ML19296C677

PA Public Util Commission First Set of Interrogatories to Licensee.Includes Request for Info Re Witnesses,Financial Qualifications,Cash Flow & Managerial Capability.Certificate of Svc Encl

ML19296C677
Person / Time
Site:	Three Mile Island
Issue date:	01/29/1980
From:	PENNSYLVANIA, COMMONWEALTH OF
To:	METROPOLITAN EDISON CO.
Shared Package
ML19296C676	List: ML19296C675 ML19296C677
References
NUDOCS 8002270463
Download: ML19296C677 (9)

Text

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UNITED STATES OF AMERICA -

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NUCLEAR REGULATORY COMMISSION 6 e I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Cb -[

In the Matter of  :

METROPOLITAN EDISON COMPA5'l  : Docket No.

(Restart)

(Three Mile Island Nuclear  :

Station, Unit No.1)  :

PENNSYLVANIA PUBLIC UTILITY COMMISSION'S FIRST SET OF INTERROGATORIES TO LICENSEE METROPOLITAN EDISON These interrogatories are filed by the Pennsylvania Public Utility Commission (the " Commission") pursuant to 10 C.F.R. 52.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation. With respect to those in-terrogatories for which complete and responsive information is not now available to Metropolitan Edison, the Commission requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979 First Special Prehearing Conference Order.

Any reference to the " Licensee" or " Met Ed" shall be deemed to include any sister or parent corporation of Met Ed. When knowledge or information of Met Ed is requested, such request includes knowledge or informatior of Met Ed's members and, unless privileged, its attorneys (if any).

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DEFINITIONS A. " Document" means any written, recorded, transcribed, taped, f ilmed ,

or graphic =atter, however produced or reproduced, to which the responding party has or has had access.

3. " Study" means any written, recorded, transcribed, taped, filmed, or graphic matter, however produced or reproduced, to which the

. responding party has access which considers, either formally or informally, a particular issue or situation, in whatever detail, whether or not the consideration of the issue or situation is in a preliminary stage and whether or not the considerat. ion was dis-continued prior to completion.

C. " Person" means any natural person, corporation, prof essional corporation, partnership, association, joint venture, proprietorship, firm, or other business enterprise or legal entity.

D. "You" or "your" means the party to the proceeding to whom these information requests are addressed.

E. " Identify" or " identity" used in reference to a natural person means to state his or her full name and residence address, present or last known position and business affiliation, and position and business affiliation at the time in question.

F. "Identif y" or " identity" when used in reference to a document means to state the date or dates, author or originator, subject matter, all addresses and recipients, type of document (e.g., letter, me=orandum, telegram, chart, etc.), number or code number thereof or other means of identifying it, and its present location and custodian. If any such document was, but is no longer in your possession or subject to your control, state what disposition was made of it.

G. " Identify" or " identity" when used in reference to a business entity means to state its full name, the address of its principal office, and the type of entity.

H. "And" and "or" are both conjunctive and disjunctive.

I. Words in the singular include the plural, and words in the plural include the singular. "Each" and "any" are both singular and plural.

J. Words in the past tense include the present, and words in the present tense include the past.

K. Words in the masculine gender include the f eminine gender and words in the feminine gender include the masculine gender.

INSTRUCTIONS -

L. If any matter is evidenced by, referred to, reflected by, re-presented by, or recorded in any document identify or produce for . discovery and inspection each such document.

M. These information requests are continuing in nature, and infor=ation which,the responding party later becomes aware of or has access to and which is responsive to any request is to be made available to Bell.

N. Unless otherwise expressly provided, each information request should be construed independently and not with reference to any other, information request herein for purpose of limitation.

O. Answer each designated part of each information request separately.

If you do not have complete information with respect to any information request, so state and give as =uch infor=ation as you do have with respect to the =atter inquired about and identify each person who you believe may have additional infor=ation with respect thereto.

P. The information requests are to be answered under oath by an authorized person.

Q. If you object to any infor=ation request or to the production of amy document on the grounds of an asserted privilege, . identify the privileged document or subject matter claimed to be privileged, explain the reasons for your clai= of privilege and =ake a response to any portion of the request to which you do not object and produce any documents called for by the request to.which you do not assert a clai= of privilege.

1) State the name, address, position and occupation, place of e= ploy =ent and subject matter of testimony of all vitnesses who will be called by Met Ed in this proceeding to testify on any aspect of Met Ed's financial position and capabilities, either past, present or future.

2) State the name, address, position and occupation, place of'e= ploy =ent and subject =atter of testimony of all witnesses .who will be called by Met Ed in this proceeding to testify on any aspect of Met Ed's managerial capability or competence, past, present or future.

3) For each person named in response to Nos. 1 and 2 above who will testify to =atters of opinion based upon asserted expertise in some recognized discipline, profession or occupation, state all

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educational institutions attended after secondary school, all under-graduate and graduate degrees granted, areas of concentration, titles of theses, professional articles and books authored or co-authored; caption, docket number, date, place and subject matter su= mary of any prior testimony in any state or federal judicial or administrative proceeding, as well as the name of the party for whom appearing.

4) How does Met Ed define " financially qualified" in the context of this proceeding? If financial tests or ratios are referenced, specify methodology employed.

5) What facts or opinions demonstrate that Met Ed is financially qualified to operate TMI-l? If reference is made to documents, attach them or provide verbatim summaries thereof.

6) Have any cash flow studies been prepared by or for Met Ed? If so, state by whom they have been prepared, the dates of pre-paration and source and nature of assumptions used. Attach copies or verbatim su=maries thereof.

7) How does Met Ed define " managerially capable" in the context of this proceeding?

8) What f acts or opinions demonstrate that Met Ed is managerially capable to operate TMI-1, while maintaining TMI-II in a safe configuation and supervising cleanup and decontamination tasks?

If reference is made to documents, attach them or provide verbatim su=maries thereof.

9) Are all management positions within GPU, CPUSC, and Met Ed presently filled? " Management" as used in this interrogatory and Interrogatory No. 10 shall be defined as person holding line supervisory positions and above.

10) For each management position not presently filled, state job description, name of the prior incumbent, reason for his ter=ination, transfer or leave of absence and length of vacancy to date,

11) State in chronological sequence separately for TMI-l and 2 the nature, date and disposition of every NRC-alleged or reported violation, infraction or other item of non-compliance with NRC regu-lations or technical specifications. For each such violation, infraction or non-compliance, state the name of the NRC inspector making the report, and the report number.

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% f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 6 g*7Y '

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-4 In the Matter of g)TED cogg3POWN METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that I have caused to be for-warded the attached " Interrogatories to Licensee-Set-1" upon those persons as shown by the following Service List by ,

deposit in the United States mail, postage prepaid, this 29th day of January, 1980.

AL O '-

J o'n n' A . Levin Ahsistant Counsel Pennsylvania Public Utility Commission e

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire Marcia Mulkey, Esquire thairman Office of Executive Legal Director Atocic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Ms. Marjorie M. Aamodt Washington, D.C. 20555 R. D. #5 Coatesville, Pennsylvania 19320 Dr. Walter H. Jordan Atomic Safety and Licensing Ms. Holly S. Keck, Leg. Chairman Board Panel Anti-Nuclear Group Representing 881 West Outer Drive Ycrk (ANGRY)

Oak Ridge, Tennessee 37830 245 W. Philadelphia Street York, Pennsylvania 17404 Dr. Linda W. Little Atomic Safety and Licensing Ms. Frieda Berryhill, Chairman Board Panel Coalition for Nuclear Power 5000 Hermitage Drive Plant Postponement Raleigh, North Carolina 27612 2610 Grendon Drive Wilmington, Delaware 19808 James A. Tourtellotte, Esquire Office of the Executive Legal Mr. Robert O. Pollard Director Chesapeake Energy Alliance U.S. Nuclear Regulatory Commission 609 Montepelier Street Washington, D.C. 20555 Baltimore, Maryland 21218 Docketing and Service Section Karin W. Carter, Esquire Office of the Secretary Assistant Attorney General U.S. Nuclear Regulatory Commission 505 Executive House Washington, D.C. 20555 P.O. Box 2357 Earrisburg, Pennsylvania 17120 George F. Trowbridge, Esquire Shaw, Pite=an, Potts & Trowbridge Walter W. Cohen, Esquire 1800 M Street, N.W. Consumer Advocate Washington, D.C. 20006 Department of Justice For: Licensee Strawberry Square, 14th Floor Harrisburg, Pennsylvania 17127

Dr. Chauncey Kepford Karin P. Sheldon, Esquire Environmental Coalition on Nuclear Sheldon, Ha rmon , Roiscan & Weiss Power 1725 I Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801 For: PANE Robert L. Knupp, Esquire Mr. Steven C. Sholly Assistant Solicitor 304 South Market Street County of Dauphin Mechanicsburg, Pennsylvania 17055 P.O. Box P, 407 N. Front Street Harrisburg, Pennsylvania 17108 Theodore A. Adler Widoff, Reager, Selkowitz & Adler Mr. Marvin I. Lewis 3552 Old Gettysburg Road

. 6504 Bradford Terrace Ca=p Hill, PA 17011 Philadelphia, PA 19149 For: Three Mile Island Alert, Inc.

Jordan D. Cunningham, Esquire Ellyn P. Weiss, Esquire Fox, Farr & Cunningham Sheldon, Harmon, Roiseman & Weiss 2320 North Second Street 1725 I Street, N.W., Suite 506 Harrisburg, Pennsylvania 17110 Washington, D.C. 20006 For: Newberry Twp. TMI Steering For: Union of Concerned Scientists Committee

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