns or controls and did own or control prior to the design of the Bechtelsville line, high-tension transmission lines that transversed the same properties over which the Bechtelsville line vould so transverse?
If so, set forth fully and in detail why the 1
500 kv line from Unit 2 could nc have been integrated into the lines on the properties so involved as to avoid the impacts, i
of transversing said properties with additional transmission lines and right-of-ways.
Identify any and all studies concerding the same, if any.
Produce copies of any studies, reports and documents that support yaur answer.
15.
Produce copies of any and all statements presented by J.
E.
Burkert, the Superintendent of Trancportation for Metropolitan Edison Company, before the Pennsylvania Public Utility Commission concerning the Bechtelsville line.
16.
Produce copies of all testimony and statements of Edmund Newton, Jr.,
the Cencral Public Utilities Corporation's Vice President of Planning and Economics, concerning testimony qG-
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and statements he made before the Pennsylvania Public Utility I
Commission concerning the said line.
i 17.
Produce copies of all testimony and statements of Paul Uinter, Metropoliran Edison's Systems Planning Engineer, concerning testimony and state =ents he made before the Pennsylvania Public Utility Commission concerning the said line.
18.
Detail fully how the proposed line would increasc the reliability of the Metropolitan Edison system.
19.
With reference to your answer to the last question, set forth fully what alternatives were considered to assure the same objectives.
Produce copics of any and all reports, I
documents, and memoranda concerning said considerations, objectives, and evaluations.
20.
If the applicant's position is that the transmission s
lines were necessary to assure system reliability, set forth any and all evidence with reference to the fact that the system would not be reliable without the proposed Bechtelsv111e line.
21.
With reference to the Bechtelsville line, was any consideration given to the design of said line that Metropolitan Edison's customers would consume more electricity in the future in the area in which the line transverses, making the line necessary?
If so, produce copies of any memoranda, studies and/or reports concerning said considerations.
Detail in full precisely what the objectives and concerns of the applicant *1 q.
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were in that regard.
Set forth any and all estimates and l
opinions that gave rise to these concerns and objectives.
22.
Produce copies of any and all exhibits presented by the applicant before the Pennsylvania Public Utility Commission
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with reference to its application for certification of public convenience and necessity of and concerning said line.
23.
With reference to each and every exhibit proferred before the Pennsylvania Public Utility Commission of and concerning said line, identify the person, his or her address, and the company by whom said person is employed that made such exhibits.
24.
What considerations of load forecasting, if any, gave rise to the Bechtelsville line?
Detail and explain fully your answer.
Identify and produce copies of any and all memoranda, 8
reports, and/or documents concerning the same.
25.
Set forth the factual foundation and basis for any load forecasts that were considered and used in justifying the necessity and/or the design of the Bechtelsville line.
With reference to any load forecasts that were so considered, were any revised?
If so, detail the revisions thereto.
26.
What considerations with regard to the shape of the overall load, installation costs, transmission costs and operating costs over the transmission lines were made and 4
considered in establishing the Bechtclsville line?
Detail fully your answer and produce copies of any memoranda, reports and/or documents concerning the same.
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27.
Was the design of the Bechtelsville line influenced in any regard, whatsoever, by agreements between Metropolitan Edison Company and any other utilities?
If so, identify said agreement and produce copies of same.
28.
Is it not so that the design of the proposed Bechtelsv111e line as a portion of the line coming from Unit 2 was primarily established so that power and transmission could be supplied through the Metropolitan Edison's service territory to other electric companies in the power pool, including the other utility applicants herein?
If you disagree with said statement, fully set forth the basis for said disagreement and explain fully vour answer.
29.
Produce a copy of the GPU Power Pool agreement of July 21, 1969.
30.
Produce a copy of the rJM agreement of September 26, 1956 together with all revisions thereto.
31.
Produce a copy of the ERV agreement of April 27, 1967 together with all visions thereto.
32.
Do the applicants justify the design and location of the Bechtelsville line on the basis of any of the aforesaid agreements?
If so, identify the section of said agreements that the applicants relied upon.
33.
Set forth any and all studies, docunents and/or reports concerning the environmental impacts of the proposed Bechtelsville line.
Produce copies of same. n ?s l3
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l 34.
Was any consideration given to an alternative route to avoid the environmental impacts of the Bechtelsville line?
If so, set forth with particularity what cor 91derations were made and what alternr ive routes were considered.
Produce copies of any and all reports, documents and/or memoranda concerning said analysis.
35.
Identify all purposes and justifications for the design of the Bechtelsville line.
36.
Justify fully why the shortest way to interconnect i
Unit 2 with the PJM systen is through the design line as proposed, including the Bechtelsville line.
Detail your answer fully and explain fully why the reliability of the interconnection system necessarily caused a design as proposed and why other alternative cptions were foreclosed or not considered.
37.
What design criteria and standards were used by the applicant to minimize the environmental impact of the proposed line?
Detail fully your answer.
Produce any documents, reports and/or memoranda concerning said standardc or considerations.
38.
With reference to the Bechtelsville line, what analysia, if any, was made in order to ende avor to design the line over existing transmission rights-of-way?
Explain fully and detail your answer, identifying any reports, studies and/or memoranda, as well as design plans.
Produce copies of same.
39.
Did any revfsions in your initial plan with reference j1 9;f
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,s to the transmission of electricity from Unit 2 beyond Bechtelsville I
change the number of streams, roads, highways or other pathways as opposed to the final design from Bechtclsville to Hosensak?
Detail your answer and provide documentation for same.
40.
With reference to the original proposal by the applicants, particularly Metropolitan Edison, to construct a line from Bechtelsville to Souderton, please set forth the justification for same with reference to load forecasts, the necessity for said line, and any other analysis concerning the appropriateness and necessity of said line for reliability t
purposes.
41.
With reference to the Bechtelsville-Souderton proposal, how, if in any way, did the original analysis of the applicant change with reference to the need of said line s
concerning reliability aspects, load forecasting, and the other considerations set forth in the previous question and answer thereto, with the exception of environmental factors?
Set forth your answer in detail and document the foundation for same.
42.
Produce copies of any and all communications with the Montgomery County Planning Commission concerning the proposed Bechtelsville to Souderton line.
Document and set forth the substinance of any law communication between representatives of the applicant and the Montgome ry Coun ty Planning Commission, noting the date thereof, and the parties thereto.,9 a :,
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43.
Produce copies of any and all analyscs, documents, studies and memoranda of the applicants concerning the aged and propriety for the proposed Bechtelsville to Souderton line.
44.
Present and produce copies of any documents, studies, memoranda and/or reports of the applicant concerning the reasons why the applicant redesigned their route and eliminated the Bechtelsville to Souderton line.
45.
Set forth cl1 analyses and considerations, identifying any studies, reporta, documents and memoranda producing copies of the same, conce rning the design of the Bechtelsville line so as to avoid accident conditions.
46.
Detail fully any and all environmental impact considerations that gave rise to change in judgment, if any, by the applicant in designing the proposed Bechtelsville to Hosensak line rather than Bechtelsville to Souderton.
47.
Document any and all contacts with Berks County Planning Commission with respect to the initial plans for the design of the Bechtelsville to Hosensak line.
Produce copies of any and all reports, documents, and memoranda between the representatives of the applicant and representatives of the Berks County Planning Commission.
43.
Detail and set forth specifically what analyses and what considerations were s1ven in the design of the line so as to mini =ize scenic impair =ent.
Were the transmission lines and towers run along the bases of hills so as to minimize scenic i=pairment?
Document your answer fully.
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What was done in order to assure that the towers and lines would blend, in so far as practical, with the surrounding scenery, topography, and landscape with reference to the portion of~the line from Bechtelsville to Hosensak?
Explain in detail your answer fully.
50.
What was done in order to avoid and minimize environ = ectal impacts with reference to the construction of the line and towers on the right-of-way by replanning, restoring, and revitalizing the disturbed rights-of-way for the construction of the Bechtelsville to Hosensak line?
Detail your answer in full.
51.
With reference to the collection of the Bechtelsville t
to Hosensak line, detail fully what analyses and what studies were made concerning the impact of the proposed lines and towers on property values and property rights.
Produce copies of any reports, memoranda, and/or documents concerning the same.
i 52.
Detail and set forth the environmental impacts that are occasioned by the construction of the Bechtelsville line.
With reference to each environmental impact, set forth the costs for avoiding or minimizing the impact of same.
53.
Set forth the effective life period for the towers and the lines.
Document the foundation of your answer.
54.
Set forth the operating and maintenance costs for the propsed line.
Present the foundation and basis for your answer.
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l 55.
Compare the amount of land that would have beet
.ecessary to clear in order to establish the Bechtelsville to Souderton route as opposed to the amount of land that would have to be cleared in order to establish the Bechtelsville line.
Set forth
,your answer with reference to woodland, agricultural land, and so forth.
56.
Is it not so that the Bechtelsville to Souderton line would have been closer to your load and would have resulted in less of a loss of electricity than as compared to the Bechtelsville line?
Explain fully your answer.
57.
Is it not so that the MAAC System Liability Review of the fall of 1971 indicated that the Bechtelsv111e to So'iderton 8
line was necessary in order to establish system reliability and should not be delayed beyond June, 1974?
If you disagree, please explain fully your answer.
If you agree, please explain any changes in judgment and the basis therefore.
58.
What roadways, if any, were necessary to be constructed or were constructed for the Bechtelsv111e line?
Compare the number of roadways for the construction of the Bechtelsville line with an al te rna t ive route, particularly the Bechtelsville to Souderton route.
Set forth the costs of construction cf said roadways.
59.
Will there be any tap-ins to the Bechtelsville line between Bechtelsville and Hosensak?
Would there have been any tap-ins for the line between Bechtelsv111e and ))
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Souderton?
Is it not so that the benefits to be derived from a tap-in were more probable for a Bechtelsville to to Souderton line than for a Bechtelsville to Hosensak line?
Please explain in detail your answers fully.
60.
Is it not so that the transmission line path was recommended and decided as a result of coordinated efforts between Metropolitan Edison, GPU, PJM interconnection, and MAAC?
If you disagree, explain fully why you disagree.
If you agree, set forth and produce any communication, memoranda, reports, and/or documents con ce rning the said coordination effort.
61.
Produce a copy of Plan No. B-2949-R and any revision thereto concerning the Metropolitan Edison principal transmission
- line, s
62.
Is it not so that the applicant controls a substation on the east side of the Susquehanna through which current generated at Unit 2 will pass?
63.
With reference to the answer to the previous question, is it not further so that the current passing through said substation for Unit 2 would go in two directions:
one into an existing 500 kv line that would take the electric flow through ot towards the Juniata line and the other direction would be for the proposed line eventually coming into the Bechtelsville line?
If you disagree, set forth the facts and basis for your disagreeing with the previous statemeat and question. 1
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_I 64.
Set forth the reasons why all the electricity fron Unit 2 could not be transmitted in the direction or through the Juniata line, giving particular reference to the c=nstruction of additional transmission facilities along the right-of-way of the Juniata line.
SAGER & S I ASSOCIATES 4.%<<sc-(, s4 M'a'v r e e Sager, Attorney f
Intervenors 1
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EbLATL'.D CORRESPONDENCE t
i UNITED STATES OF AMERICA i
NUCLEAR RECULATORY COMMISSION In the Matter of
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METg0POLITAN EDISON COMPANY,
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(Three Mile Island Unit No. 2))
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CERTIFICATE OF SERVICE o
I.hereby certify that I have this day served the foregoing document upon each person designated below by pl4cing the same in the United States mail.
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N DATED:
May 28, 1975 m
w ence Sager, Esquire V Edward Luton, Esq. Chairman Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Ccomission Washington, DC 20555 Mr. Gustave A. Linenberger
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N Atomic Safety and Licensing Board kg',7 U.S. Nuclear Regulatory Commission Washington, DC 20555
'6I Jgg ii 1975 > T_3, Dr. Ernest O.
Salo
.,7 o g* fr,% U Z I Professor, Fisheries Research
- d" Institute, WH-10 41 bbN College of Fisheries D
- s University of Washington te\\
n Seattle, Washington 98195 George F.
Trowbridge, Esq.
Shaw, Pittman, Potts & Irowbridge 910 17th Street, N.W.
Washington, DC 20006 Henry J. McGurren, Counsel for NRC Staff Office of the Executive Legal Director Nuclear Regulatory Commission Washington, DC 20555
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