ML19327A049
| ML19327A049 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| 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
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Docket No. 50-289
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(Restart)
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Se!. Y[,$ f[Y TMIA'S INTERRCGATORIES BASED ON NEW 6 i
INFORMATION CONTAINED IN THE
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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:
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Mark P. Wideff
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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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4 Dr. Linda W. Little 5000 Hermitage Drive ccc;c4rga UsNac 3
Raleigh, NC 27612
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George F. Trowbridge, Esquire
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a :,,.9 [y3;7 Shaw, Pitunan, Potts & Trowbridge T ;;
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1800 M Street, N.W.
Washington, DC 20006
...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