ML19209B147

Motion to Reopen Discovery for Contention 13 Dealing W/ Applicants Financial Abilities to Build & Operate Facility. Costs of Facility Have Recently Increased by $186 Million. Nature & Effects of Addl Costs Should Be Investigated

ML19209B147
Person / Time
Site:	Zimmer
Issue date:	08/24/1979
From:	Kosik L KOSIK, L. S., MIAMI VALLEY POWER PROJECT
To:
Shared Package
ML19209B128	List: ML19209B127 ML19209B134 ML19209B139 ML19209B145 ML19209B147 ML19209B150 ML19209B153 ML19209B158
References
NUDOCS 7910090233
Download: ML19209B147 (2)

Text

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MIA11I VAUEi PCVER PPNECr*S hK7FICN M EECPl'.N DISCLTERY ICR CChTr.'YIICN 13 137P moves the Atanic Safety and Licensing Scard tc recpen discovery fcr Contention 13.

In a letter dated July 30, 1979, counsel fcr Applidts revealed that a review of the project schedule and costs resulted in a ne"x esti :ated ecs: for the Zirr.ar Pcuer Statica of $850 million.

1:'.7P's Cententien 13 deals with tha financial abilit:7 of Applicants to build, cperate and prcperly maintain the Zirmer Station.

It has recently cc.e to ISTP's attention that the costs of the Zirmer Staticn ihave increased by S186 millien.

It is ir: perative that sn7p be able to dis =crer the nature of these r 2itional costs and how they will affect the fina:.cial ability of the Applicants to cperate and maintain the plant.

It should be known that tw of the applicant ce' ' es are presently seeking large rate increases, substantialpcrtiens of which are based en adding the Zirrner Staticn to the rate base en a Ccnstruction Tc-k in Progress basis.

The require ent that 75~e of anticipated costs of the ccnsc:acticn pre;ect have already accrued in crder to add CTIP to the rate base is no lenger met Aten the increased ccsts are considered. Thus it is necessa.t that 3nTP disecver hcw Anplicants will raise revenues to finance the Zister project.

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. In order that ANPP prepare its case en Centantior 13 in light of the recent additional cost disclosure, it is necessary that discove7* be reopened.

For the above reasons, the Board should grant E PP's motien to recpen discovery.

Respectfully sutr.itted, August 24, 1979

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