ML19329C388
| ML19329C388 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 02/14/1975 |
| From: | Berger M, Charno S JUSTICE, DEPT. OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8002130757 | |
| Download: ML19329C388 (4) | |
Text
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COnhISSION tiEFORE THE ATOMIC SAFTSY add LICENSING BOARD In tne Matter of
)
THE TOLEDO EDISOd COMPANY ano
)
THE CLEVELAND ELECTRIC ILLUMIdATIdG
)
AEC Docket No. 50-346A COMPAdY
)
(Davis-Besse Nuclear Power Station)
)
)
THE CLEVcLAND ELECTRIC ILLUMINATING
)
AEC Docxet dos. 50-440A COMPAdY, ET AL.
)'
50-441a (Perry Nuclear Power Planc,
)
Units 1 and 2)
)
SUPPLEMcNTAL INTERROGATORIES sY THE DEPARTMENT OF JUSTICE TO TdE CLEVELAND ELECTRIC ILLUMInATIdG COaPAWY, OdIO EDIS0d COMPANY, PENNSYLVANIA POWEk COMPANY add THE TOLEDO EDIS0a CUMPANY Pursuant to Rule 2.740(o) of tne Commission's Rules of Practice (10 C.F.R. 32.740(b)) and Applicant's statement at page l? of the Applicants' Decemoer 16, 1974 sucmission entitled
" Applicants' Reply to Motions of tne AEC Regulatory Staf f, the Department of Justice, and the City of Cleveland to Produce Documents in Wasnington, D.C., and to submit Additional Infor-mation in Response to Interrogatories", the Department of Justice
(" Department") nereby suomits supplemental interrogatories.
Responses to tne supplemental interrogatories snall be served upon tne U.S. Department of Justice, Wasnington, D.C.
20530 within
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fifteen (i 5) days (see page 14 of tne " Memorandum of the Depart-i ment of Justice on Document Froduction Submitted at the Request of tne Ato nic Safety and Licensing Board" filed January 2, 1975).
Respectfully suomi ted, 7
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Steven 3. Cnar'no Attorney, Antitrust Division Department of Justice
'Afv Melvin G.
Berger Attorney, Antitrust Division Department of Justice Dated at hasnington, D.C.
tnis 14th day ot feoruary 1975 l
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f SCdEDULE Definitions All definitions used in the August 23, 19'/4 " Joint Request of the AEC Regulatory Staff and U.S. Department of Justice For Interrogatories anc for Production of Documents by Applicants" witn the exception of " Company" shall be applicable to the supplemental inter rogatories.
" Company," as used herein, shall mean The Cleveland Electric Illuminating Company, Onio Edison Company, Pennsyl-vania Power Company, and Tne Toledo Edison Company, respect-tively, its suosidiaries or affiliates, predecessor companies and any entities providing electric service at wholesale or retail, tne properties or assets of whicn have been acquired by it.
In addition, for tne purposes of the supplemental inter-rogatories only, the term " system" shall mean transmission facilities of Company capaole of transmitting electric power and/or energy at 35 kv or higner.
Supplemental Interrogatory No. 1 Since Septemoer 1, 1965, has Company ever directly or indirectly transmitted electric power ana/cr energy (wnether originating inside or outside Company's system) from its trans-mission system to tne transmission system of any electric utility (wnether directly interconnected with Company or not) engaged in the utilization, sale or furtner transmission of enat power and/or energy?
If so, describe each stiuation, stating (a) tne O
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parties involved, (b) tne time period (s) involved, (c) the amount of energy and/or power in MWs involved annually, (d) the reason (s) toe tne transmission (s), (e) the date of and signatories to any agreement relating to each sucn situation, (f) tne rate (s) at which tne Company billed the otner electric utility (s) for each transaction, and (g) the method and factors used to determine the rate (s) listed in response to part (f) above.
Supp1'emental Interrogatory No. 2 Since September 1,1965, has Compdny ever refused any request, either formal or informal, to transmit electric power and/or energy in tne manner descrioed above in Interrogatory No. 1?
If so, describe eacn such request oy (a) the date of the request, (b) tne party making tne request, (c) tne proposed supplying and receiving parties, (d) tne requested transmission routa, (e) the amount of power involved, (f) tne time period involvec, (g) the reasons for Company's decision witn regard to this request, and (h) the identity by date, author (s) and suoject matter of any documents relating thereto.
Supplemental Interrogatory No. 3 Since Septemoer 1, 1965, has Company had electric power and/or energy transmitted to it either directly or indirectly from the transmission system of any otner electric utility (wnether or not said utility is directly interconnected witn Company)?
If so, describe eacn situation, stating (a) the parties involved, (c) the time period (s) involved, (c) tne amounts of energy and/or power in Mna involved annually, (d) the reason (s) for the Y
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transmission (s), (e) tne date of and signatories to any agreements relating to eacn such situation, and (f) the rate (s) at wnich Company was billed for each tr ansaction.
Supplemental Interrogatory No. 4 State each request, either formal or informal, since September 1,1965 made by any electric utility to Company for a new or altered interconnection arrangement, giving (a) tne name of the entity, (o) the date of tne request, (c) tne date of any agree-ment to interconnect, (d) tne reasons $or any refusal to inter-connect, and (e) ene date and author (s) of any document relating to any sucn refusal.
Supplemental Interrogatory No. 5 Since Septemoer 1, 1965, has Company ever purchased a dis-cernible quantity of electric power and/or energy from another electric utility at one point on its system and, within about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, sold a comparable quantity of electric power and/or energy to that same electric utility at another point on the Company's system?
If so, describe eacn situation, stating (a) the parties involved, (o) tne time period (s) involved, (c) the amount of power and/or energy in MwH involved annually, (d) the reason (s) for the transaction (s), (e) the date of and signatories to any agreements relating to each situation, (f) tne rate at which Company billed '
tne other electric utility, (g) the rate at which the otner elec-tric utility oilled the Company, and (h) the method and f actors used to determine the rates listed in response to parts ( f) and (g).
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Supslemental Interrogatory do. 6 Since Septemoer 1,1965, has Company ever purchased a dis-cernible quantity of electric power and/or energy from another electric utility at one point on its system and, within about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, solo a comparable quantity of electric power and/or energy to anotner electric utility (or utilities) at another point (or points) in Company's system?
If so, describe each situation, stating (a) the parties involved, (D) the time period (s) involved, (c) the amount of power ana/or energy in MnB involved annually, (d) the reason (s) for the transaction (s),
(e) the date of and signatories to any agreements relating to each situation, (f) tne rate at wnica Company billed tne other electric utility (or utilities), (g) the rate at whicn the other electric utility billed tne Company, and (h) the metnod and factors used to determine the rates listed in response to parts (f) and (g).
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COdnISSION SEFORE THE ATOMIC SAFTEY AND LICENSING BOARD
)
In tne Matter of THE TOLEDO EDISON COMPANY and
)
THE CLEVELAND ELECTRIC ILLUMINATING
)
AEC Doc.ket No. 50-346A
)
COMPANY (Davis-Besse Nuclear Power Station)
)
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THE CLEVELAND ELECTRIC ILLUMINATING
)
AEC Docket Nos. 50-440A 50-441A COMPANY, ET AL.
)
(Perry Nuclear Power Plant,
);
)
Units 1 ano 2)
CERTIFICATE OF SERVICE I nereby certify that copies of tne SUPPLEMENTAL INTERRO-GATORIES bY THE DEPAkTMEdT OF JUSTICE TO THE CLEVELAiiD ELECTR ILLUMINATING COMPANY, OdIO EDISON COhPANY, PENNSYLVANIA POWER COMPANY AND THE TOLEDO EDISON COdPANY have been served upon all the parties listed on tne attacnment hereto oy deposit in tne United States mail, first class or airmail, this 14th day of Feoruary 1975.
h&% lI Melvin G.
derger Attorney, Department of Justice Antitrust Division he
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ATTACHMENT John B. Farmakides, Esq.
Roy P. Lessy, Jr., Esq.
Chairman Benj amin H. Vogler, Esq.
Atomic Safety and Licensing Lee S. Dewey, Esq.
Office of the General Board U.S. Atomic Energy Commission Counsel U.S. Atomic Energy Commission Washington, D.C.
20545 a
Washington, D.C.
20545 John H. Brebbia, Esq.
l Atomic Safety and Licensing :
Gerald Charnoff, Esq.
Board William Bradford Reynolds, Esq.
Alston, Miller & Gaines Shaw, Pittman, Potts-&
1776 K Street, N.W.
Trowbridge Washington, D.C.
20006 910 Seventeenth Street, N.W.
Washington, D.C.
20006 Douglas Rigler, Esq.
Hollabaugh & Jacobs Lee C. Howley, Esq.
Suite 817 Vice President & General Counsel Barr Building The Cleveland Electric 910 Seventeenth Street, N.W.
Illuminating Company Washington, D.C.
20006 Post Office Box 5000 Atomic Safety and Licensing Board Panel Donald H. Hauser, Esq.
U.S. Atomic Energy Commission Corporate Soli'citor Washington, D.C.
20545 The Cleveland Electric Illuminating Company Frank W. Karas-Post Office Box 5000 Chief, Public Proceedings Cleveland, Ohio 44101 Staff Office of the Secretary John Lansdale, Jr., Esq.
U.S. Atomic Energy Commission Cox, Langford & Brown Washington, D.C.
20545 21 Dupont Circle, N.W.
Washington, D.C.
20036 Abraham Braitman Office of Antitrust and Chris Schraff, Esq.
Indemnity Office of Attorney General U.S. Atomic Energy Commission State of Ohio Washington, D.C.
20545 State House Herbert R. - Whitting, Esq.
Robert D. Hart, Esq.
Dwight C. Pettay, Jr., Esq.
Law Department Assistant Attorney General City Hall Chief, Antitrus t Section Cleveland, Ohio 44114 30 East Broad Street 15th Floor Reuben Goldberg, Esq.
Columbus, Ohio 43215 David C. Hjelmfelt, Esq.
1700 Pennsylvania Avenue, N.W.
Suite 550 Washington, D.C.
20006 l
l l
Thomas A. Kayuha, Esq.
Ohio Edison Company 47 North Main Street Akron, Ohio 44308 David M. Olds, Esq.
Reed, Smith, Shaw & McClay 747 Union Trust Building Pittsburgh, Pennsylvania 15219 Mr. Raymond Kudukis Director of Utilities City of Cleveland 1201 Lakeside Avenue Cleveland, Ohio 44114 i
Wallace L. Duncan, Esq.
Jon T. Brown, Esq.
Duncan, Brown, Weinberg
& Palmer 1700 Pennsylvania Avenue, ii.W.
Washington, D.C.
20006 Leslie Henry, Esq.
Fuller, Henry, Hodge &
Snyder 300 Madison Avenue Toledo, Ohio 43604 Deborah Powell Highsmith, Esq.
Assistant Attorney General Antitrust Section 30 East Broad Street 15th Floor Columbus, Ohio 43215 t
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