ML19220C150
| ML19220C150 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/05/1973 |
| From: | Silberg J SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Haskins C Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7904280296 | |
| Download: ML19220C150 (3) | |
Text
I ew
-i 4Jb s
e.
)
~-
SHAW. PITTM AN, POTTS & TROWBRIDGE
', " ^ * ". ' * ' '. " > ', ",
e,
^a a avc'~a ersuaar6.pitewa
- O I Ftr $ 7 R [ f f, N. w.
aconor a vnoweniocc WO2129e*3ese atta=cm o.=ctes WAS HING To N. o. C. 2 c o o O castt; swawtaw-ornato c=aamorr e.eetu p o. so s r = >c =
Trtta 440 43
- m. fleeOYM F M a h L O pe ococo e =. noo c a s. sa.
A. J. oo N nC u, J n.
eauct w c=unc=itt LESta t a heCwCLSON. J R.
M ARTtN o amaLL micmanoJ.c=oast a-r. se 6e c ao sanoa ~ ~ nosso+vi atomot v at.*N.se sammy ne smoott%
- ", "." U.'c."c ", " *a'.T c
srtowcm o ram.ca
".'s"o"OUNY'"
December 5, 1973
- "" ' 'l. c c'c'.'" * '"
CamLCTOM s. SONES TwC** a s a. sa n T E R jam E S Twomeas LCNMaef*
(
Charles A. Haskins, Ecq.
Chairman Atomic Safety and Licensing Board Windy '. fill Farn Blucrant, Virginia 22012 Re:
Three Mile Island Nuclear Station, Unit 2 (Juniata Transmission Line),
Docket No. 50-320.
Dear Mr. Haskins:
On November 7, 1973, immediately following adjournment of the hearing on Three Mile Island Nuclear Station, Unit 1, an informal conference was held with the Board and counsel for all parties.
At that time, you asked about the construction schedule for the Juniata transmission line associated with Three Mile Island Nuclear Station, Unit 2.
Today I received the following information from Metropolitan Edison Company.
The Juniata transmission line is required to be in operation by June 1975 in order to meet the overall reliability criteria for the transmission system of the Pennsylvania-New Jersey-Maryland interconnection.
This need is independent of the line's function with respect to Unit 2.
In order to meet the June 1975 date, construction must begin by February 1974.
Notwithstanding this schedule, Met Ed will incur cdditional costs of approximately $250,000 unless construction of the Juniata line begins within threg g __,
h 'b
%N ~)
8e. 0gg3 p
g ygousoz w 88 053
f,v__2 u
.e
'.)
x _,)
s Charles A. Haskins, Esq.
December 5, 1973 Page Two weeks.
This additional cost ;ould result from the necessity of disbanding the work crew now under contract and the need to renegotiate a new contract at a substantially higher cost.
Thus, further delay in resolving the suspension of the Janiata line involves a substantial financial penalty to Met Ed.
As the Board is well aware, the Juniata proceeding has been pending for a considerable time.
Met Ed first requested that the suspension of construction of the Juniata trans-mission line be lif ted on. November 13, 1972.
The S taf f's Amanded Discussion and Findings on the suspension was dated December 9, 1972.
A notice of opportunity for hearing, along with a determination to rescind suspension, was published in the Federal Register on April 10, 1973.
The Notica of Hearing was issued on August 31, 1973.
On October 11, 1973, Applicants served interrogatories and a request for production of documents on Intervenors.
Intervenors have never made any response to this discovery request.
On November 9,
- 1973, Applicants filed a motion to compel discovery.
No response to this motion has been received.
On November 29, 1973, the Board informed the parties that Intervenors' counsel would no
~
longer be representing them in this proceeding and that Intervenors wculd seek other counsel.
We sincerely hope that this proceeding can be expeditiously concluded.
In order to achieve this aim, Applicants submit the enclosed Motion for Determinaticn of Default and Termination of Prcceeding.
In view
. the already extended length of this proceeding, the absence of any response by Intervenors to recent filings in this proceeding, and the significant financial cost to Applicants of further delay, we respectfully request that the Board take nrompt action to terminate this proceeding as requested by the enclosed motion.
Very truly yours, b
E Silberg C
ns 1 for Applicants JEs/dag Enclosure Copies as per attachment.
.W,
~.
s
'v Copies Dr. M. Stanley Livingston Dr. John R.
Lyman Douglas Olson, Esq.
Frank R.
Clokey, Esq.
Mr. Frank W. Karas Atomic Safety and Licensing Appeal Board At" mic Safety and Licensing Board Panel Miss M. V. Southard Mr.
D. Baker 88 055