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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20148P2031988-04-0404 April 1988 NRC Staff Response to Supplemental Interrogatories from TMI Alert/Susquehanna Valley Alliance.* Related Correspondence ML20150F8851988-03-30030 March 1988 Answers to Sva/Tmi Alert Second Set of Interrogatories to Util.* Submits Responses to Sva/Tmi Alert 880315 Interrogatories.W/Certificate of Svc.Related Correspondence ML20150D0561988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to NRC Staff.* Certificate of Svc Encl.Related Correspondence ML20150D0441988-03-21021 March 1988 Valley Alliance/Tmi Alert Second Set of Interrogatories & Request for Production of Documents to Gpu Nuclear.* Related Correspondence ML20149N0461988-02-22022 February 1988 NRC Staff Response to Interrogatories from TMI Alert/Sva.* Responds to Interrogatories Filed by TMI Alert/Sva on 880207.NRC Waived Requirement for Order from Presiding Officer Directing Discovery.Related Correspondence ML20196F1181988-02-22022 February 1988 Responses to NRC Interrogatories.* All Responses Re Disposal of Accident Generated Water by Intervenor F Skolnick. Certificate of Svc Encl.Related Correspondence ML20149M8671988-02-22022 February 1988 Licensee Response to Sva/Tmi Alert Request for Production of Documents.* Documents Re Disposal of accident-generated Water Will Be Made Available for Insp & Copying as Listed. Certificate of Svc Encl.Related Correspondence ML20149M8621988-02-19019 February 1988 Licensee Answers to Sva/Tmi Alert Interrogatories to Gpu Nuclear Corp.* Responds to Sva/Tmi Alert Interrogatories Re Disposal of accident-generated Water.Related Correspondence ML20149K8801988-02-15015 February 1988 Valley Alliance/Tmi Alert Responses to Licensee Interrogatories & Request for Documents.* Info Will Be Provided Upon Availability & Listed Documents Being Sent to Licensee.W/Certificate of Svc ML20196D3731988-02-0303 February 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Util.* Original Documents Identified in Answers to Listed Interrogatories Requested.W/Certificate of Svc.Related Correspondence ML20196D3921988-01-31031 January 1988 Valley Alliance/Tmi Alert Interrogatories & Request for Production of Documents to Nrc.* NRC Must Produce Any Addl Documents Responsive to Request.Certificate of Svc Encl.Related Correspondence ML20148U5331988-01-29029 January 1988 Licensee Interrogatories & Request for Production of Documents to TMI Alert & Susquehanna Valley Alliance.* Joint Intervenors Should Produce Original Documents Noted in Interrogatories.W/Certificate of Svc.Related Correspondence ML20235B6151987-09-18018 September 1987 NRC Staff Sixth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories.* Staff Intends to Call C Barus as Rebuttal Witness.W/Certificate of Svc.Related Correspondence ML20214S0551987-06-0202 June 1987 Gpu Nuclear Response to NRC Staff Request for Production of Documents.* Request 1 Overly Broad,Burdensome & of Limited Relevance.Request 2 Vague.Related Correspondence ML20207S5861987-03-18018 March 1987 NRC Staff Response to Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20212N4831987-03-0505 March 1987 Gpu Nuclear Corp Response to NRC Staff Second Request for Documents.* Notes of Interviews Conducted by Stier or Associates & Certificate of Svc Encl.Related Correspondence ML20212K3891987-03-0303 March 1987 NRC Response to Gpu Nuclear Corp Third Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20212F9481987-03-0202 March 1987 Gpu Nuclear Corp Second Set of Interrogatories to NRC Staff & Fourth Request for Production of Documents.* NRC Should Produce All Documents Required to Be Identified by Listed Interrogatories.W/Certificate of Svc.Related Correspondence ML20211F5331987-02-19019 February 1987 Gpu Nuclear Corp Response to NRC Second Set of Interrogatories.* Persons Attending 830323 Meeting Re R Parks Public Statement Listed.Certificate of Svc Encl. Related Correspondence ML20211D6811987-02-19019 February 1987 NRC Fifth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Affidavit of MT Masnik Encl.Related Correspondence ML20212R6771987-01-29029 January 1987 NRC Staff Second Set of Interrogatories & Request for Documents to Gpu Nuclear Corporation.* Requests Info on 830323 Meeting W/Bechtel & Transfer or Removal of R Parks. W/Certificate of Svc.Related Correspondence ML20212R6501987-01-27027 January 1987 Gpu Nuclear Corp Third Request for Production of Documents.* W/Certificate of Svc.Related Correspondence ML20207P7141987-01-13013 January 1987 Gpu Second Request for Production of Documents.* Gpu Requests That NRC Identify Title,General Subj Matter,Date, Author & Reason Why Documents Requested Being Withheld. Related Correspondence ML20207N6721987-01-0909 January 1987 NRC Staff Fourth Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N7081987-01-0909 January 1987 Second Supplemental Response of Gpu Nuclear Corp to NRC Staff First Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20207N6911987-01-0909 January 1987 Third Supplemental Response of Gpu Nuclear Corp to NRC Staff First Set of Interrogatories.* Related Correspondence ML20207L9041987-01-0505 January 1987 NRC Staff Third Supplemental Response to Gpu First Set of Interrogatories & Request for Production of Documents.* MT Masnik & Me Resner 870105 Affidavits & Certificate of Svc Encl.Related Correspondence ML20207C4711986-12-22022 December 1986 Second Supplemental Response to NRC First Set of Interrogatories Re Util Organization & Witnesses.Certificate of Svc Encl.Related Correspondence ML20212D6651986-12-15015 December 1986 NRC Staff Second Supplemental Response to Gpu Nuclear Corp First Set of Interrogatories & Request for Production of Documents.* Unexecuted Affidavit of RA Meeks & Certificate of Svc Encl.Related Correspondence ML20211K2771986-11-13013 November 1986 Response to First Request for Production of Documents Re Basis for R Parks Removal from Test Working Group on 830223 & Parks Involvement W/Quiltech Co.Certificate of Svc Encl. Related Correspondence ML20215M9901986-10-29029 October 1986 First Supplemental Response to NRC First Set of Interrogatories Re Suspension of R Parks Employment at Facility Site.W/Certificate of Svc.Related Correspondence ML20211G5101986-10-28028 October 1986 Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence ML20215D8681986-10-0909 October 1986 First Request for Production of Seven Categories of Documents Re Basis for R Parks Removal from Testing Working Group on 830223 & Investigation of Parks Involvement W/ Quiltech Co.Related Correspondence ML20215D8781986-10-0909 October 1986 First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence ML20215D8821986-10-0909 October 1986 Supplemental Response to Gpu First Set of Interrogatories & First Request for Documents Re Enforcement Action EA-84-137. Supporting Documentation & Certificate of Svc Encl.Related Correspondence ML20214R6291986-09-23023 September 1986 Response to Util First Set of Interrogatories & Partial Response to First Request for Production of Documents. Affidavits Encl.Related Correspondence ML20209G1681986-09-0404 September 1986 First Request for Production of Documents Identified in NRC Responses to Listed Interrogatories,Including Interrogatory 1(e) Re Protected Activity Engaged in by Parks Resulting in Alleged Discrimination Against Parks.W/Certificate of Svc ML20209G3181986-09-0404 September 1986 First Set of Interrogatories Re Removal of Rd Parks from Employment.W/Certificate of Svc ML20211E6311986-06-11011 June 1986 First Supplemental Answer to NRC First Interrogatories & Request for Production of Documents to C Husted.Rl Long Notes Produced Indicating Husted Met W/J Herbein on 811005. Related Correspondence ML20211E6601986-06-11011 June 1986 First Supplemental Answers to TMI Alert First Request for Production of Documents & First Interrogatories to C Husted. Rl Long Notes of 820527 Conversation W/Newton Encl.W/ Certificate of Svc. Related Correspondence ML20197C1931986-05-0808 May 1986 Answers to TMI Alert,Inc 860501 Supplemental Interrogatories.Certificate of Svc Encl.Related Correspondence ML20203L6011986-04-28028 April 1986 Responses to TMI Alert First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20141J3171986-04-23023 April 1986 Response to Util First Interrogatories & Request for Production of Documents Re Senior Reactor Operator Licensing Exams.Certificate of Svc Encl.Related Correspondence ML20141J4071986-04-23023 April 1986 Response to Husted First Interrogatories & Request for Production of Documents Re Alleged Cheating During Apr 1981 OL Exams.Certificate of Svc Encl.Related Correspondence ML20155F5471986-04-18018 April 1986 Supplemental Response to NRC Interrogatories 3 & 4 & Request for Production of Documents to Util.Certificate of Svc Encl. Related Correspondence ML20203B4121986-04-15015 April 1986 Response to First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence ML20203B6311986-04-14014 April 1986 Answers to Staff First Interrogatories & Request for Production of Documents.Related Correspondence ML20202G5381986-04-0909 April 1986 First Interrogatories & Request for Production of Documents to TMI Alert Re Apr 1981 Senior Reactor Operator Exam. Certificate of Svc Encl.Related Correspondence ML20202G7361986-04-0909 April 1986 Response to TMI Alert,Inc First Request for Production of Documents & First Interrogatories.Certificate of Svc Encl. Related Correspondence ML20202G6651986-04-0808 April 1986 C Husted Answers to NRC First Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence 1988-04-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] |
Text
o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFOR5 THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE 'S RESPONSE TO INTERROGATORIES 41-50 (FIRST SET) OF THREE MILE ISLAND ALERT, INC.
INTERROGATORY NO. 41 Has the Licensee prepared , or had prepared, any analysis of its financial position as a result of the March 28, 1979 accident?
INTERROGATORY NO. 42 If so, state:
(a) the name, address and telephone number of the person who prepared the analysis:
(b) the nature and topics of the analysis; (c) identify and provide copies of all such analyses.
RES PONS E The most recent forecast of the financial position of Metropolitan Edison is contained in the testimony of Mr. John G. Graham in the Pennsylvania Rate Proceeding Docket No.
I-79040308. This represents the 1980 Budget for GPU and sub-sidiaries together with a forecast, based upon explicitly stat-ed assumptions, of financial position beyond 1980.
(a) The current and forecasted financial position of Metropolitan Edison was prepared under the direction of:
1946 027 av)os110 afi:L
Mr. John G. Graham GPU Service Corporacion 100 Interpace Parkway Parsippany, N. J. 07054 (201) 263-6130 (b) The analysis, as reflected in Mr. Graham's testimony, details and discusses a four year projection of sources and application of funds together with an an-alysis of the results of operations.
(c) The analysis has been filed in Pennsylvania Docket No. I-79040308 and is identified as Met-Ed/Penelec Statement A-1, Supplement No. 1, Witness: John G.
Graham and Exhibits A-23 through 29 and 35 through 39.
Copies have been provided to Three Mile Island Alert, Inc. since they are a party to the referenced pro-ceeding. A copy of the testimony and exhibits will be placed in Licensee's Discovery Reading Room.
INTERROGATORY NO. 43 Has the Licensee had difficulties in obtaining short-term financing since :Drch 28, 1979?
INTERROGATORY NO. 44 If so, state:
(a) the nature of the difficulties; (b) the name, address and telephone number of each person who has been requested to provide shor t-term finan-cing to Licensee; (c) the results of each request; (d) the present status of any short-term financing plans presently available to Licensee; (e) identify and provide copies of all short-term finan-cing plans developed or implemented, inciuding those that sere unsuccessful.
RES PONSE (a-e) 1946 028
_r_
'mmediately following the March 28 accident, GPU and its three operating companies contacted their banks and requested increases in their existing lines of credit from a March 28 level of $225 million to a level of almost S500 million.
Because the existing lines were infcrmal unsecured lines of credit, the banks could decide to revoke their line of credit at any time. Because of the uncertainty surrounding the acci-dent, particularly with respect to regulatory response, it was soon apparent that the GPU System required a short-term credit arrangement that would provide a better assurance of availability for short-term borrowings. As a result and fol-lowing extensive discussions, the GPU System entered into a re-volving credit agreement. The credit under that agreement is now available according to its terms. The Revolving Credit Agreement limits the amount of short-term borrowings that can take place outside the credit agreement. As of December 31, 1979, there were no borrowings under the lines of credit avail-able outside of the Revolving Credit Agreement.
Copies of the following documents will be placed in Licensee 's Discovery Readir.g Room: (1) the Revolving Credit Agreement, together with subsequent amendnents; (i) a summary of the major terms of the Agreement, (3) a list of names and addresses of the banks participating in the Revolving Credit Agreement; (4) a summary, as of December 31, 1979, of the bor-rowings under the Revolving Credit Agreement; and (5) a list of the names and addresses of the banks providing credit outside the Revolving Credit Agreeuent and a list of each bank's credit line.
INTERROGATORY NO. 45 What are the present plans of Licensee or its parent, GPU, with respect to long-term financing?
RES PONSE The present plans for the GPU System 1980 long-term finan-cings are as follows:
Metropolitan Edison Met-Ed will have coverage through January 1980 to irisue approximately S6 million of mortgage bonds. We have not an-ticipated the sale of these bonds because we have been unable to find a market for these securities.
To preserve a capacity to market these securid es in the future , however, we have had discussions with the Revciving
Credit agent banks of having the banks in the Revolving Credit Agreement purchase $6 million of bonds. The price would be the same as under the credit agreement and these bonds would offset some of the $125 million now available. In other words, the total available from the banks would still be S125 million.
The advantage to the banks would be additional security during this difficult time. The advantage to Met-Ed would be (1) an ability to fund out these bonds to another purchaser at a future time and (2) a greater likelihood of continued bank sup-port.
Another area of possible additional financing is by refunding maturing Met-Ed bonds. In 1980, $12 million of Met-Ed bonds will come due with S7 million on February 1st and
$5 million on December 1st. With respect to the $7 nillion, we engaged our investment banking firm to attempt to place a new issue of bonds to refinance the maturing bonds but they were unable to do so pending completion of the proceedings ongoing now in Penasylvania. We have held discussions with our agent banks about an arrangement similar to that for the proposed issue of $6 million of bonds, i.e., for the banks to purchase these S7 million which could then be refunded at a later time.
We anticipate the sale of $5 million of bonds in December to refinance the SS million maturing issue.
Pennsylvania Electric Penelec has ample interest coverage throughout 1980 to issue mortgage bonds but does not need any external capital until the fourth quarter of 1930. Our current forecast calls for a S30 million mortgage bond to be issued in December 1983 (Penelec bas interest coverage to issue more than $30 million if needed). Penelec does not have a significant dollar cmount of securities maturing during 1980.
Jersey Central Power & Light and GPU Corporation Our forecast does not include any long-term financing for Jersey Central or GPU Corporation during 1980.
INTERROGATORY NJ. 46 Please provide copies of all analyses prepared by or for Licensee concerning the availability of long-term finan-cing for Licensee.
_,_ 1946 030
RES PONSE Reference is made to the response to Interrogatories Nos.
41 and 42 as to analyses of financial position. These include studies of interest and preferred stock coverage and, there-fore, define the ability of the operating companies and of GPU to issue long-term financing.
INTERROGATORY NO. 47 Has Licensee or its parent, GPU, had prepared any studies or analyses regarding the potential impact if Licensee were to be unable to meet its debts and file for bankruptcy?
INTERROGATORY NO. 48 If so, state:
(a) the names, addresses and telephone number of each person who prepared these studies; (b) the names, addresses and telephone number of each person who has custody of these studies; (c) identify and provide all such records, notices, reports, and memoranda dealing with these studies.
RES PONSE NO. 47 While no formal studies or analyses of the potential im-pact if Licensee were to be unable to meet its debts and file for bankruptcy has been performed, Licensee has had continuous discussions within its organization and with its advisors on this subject.
NO. 48 (a) 1. James B. Liberman, Esq.
Berlack, Israels & Liberman 26 Broadway New York, New York 10004 (212) 248-6900 1946 031
- 2. Mr. Aaron Levy (202) 523-5691 Mr. Grant Guthrie (202) 523-5156 Division of Corporate Regulation Securities and Exchange Commission 1100 L Street, N.W.
Washington, D.C. 20005
- 3. Mr. John G. Graham, Vice President & Treasurer GPU Service Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 (201) 263-6130
- 4. Harvey R. Miller, Esq.
767 Fifth Avenue New York, New York 10022 (212) 758-7800
- 5. Mr. L. Sandford Reis Reis & Chandler 14 Wall Street - Suite 2910 New York, New York 10005 (212) 964-3936 (b) Mr. John G. Graham, Vice President & Treasurer GPU Service Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 (201) 263-6130 (c) Copies of the testimony of Mr. Aaron Levy bJfore the New Jersey Board of Public Utilities under Docket No.
795-427, and the testimony of Mr. John G. Graham be-fore the PaPUC, will be placed in Licensee's Discovery Reading Room. A study by Mr. Miller is in the process of being prepared for submission as tes-timony before the PaPUC. This will be supplied when completed.
INTERROGATORY NO. 49 Since the March 28, 1979 accident, has the Licensee been unable to pay those debts which it normally paid out of current revenues prior to the March 28, 1979 accident?
1946 032 INTERROGATORY NO. 50 If so, state:
(a) each instance of indebtedness Licensee has been unable to pay out of current revenues; (b) how the Licensee has obtained funds necessary to meet these debts; (c) refinancings that Licensee has done since the March 28, 1979 accident.
RES PONSE (a-c)
Because GPU and its subsidiaries are involvei in a capital intensive industry, GPU has never been able to meer its needs for funds through internal cash generation either before or after the March 28 accident. GPU is no different from any other major electric utility in that as long as a company is involved in a substantial construction program, there is a need to secure financing from external capital sources. Since the accident the GPU System has continued to require external funds but it is not possible to " trace" dollars in terms of their source and application, that is, for any specific application of funds (e.g., construction) it is not possible to state what the corresponding cource of funds was (e.g. internal genera-tion or external financing).
The GPU System has obtained external funds since the acci-dent through the sale of First Mortgage Bonds and short-term borrowings in the following amounts:
First Mortgage Bonds Jersey Central Power & Light
- $50 million issued in June, 1979
- S47.5 million issued in October, 1979 Pennsylvania Electric
- $50 million issued in June, 1979 1946 033 Short-Term Debt Borrowings
($ Millions)
Short-Term Debt Outstanding Increase in March 31, 1979 December 31, 1979 Borrowings Jersey Central $53 $45 S(8)
Met-Ed 30 68 38 Penelec - - -
GPU Corp. 16 58 4_2 Total $99 $171 $72 The only maturing debt that has been refinanced was $25 million of Jersey Central First Mortgage Bond'. s This refunding was part of the S47.5 million bond issue in June, 1979.
Dated: January 22, 1980 1946 034 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY )
Docket Nc. 50-289 Restart)
(Three Mile Island Nuclear Station, Unit No. 1) )
AFFIDAVIT OF JOHN G. GRAHAM State of New Jersey )
.i : SS County of M" .M $ )
JOHN G. GRAHAM , ceing duly sworn according to law, deposes and says that he is Treasurer of General Public Utilities Corporation; that the information contained in Licensee 's Responses ':.o Interrogatory Nos. 41, 42, 43, 44, 45, 46, 47, 48, 49, and 50 are true and correct to the best of his knowledge and belief.
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c'. . ~ . f .' .
V John G Graham
-.. v Treasurer Sworn to and subscribed before me this N 4 day of January, 1980.
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Notary Public , _ _ . _
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My Commission Expires .
1946 035
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-239
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
Certificate of Service I hereby certify that copies of " Licensee's Response to Interrogatories 41-50 (First Set) Of Three Mile Island Alert, Inc." together with Licensee's accompanying transmittal letter, dated January 22, 1980, were served upon those persons listed on the attached Service List, by U.S. mail, first class, post-age prepaid, this 22nd day of January, 1980.
M Harry . Glasspieg'ehf Dated: January 22, 1980.
1946 036
UNITED STATES OF .33. ERICA NUCI.I.E PIGU~ ATORY CCMMISSICN
.p_ID 3 _r_r O u. r . u..r as-c.u. v_ o ,._e r_ _ v_ . C r s.To- m_.I G 3 0.3 2.D In the Matter of )
)
MITROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
arsV.Cr 1 ..S, u_ _
Ivan W. Smith, Esquire Jchn A. Lav'_n, Esqaire Chair an Assistant Counsel Atcmic Safety and Licensing Pennsylvania Public C64'irf C n 'n Scard Panel ? cst Office Ecx 3265 U.S. Nucla=- Fagulatory C r issicn Earrisburg, Pennsylvar = '7120 4 Washingt:n, D.C. 20555 Earin W. Carter, Esquire Dr. Walter E. Jorfan Assistant Atter.ey General Atcmic Safety and Licensing 505 Executive Ecuse Scard Panel ? cst Office Scx 2357 381 West Cuter Crive Harrd eurg, Perr.sylvar = i
'7120 Cak Rifge, Tennessee 37820 Jchn T vi-aich Cr. Linda W. Little Chai.ran, Cauchin Ccuntf Scard Atcmic Safety and Licensing of n',94asicners Scard Panel Cauchin Cctntf Ccurthcuse 5000 Herritage Drive Front and Market Streets Faleigh, Ncr,A Carolina 27612 ?= _sburg, Fernsylvania 17101 Jares R. Tcurcellotte, " squire. Walter W. Cchen, Esquire Office of the F.xece.ive Legal Direc cr Const:rer Ph/ocate U. S. Nrclaa- Fe e ulatcry Cc mission Cffice of Ccnst:rer Phxcate Washingcon, D.C. 20555 14th Flecr, Straterry Sqcare F= _sburg, Pennsylvania 17127 Dccketing and Se vice Sec icn Cffice of the Secrets ]
U. S. N'cla=- Fag"' =tcry Conn'issicn Washingtcn, D.C. 20555 1946 037
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"yn R. Weiss, Esquire Chauncev. Kepferd At c rey for de t;nien of Conce =ed Scientists Judid H. Jchnsrud Shelden, Ha'..en & Weiss Erre = ental Ccai4 tien en Nuclear 1725 Eye Street, N.W., Suice 506 ?cwer Washi. p , D.C. 20006 433 Criand: Avenue state Ccilege, Pennsylvania 16E01 5teven C. ShcIly 304 Scuch Market Street .v.arr n I. *se s MecP2nicsburg, Ferrsfl vania 17055 6504 3r=d#crd Te_m ce
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- - - . ' Marjerie M. 2 m. 2 edt Eclly S. Keck I.egislaticn O =4 -an R. D. 5 Ar?i-Nuclear Grouc Fepresenti .g Ycrk Ccatesville, Fenrsf 1vania 19320 245 West Philadel=hia Street Yort, Pennsylvania 17404 1946 038