ML19316A973
| ML19316A973 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/25/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8005280114 | |
| Download: ML19316A973 (5) | |
Text
r Lic 4/25/80 W p
UNITED STATES OF AMERICA 0/
g NUCLEAR REGULATORY COMMISSION
~
E APR 2 Before the Atomic Safety and Licensing Boar 0
'g ce 9 -
e 5'
In the Matter of
)
a)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
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LICENSEE'S RESPONSE TO MOTION TO COMPEL OF PENNSYLVANIA PUBLIC UTILITY COMMISSION By motion dated April 17, 1980, Pennsylvania Public Utility Commission ("PUC") seeks information on cash flow studies prepared by or for Licensee since January 29, 1979, additional to the information supplied by Licensee in its March 17, 1980 Response to Interrogatory No.
6.
By filing dated February 25, 1980, Licensee objected to Interrogatory No. 6 on the grounds that it was unlimited in scope and time frame; but Licensee did, in its March 17 Response, supply its most recent cash flow projections and short-term debt forecast.
Thereafter, in a letter dated March 26, 1980,.from the PUC counsel to the undersigned, which was served on the Board and parties, the PUC stated that " Interrogatory No. 6 which asks for cash flow studies prepared by or for Met Ed includes all cash flow studies prepared or submitted on or after January 29, 1979 until and including. January 29, 1980."
Licensee is assembling additional cash flow information responsive to the PUC's March 26 specification of its earlier discovery request,-and expects to be able to supply this s 0 0 5 280 //$l
o information by May 2, 1980, or shortly thereafter.
Accordingly, Licensee requests that the Board withhold ruling on the PUC's April 17 Motion unless or until the Board is informed by the PUC that Licensee's additional response is not satisfactory.
Licensee's responses to PUC's discovery requests are voluntary in nature; Licensee does not agree that NRC regula-tions sanction discovery by State agencies participating pursuant to 10 CFR 2.715(c).
Such agencies are not " parties" entitled to discovery under 10 CFR 2.740 (a).
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By J.4W(2, d4 George /F. Trowbridgs/ j-p/p(-
Dated:
April 25, 1980 i
,1
Lic 4/25/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMPISSION Before 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)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response to Motion to Compel of Pennsylvania Public Utility Commission,"
dated April 25, 1980, were served upon those persons on the attached Service List, by U.
S.' Mail, first class, postage prepaid, this 25th day of April, 1980.
/
CSfA s
m/
Harry
/ Glasspiege'l d Dated:
April 25, 1980 i
l
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
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Ivan W.
Smith, Esquire John A.
Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm'r Board Panel Post Office Box 3265 U.S.
Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C.
20555 Karin W.
Carter, Esquire
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Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box 2357 E81 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 John E.
Minnich Dr. Linda W.
Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R.
Tourtellotte, Esquire (4)
Walter W.
Cohen, Esquire Office of the Executive Legal Director Consumer Advocate U.
S.
Nuclear Regulatory Commission Office of Consumer Advocate Washington, D.C.
20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21)
Office of the Secretary U.
S.
Nuclear Regulatory Cormission Washington, D.C.
20555 l
l l
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Jordan D.
Cunningham, Esquire Karin P.
Sheldon, Esquire Attorney for Newberry Township Attorney for People Against T.M.I.
Steering Committee Nuclear Energy 2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W.,
Suite 506 Washington, D.C.
20006 Theodore A.
Adler, Esquire Widoff Reager Selkowitz & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R.
Weiss, Esquire Chauncey'Kepford Attorney for the Union of Concerned Judith H.
Johnsrud Scientists Environmental Coalition on Sheldon, Harmon & Weiss Nuclear Power 1725 Eye Street, N.W.,
Suite 506 433 Orlando Avenue Washington, D.C.
20006 State College, Pennsylvania 16801 Marvin I.
Lewis Steven C.
Sholly 6504 Bradford Terrace 304 South Market Street Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania 19149 Gail Bradford Marjorie M.
Aamodt R.
D.
5 Holly S.
Keck Coatesville, Pennsylvania 19320 Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 I
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