ML19327A049

Interrogatories Directed to Licensee Re Harrisburg Patriot 800714-16 Articles, Cleanup at TMI Will Take Yrs, & Met-Ed Asks $76.4 Million Rate Increase. Requests Cost Estimates.Certificate of Svc Encl.Related Correspondence

ML19327A049
Person / Time
Site:	Three Mile Island
Issue date:	07/24/1980
From:	Widoff M THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER
To:	METROPOLITAN EDISON CO.
References
ISSUANCES-SP, NUDOCS 8008010103
Download: ML19327A049 (4)

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

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289 ~

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TMIA'S INTERRCGATORIES BASED ON NEW 6 Se!. Y[,$ f[Y i INFORMATION CONTAINED IN THE ""9 3 HARRISBURG PATRIOT, JULY 14 & 16, 1980 9 y These interrogatories are submitted pursuant to the Board's Order cf May 5,1980, for discovery requests based upon new information. Interrcgatories 1-4 are based upon an article in the Harrisburg Patrict dated July 14, 1980, entitled " Cleanup At TMI Will Take Years", which stated that the cost cf cleanup would cost "well ever $400,000,000.00" (Harrisburg Patriot, p . 2) . Interrogatories 5-7 are based upon an article in the Harrisburg Patrict dated July 16, 1980, entitled " Met-Ed Asks $76.4 Million Rate Increase", which reported the filing cf a " letter of intent" with the Public Utility Commissicn.

Interrogatory No.1 Provide all cost estimates and other data relied upcn by Licensee in deter-mining that it will cost "well over $400,000,000.00" (Harrisburg Patrict, p . 2) to cleanup TMI-2.

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Interrogatory No. ' 2

.On what date did Licensee determine that its previcus cleanup cost esti-mates were too low?

Interrogatory No. 3 Provide an analysis of the factors used by Licensee in concluding that the -

cost cf niI-2 cleanup would exceed previcus estimates.

Interrogatory No. 4 Provide the name and position cf each persen involved in the analysis of n!I-2 cleanup ccsts as well as a description of each person's particular responsibilities .

Interrogatory No. 5 Provide all financial data, exhibits and witness statements which will be relied upon by Licensee in seeking an additional rate increase from the Pennsyl-vania Public Utility Commission (per the newspaper article of July 16, 1980).

Interrogatory No. 6 Provide the analysis used by Licensee in concluding that an additicnal rate increase is required.

Interregatory No. 7 Provide the name and position cf each person involved in the analysis cf Licensee's need for an addidenal rate increase as well as a descripticn cf each persen's particular responsibilities.

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P Respectfully submitted, WICOFF, REAGER, SELKOWITZ & ADLER, P.C.

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By: O[ / [/

Mark P. Wideff (

P . G. Box 1547

.arrisburg, PA 17105 (717) 763-1383 Dated: July 24,1980 1

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1 ar;,uTED ccRRE.5POMM:3 CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct copy of the foregoing document, TMIA's Interrogatories Based On New Information Contained In The Harrisburg Patriot, July 14 & 16, 1980, to be placed in the United States mail, first-class, postage prepaid, addressed to th'e persons listed belcw:

Ivan W. Smith, Chairman Atomic Safety & Licensing Board Panel U.S . Nuclear Regulatory Ccmmission Washington, DC 20555 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, TN 37830

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Dr. Linda W. Little ' 4 5000 Hermitage Drive ccc;c4rga Raleigh, NC 27612 ~'

UsNac 3 George F . Trowbridge, Esquire q JUL 2 a1939 ,

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, 4 Shaw, Pitunan, Potts & Trowbridge , aT:,,;;.9 [y3;7 1800 M Street, N.W.

Washington, DC 20006

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.n l l 101 Docketing and 3ervice Section U.S. Nuclear Regulatory Ccmmission Washington, D3 20555 Executive Legal Director U.S. Nuclear Regulatory Ccemissien Washington, DC 20555

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/.. ' Mart P . Widoff f Dated: . July 24,1980 4