ML19331D303
| ML19331D303 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/25/1980 |
| From: | Adler T THREE MILE ISLAND ALERT, WIDOFF, REAGER, SELKOWITZ & ADLER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8008280560 | |
| Download: ML19331D303 (3) | |
Text
5 -7:.f3 DOCUMENT CONTAINS P00R QUALITY PAGES
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NUCLEAR REGULATORY COMMISSION
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d-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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METROPOLITAN EDISO.T COMPANY
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Docket No. 50-289 (Restart)
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(Three Mile Island Nuclear
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Station, Unit No. 1)
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TMIA'S OBJECTION TO VICTAULIC COMPANY OF AMERICA. ET AL._
PETITION TO INTERVENE On August 13, 1980, TMIA war served with Victaulic's petition to intervene.
This petition cited 10 CFR 2.714 as authority for late intervention.
TMIA does not believe that the require-ments for late intervention has been met, and therefore, Victaulic's petition should be denied.
Both 10 CFR 2.711(A) and 2.714(a) (1) (1) state that good cause should be shown before an extention of time is granted.
Victaulic has not made such a showing in this case.
Paragraph 19 states that the July 29, 1980 filing (for 76.5 million rate increase) has made it clear that petitioners "have very vital interests at stake" in this proceeding.
This argument at this i
point in time is unpersuasive.
l The petitioner's have known the ramifications of these
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proceedings from the outset.
In fact, a letter dated June 26, 1980 from petitioner Lebanon Steel Foundry (attached) states the 9503 Oj
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._d sa=e basic argn=ent set forth in the petition It is evident s
frc= the June 26, 1980 letter that the petitioners have been monitoring the effects of this 11tiga.icn fer sc=e ti=e.
Petitioners have had a=ple c;;crtunity to intervene in this proceeding and gced cause has net been she*n for the delay.
Respectfully sub itted,
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Theedere/ a. Adler
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Cated:
August 25, 1980
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CERTIFICATE OF SERVICE I hereby certify that I caused a true and correct ecpy of the fecegoing docu ent to be placed in the United States = ail, first-class, postage prepaid, addressed to the persons listed below:
Ivan W.
Smith, Chairman Atomic Safety & Licensing Ecard Panel U.S. Nuclear Regulatory Cc=ission
,'. 3. i Washington, DC 20555
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s Dr. Walter H. Jordan
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C Cak Ridge, TN 37830 a
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Little.:
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- i s _s George F. Trewbridge, Esquire Shaw, Pittman, Pctts & Trewbridge 1800 M Street, N.W.
Washington, DC 20005 Decketing and Service Section U.S.
Nuclear Regulatory Commission Washington, DC 20555 Executive Legal Director U.S. Nuclear Regul cry Cc=1ssien Washingten, DC 2C
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Dated:
August 26, 1930
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June 26, 1980 c.. aries w. M emn;er
.reasurer Docxmn USNRC Mr. John F. Ah u ne, Chairman 2
U.S. N. R. C.
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Washington, D.C.
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Dear Mr. Ahearne:
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/e In reviewing the effect of the rate increase apprc,ved by the Penn-sylvania Public Utility Commission for Met-Ed customers, we find the impact to be shocking and frightening.
We realice that energy costs will be subjected to inevitable in-creases of sarying proportions, and we aie prepared to pay for this
=recious service.
Ecwever, the current situation needs a more in-tensive review than we believe has been given.
In addition, we also believe that seme of the underlying concepts, statistics, facts and prospects should be more thorougnly understood by the public.
In order to better understand our position, we will have to use the financial effect that this increase has en cur company.
We have used actual use figures for the last 12 months to compare old costs to the revisions brought on by this rate increase.
The net result will increase cur costs by $36.50 per ton for each ten shipped.
Any of our competitors not located in Me:-Id territory have a distinct advantage over us, and as you can probably appreciate it is increas-ingly difficult to explain this to cur cus:cmers.
';:.e =cs: frightening statistic brought en by this increase is that the energy charge on the new rate schedule is $163,000.00 =cre than the base costs of the power.
The energy charge results from a re-vised formula for recapturing fuel costs, including purchased pcwer, as last approved by P.U.C.
Cn a typical industrial bill the base rate cost is about 1.9c/KG., but the fuel adjustment charge is
- 2. 7 c/:GE.
- n recomputine. our pcwer ces:s the energy char e addus:=ents went c:
2 a
69 The old rate adjustment was.015654 and the new charge is
.02650.
Using the 12 menth period ending March 1980 under the new rate schedule, cur energy charge costs would have increased 5339,000.00.
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Juno 26, 1980 Paco #2
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The Met-Ed energy charge adjustment is the hichest in the State.
The basic reason for this is that 50% of the power used by Met-Ed cus-temers must be purchased.
A major source of this power is frc= Penn-I svivania Power & Light company which has the second 10 wast enere.v charc.e in the State, and is undoubtediv. affected b.y the sale of power to Met-Ed.
Under the rules that apply, the selling utility is. per-
- itted to charge the purchasing utility their highest cosu rate of generation - under the assumption that the extra costs generated is not needed by the selling utility censumers'.
On a ecmparktive basis, PP&L's energy costs is about.6c/KWE compared to Met-Ed's at 2.7 C/KWE.
The basic costs of pcwer generation of both companies is within
.2c/KWE.
The base cost of power should not under any circumstance be less than
'he cost'of the energy on a c/KWE unit.
Our situation - and all t
Me:-Ed customers -- is =.====. ted by the need for Met-Ed to bu.v c. ewer frem other utilities under the penalties already described.
It is a known factor that the fuel costs of nuclear pcwer are far less than fossil /cil/ ether fired generating units.
TMI Unit el, as we understand 1t, is ready to generate pcwer with a very short le ad-time.
We believe it is imperative that this unit be put back en stream at the earliest possible date.
Not to do so causes excessive costs and severe penalties to manufacturers in Met-Ed's carritory because we are at a ce=petitive disadvantage.
We wculd appreciate everv. effort that vcu can c.ossibiv e=c.lo.v to c.et the "'MI Unit #1 back On stream at an early date.
The statistics given above shcw that our dollar cost is much higher than the average cus-tomer would ever experience but the 20.5% increase is ccmpatible to all users.
Please help us!
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