ML19347E653
| ML19347E653 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/30/1981 |
| From: | Russell S METROPOLITAN EDISON CO., RYAN, RUSSELL & MCCONAGHY |
| To: | PENNSYLVANIA, COMMONWEALTH OF |
| Shared Package | |
| ML19347E637 | List:
|
| References | |
| M-80070221, R-80051196, NUDOCS 8105130182 | |
| Download: ML19347E653 (21) | |
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BEFORT THE PENNSYLVANIA PUBLIC UTILITY COMMISSION Rare Investigation Docket No. R-80051196 M-80070221 EXCEPTIONS OF METROPOLITAN EDISON COMPANY TO RECOMMENDED DECISION OF ADMINISTRATIVE LAW JUDGE Metropolitan Edison Company
(" Met-Ed") hereby files the followinF exceptions to the Recommended Decision of the Administrative Law Judge ("ALJ") dated March 20, 1981 in the above matter:
1.
Recommended TMI-1 Disallowsuce Exception is caken to the findings and recommen-dations of the ALJ at pages 23 and 72 of the Recommended Decision, as follows:
"We find that TMI-1 is still not used and useful in the public service and, as such, should remain excluded from Met-Ed's rate base, resulting in the reduction of Met-Ed's measures of value by $162,660,000." (p. 23).
"Since we have determined that TMI-1 is not presently used and useful, and have excluded it l
from Met-Ed's rate base, consistently with sound regulatory principles and our past policy, we exclude and disallow all income effect of Met-Ed's ownership of the plant from the Company's revenue requirements, except as to our allowance for restart expenses at TMI-1."
(p. 72).
Exception is also taken to the failure of the ALJ
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to find that TMI-1 is properly includible in calculating an l
appropriate base rate allowance for Met-Ed, and that Met-Ed's test year rate base and operating income should include l
l 8105130 k
2-l the $162,660,000 and $17,258,000 amounts (reflecting a
$42,722,000 revenue requirement) claimed in Met-Ed's Exhibit l
B-152 and B-153, respectively.
I In support of these exceptions Met-Ed incorporates herein by reference pages 25-55 of its Brief.
As pointed out therein, the inclusion of TMI-1 in base rates is not precluded by the provisions of the Public Utility Code, nor i
is it precluded by the decisions of the courts.
In its May 23, 1980 Order eliminating THI-1 costs from base r a't e s the Commission cited Schuylkill Valley Lines i
v.
Pennsylvania Public Utility Commission, 165 Pa. Super.Ct.
393, 68 A.2d 448 (1949) as support for such action.
The analysis contained in Met-Ed's Brief (at pages 50-53) demon-strates that that decision does not support the Commission's action and, indeed to the extent that it is applicable, affirmatively supports the inclusion of the TMI-1 costs in base rates.
The Commission recognized in its May 23, 1980-Order "the fact that THI-l's unusually high level of operation has inured to the benefit of Respondents' customers" and that the delay in its return to service was the consequence of the NRC's action.
Through 1978, the average annual capacity factor for TMI-1 was about 78%, substantially above the national average for nuclear generating plants-and for modetn base load coal-fired generating units.
The operation of TMI-l j
saved Pennsylvania ratepayers approximately $250 million as compared to an oil-fired plant and approximar.oly $72 million l
I
o 3-if compared to a coal-fired generation station.
At the time of the TMI-2 accident, TMI-1 had j ust completed its scheduled refueling outage, was in hot standby status and all prepa-rations were on schedule to take it critical during the day shift on the day of the accident.
The start-up schedule for TMI-1 was delayed, not because of any damage suffered by THI-1, but because of Met-Ed's desire to protect the safety of the pubJte; TMI-1 was placed in a cold shutdown condition in order that all available manpower might be initially devoted to the TMI2 accident and its aftermath.
Yet, Met-Ed has been required by the NRC to keep TMI-1 in a cold shutdown condition pending a protracted formal hearing process.
No other nuclear plant licensee, whether operating a B&U unit similar to TMI-1 or otherwise, has been subjected to such constraints (Met-Ed Stat.
E, Supp.
2,
- p. 23).
The record in this proceeding refleccs the vigorous efforts that the TMI-1 owners have made and are making to be permitted to resume generation at TMI-1 end the substantial expenditures they are making for the purpose.
Inclusion of TMI-1 costs in base rates would be consistent with the Commission's action and the Commonwealth Court's decision in the case of West Penn Power Company v.
Pa.P.U.C.,
Cmwlth. Ct.
412 A.2d 903 (1980), where the Court recently upheld the Commission's inclusion in rate base of West Penn's investment in Mitchell Unit No.
3, the operation of which was halted in 1977 due to its failure to
4-comply with environmental regulations.
Met-Ed respectfully submits that the evidence of F
record likewise supports an allowance for TMI-1 operation and maintenance expenses (wbich are essential to the anti-cipated restart of the unit) substantially in excess of the
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$11 million recommended by the ALJ.
As shown in Met-Ed Exhibit B-lS3, Met-Ed's share of the TMI-l operation and maintenance expenses in the test year is approximately
$22,000,000.
Both Met-Ed and the Trial Staff repeatedly emphasized during the course of the proceedings the importance of the expeditious restart of TMI-l (Met-Ed Stat.
J, Exh.
J-6; N.T.
2173, 2636, 2677-8).
The ALJ also expressed whole-hearted agreement with the necessity to return TMI-l to service as soon as possible.
Unfortunately, the ALJ's recom-mendations do not provide sufficient funds to do all that might be done on that score.
This shortfall in providing the financial resources has assumed even greater importance since the ALJ's Recom-mended Decisions were issued on March 20, 1981, by reason of the Order adopted by the NRC on March 23, 1981.
In that Order, the NRC denied the request of the TMI owners (in a letter, dated December 1, 1980 to the NRC) that the restart of TMI-1 be divorced from the completion of the hearings j
before the ASLB, but it also made several determinations that will expedite restart if sufficient cash resources are 1
k available.
For examplo, the NRC Order granted the companies' request that they be allowed to begin hot functional testing of TMI-1, using non-nuclear heat, and decided that the companies' financial qualifications to operate TMI should not be litigated in the restart proceedings.
Moreover, the NRC Order directed the NRC's executiv'e director of opera-tions to " insure that sufficient resources are devoted" to the restart, calling the proceeding "one of [the NRC's]
staff's highest priority items."
These directives from the NRC should expedite the conclusions of the TMI-1 restart proceedings and afford a r
full opportunity to the conpanies to utilize promptly what-ever fincncial resources are made available to them for the J
purpose of expediting resumption of the operation of TMI-1.
It is therefore submitted that TMI-1 costs should properly be allowed in base rates.
2.
Exception to Depreciation Methodology Exception is taken to the recommendations of the ALJ at pages 27 and 66 of the Recommended Decision, as follows:
"We accept the recommendation of Commission Staff and find that Met-Ed's claimed depreciation l
reserve, excluding TMI-1, should be reduced by
$4,061,000 to $224,644,000."
(p. 27).
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"Since we have accepted Commission Staff's nethodology for depreciation allowance, we adjust Met-Ed's annual depreciation, excluding TMI-1 and TMI-2, to $21,064,000." (p. 66).
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Exception is also taken to the failure of the ALJ to find that Met-Ed's depreciation reserve and annual depreciation accrual should be the $255,361,000 and
$27,803,000 amounts claimed in Met-Ed's Exhibit B-152 and B-153, respectively.
The ALJ, in accepting the Commission Staff's depreciation recommendation, has rejected Met-Ed's claim for recognition of book reserves and remaining life accruals, both of which are consistent with generally accepted account-ing principles and sound regulatory policy.
A review of the data supporting Met-Ed's claimed depreciation reserve (and the depreciation rates used to compute the annoal provision for depreciation) can be found at pages 102-108 ef its Brief in the above proceeding, which incorporated herein by reference.
are As covered in some detail in Met-Ed/Penelec Exhibit G-20, the use of book reserves and remaining life capital recovery accruals achieves a fair and equitable balancing of the interests of both ratepayers and investors.
Calculated reserves and whole life accruals, on the other hand, result in a windfall either to the racepayer or the investor (depending on the circumstances), to the disadvantage of the other. Exhibit G-20 contains a listing of 44 juris-dictions which use book reserves, 37 of which also allow remaining life accruals.
7-Furthermore, when one studies the history of de-preciation calculations for the companies (including the theoretical reserve requirements as determined by engineer-ing studies and reserve requirements mandated by the Commission as a result of its own staff's calculated reserves) it becomes readily apparent that, apart from any abstract consideration of methodology, the Staff's recommendation is not factually supportable.
- See, e.g. Med-Ed/Penelec Exhibit G-24.
3.
Exception to Exclusion of Unamortized Expense Balances from Rate Base Exception is taken to the recommendation of the ALJ at page 32 of the Recommended Decision, as follows:
"We accept the recommendation of the Commission Staff and the Consumer Advocate, and rej ect Met-Ed's claim of $27,068,000 unamortized expense balances for inclusion in its rate base."
Exception is also taken to the failure of the ALJ to find that Met-Ed's claims (set forth in Met-Ed's Exhibit B-152) for the unamortized balances of (1) rate case ex-penses in the amount of $283,000, (2) storm damage expenses in the amount of $755,000, (3) investments in Stony Creek and Berne generating station sites in the amount of $3,116,000 and (4) deferred energy costs in the amount of.*22,914,000 are reasonable end properly includibla
'n rate base.
In support of these exceptions, Met-Ed incor-I l
porates herein by reference pages 111-117 of its Brief, t
. Met-Ed's rate base claim for the unamortized balances of (1) rate case and storm damage expenses, (2) investments in Stony Creek and Berne generating station sites and (3) deferred energy costs (i.e.,
amounts deferred under former energy. clauses, including some amounts which have not as yet been recovered under the clausa in effect prior to July-1, 1978) is a reasciable claim which should have been allowed.
As pointed out in the above-referenced portion of the Brief, the past practices of this Commission in regard to these unamortized expense balances are particularly hard to understand in connection with deferred energy balances, where th,e Commission has afforded rate base treatment for deferred and unrecovered energy costs in one rate proceeding, but refused such treatment in the very next rate proceeding for deferred energy costs arising under the very same clause.
Furthermore, where circumetances are reversed (where the company has obtained refunds of expenses theretofore
- incurred, i.e.,
federal income tax refunds), the Commission's practice requires deduction from rate base of such unamorti. zed bale.nces.
In fact, such a deduction has been nr.de in the present proceeding.
The record in tige instant proceeding establishes beyond dcabt that such a claim does not involve an effort on l
the part of the Company to collect the same dollars twice, i
the result feared both by the Commission and the Commonwealth Court in recent decisions on this issue.
l l
I
. Since the foregoing expenses have not been col-1ected currently from customers, Met-Ed is entitled to a l
return on the investments tied up in such unamortized expense btlances.
The cost of carrying these investments has been significant with the interest rates at historic highs.
To deny such a return is arbitrary and unreasonable.
4.
Exception to Reduction of Cash Working Capital Requirement for Lag in Payment of Interest on Funded' Debt and Preferred Stock Dividends Exception is tcken to the recommendation of the ALJ at page 37 of the Recommended Decision, as follows:
"... we find that the accrued debt interest in the amount of $1,728,000, and the accrued preferred dividends at $209,000, for a total of $1,437,000 should be offset against Met-Ed's cash working capital requirement."
Exception is also taken to the failure of the ALJ to find that Met-Ed's cash working capital allowance should be the $7,581,000 amount (including TMI-1) and the $17,014,000 (excluding TMI-1) claimed in Met-Ed Exhibit B-152.
Met-Ed has addressed such unsupporaable reductions at pages 117-119 of its Brief, which are incorporated herein by reference.
Such reductions completely ignore the fact that Met-Ed's return (which will be included as a portion of its revenues) relates to a rate base in being at the end of the future test year (March 31, 1981) upon which the Company will not begin to collect revenues (and begin to recover such return) until April 27, 1981, ieyond the end of the future
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test year.
When and to whom Met-Ed pays dividends or interest is utterly irrelevant to the proposition that Met-Ed is entitled to treat as its own, upon receipt, the return which it earns on its previously provided rate base.
Such unsupportable reductions to working capital have been rejected by other regulatory commissions and until recently were rej ected by this Commission.
I 5.
Increased Accumulated Deferred Income Tax Deduction Exception is taken to the recommendation of the ALJ at page 39 of the Recommended Decision, as follows:
"Accordingly, we find that Mec-Ed's accumulated deferred income tax deduction from rate base j
should be increased by $155,000."
Exception-is also-taken to the failure of the ALJ to find that Met-Ed's deduction for accumulated deferred income taxes associated with liberalized depreciation should be the $61,766,000 amount (including TMI-1) claimed in Met-3d's Exhibit B-152.
The above $155,000 adjustment, which was advocated by the Consumer Advocate, really places in issue the appli-cability of the maximum rate base deduction defined in Section 1.16 7 (1)- 1(h ) ( 6 ) of the Internal Revenue Code as applied to a future test year under Pennsylvania's statutory scheme. Met-Ed maintains that it would be contrarv to good judgment to put such a significant tax benefit (i.e..
Its right to use liberalized depreciation) at risk for such a small adjustment.
Mot-Ed incorporates herein by reference page 120 of its Brief, which addresse, this issue.
)
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i 6.
Recommended Amortization Periode for Management Audit Expenses and Rate Case Expenses Exception is taken to the recommendations of the ALJ at pages 67 and 68 of the Recommended Decision, as-follows:
"We accept the recommendation of Commission-Staff, and reduce Met-Ed's claim on this account
[ management audit expense amortization) by
$156,000." (p. 67).
"We accept the recommendation of Commission Staff, and reduce Met-Ed's claim for rate case expense by $87,000." (p. 68).
Exception is also taken to the failure of the ALJ to find that Met-Ed's claims (set forth in Met-Ed Exhibit B-153) for (1) amortization over.two years of Theodore Barry &
Associates management audit expenses, amounting to $259,000 per year and (2) a three year amortization of rate case expenses, amounting to $216,000 for the test year ended March 31, 1981, are reasonable and appropriate.
In both cases, Met-Ed respectfully urges that its proposed amortization periods are reasonable an d e'.pp rop ri-ate, supported by valid considerations outlined in the testimony of Met-Ed's accounting witness at N.T.
2524-2526.
7.
Reduction to Storm Damage Expense Claim Exception is taken to the recommendation of the ALJ at page 68 of the Recommended Decision, as follows:
"We deny the allowance of such adjustment to Met-Ed's unamortized storm damage expense, and reduce test year expenses by $73,000."
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This recommended reduction removes the wrap-up storm damage expense claim presented by the Company for extraordinary' storm damages occurring during 1980.
Met-Ed respectfully submits that its storm damage claim is reason-able and fully supported by the testimony of Met-Ed's accounting witness at N.T.
2526.
8.
Cessation of TMI-2 Depreciation; Accumulation of Expenditures Exception is taken, insofar as the timing of cessation of depreciation on TMI-2 is concerned, to the recommendation I
of the ALJ at page 112 of the Recommended becision, as follows:
"1.
Transfer its net plant investment in TMI-l i
and TMI-2 to the ' plant held for future use' account, effective as of May 31, 1980, the date TMI-l was removed from jurisdictional base rate charges to customers, and to cease accruing depreciation on TMI-l and TMI-2 effective as of that date."
Exception is alsc taken, so far as timing is con-cerned, to the following recommendation at page 112:
"2.
Accumulate in a separate deferred account all capital expenditures incurred since March 31, 1979 and all non-capital expenditures incurred since May 31, 1980, the effective date of TMI-l l
removal from jurisdictional base rate charges to l
customers, in connection with modifications to TMI-l and TMI-2 which are both (i) necessary for the continued protection of the public's health and safety and/or to comply with NRC requirements and (ii) not associated with clean-up activities arising as result of the TMI-2 accident."
Met-Ed's investment in TMI-2 has never been recognized for rttemaking purposes, as a result of the
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1 Orders of the Commission on April 19, 1979 (at C-79040829).
and June 19, 1979 (at I-79040308).
Thus, January 1, 1979 is the appropriate date as of which to make TMI-2 depreciation 1
accounting changes effective.
Furthermore, any deferred accounting for TMI-2 expenditures should be made effective since March 31, 1979 (the approximate time of the accident).
May 31, 1980, the date on which TMI-1 costs were removed from base rates, is an appropriate date with respect to TMI-1, but it has no bearing with respect to TMI-2.
D e-
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9.
Residential Customer Charge Exception ~is takan to the finding by the ALJ (at 1
page 98 of the Recommended Decision)that Met-Ed's monthly l.
residential customer charge should be fixed at $5.00.
Such determination overlooks uncontroverted evidence that such an artifically low customer charge will impose unreason-able and unfair burdens on certain of Met-Ed's residential customers.
The ALJ adopts the Staff's position, the effects of which on various residential customers, as compared l
with Met-Ed's present rates, are summarized in Table 1 below:
0 Table 1 Metropolitan Edison Company Residential Restricted Rate AE - All Electric - Winter Monthly Present Met-Ed Trial Staff Base Increase Usage Base Rate (l)
Proposed Rate (2) Amount Percent (1)
(2)
(3)
(4)=(3-2)
(5)=(4+2) 0 kWh (Min.)
3.75 S
5.00
$ 1.25 33.3%
500 kWh 17.62 25.30 7.68 43.6 900 kWh 30.07 41.54 11.47 38.1 2500 kWh 78.39 106.50 28.11 35.9 i
5000 kWh 150.14 208.00 57.86 38.5 l
l l
[-
(1)
Me t-Ed Exh.
C-5, pg. 10 of 22, col. 2 (2)
Met-Ed Exh. C-43, pg. 5 o f 5, col. 5, N.T.
2348 l
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--e'.
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-. Table 2 sets forth, in identical fashion, Met-Ed's proposed rate and its effects:
Table 2 Metropolitan Edison Company Residential Restricted Rate AE - All Electric - Winter Monthly Present Met-Ed Met-Ed Base Increase Usage Base _ Rate (I)
Proposed Rate (I) Amount Percent (1)
(2)
(3)
(4)=(3-2)
(5)=(4+2) 0 kWh (Min.)
3.75 8.00
$ 4.25(2) 113.3%(2) 5 00 kWh 17.62 26.00 8.38 47.6 900 kWh 30.07 40.40 10.33 34.4 2500 kWh 78.39 98.00 19.61 25.0 5000 kWh 150.14 188.00 37.86 25.2 (1)
Met-Ed Exh.
C-5, pg. 10 of 22, col. 2 and col.
5~'
(2)
$2.25 (39%) over the $5.75 customer charge approved by the Commission in R-78060626 An analysis of Tables 1 and 2 shows that the ALJ/ Staff's proposal would impact the larger electric heat customers using 5000 kWh per month, in the cold months of l
December and January, by increasing the base rates $20.00 per month more than the Company's proposal.
For these customers, ALJ/ Staff's proposed base rate increase of 38.5%
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is 53% greater than the 25.2% increase preposed by the Company.
i
Met-Ed Exhibit C-43, page 4 of 3, shows that the ALJ/ Staff's proposal would increase the annual bill of the av e rag e total electric customer by $49.50 (or 6.5%) greater than the Company's proposed rate. Exhib i t C-43, page 5 of 5 also demonstrates that the ALJ/ Staff's proposal would further increase the base rate charged to large residential users (farms) consuming 10,000 kWh per month by an annual amount of $516 greater than the increase proposed by Met-Ed.
Me t-Ed believ es that undue attention has been focused upon the minimum charge.
The casual observer tends l
l to overlook the fact that there are few customers that fall into this low use category.
Me t-Ed Exhib it C-5 (column 13 on pages 2, 3,
6, 7,
9 and 10, r e spe c t iv ely) shows that less than 1% of the bills rendered to residential customers are for zero kWh usage.
As this Commission knows, these
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zero use situations are predominently vacant premises, l
i seasonal cottages, hunting camps, etc.
t As Met-Ed (at page 170 of its Brief) points out, and as the Commission is well aware, the larger use residen-tial customers (i.e. electric heating customers and farms) l l
have been subjected to significantly higher increases in 1
their electric bill than have other residential customers (Met-Ed Exhibit C-45).
Great care should be taken to insure
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. l that tnese customers are not further burdened by inappropri-ately designed rates that are not cost justified.
Met-Ed, in its' Brief at page 169, would also remind the Commission that it had approved a $5.75 customer charge in Met-Ed's last base rate case at R-78060626 (N.T.
2608).
Nothing has occurred since that case that could have reduced customer costs.
On the contrary, costs have risen due to inflation Me t-Ed has proposed a monthly customer charge of
$8.00. The Staff (the only other party offering a witness on the subj ec t) admits that Met-Ed's customer costs range from
$3.33 to $11.00 or $12.00 (N.T. 2382). The Office of Consumer Advocate has agreed with this conclusion (see OCA Main Brief, page 91).
An $8.00 customer charge is clearly supported by the evidence in this case.
However, if the ALJ/ Staff's concept of " gradualism" is applied and the full $8.00 requested charge is not allowed, equity among the various residential customers demands that (a) the customer charge be increased to something greater than the ALJ/ Staff recom-mended level and (b) a two block energy charge be established l
in order to recover the balance of the customer costs in the i
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i
. initial block.
Staff Witness Japak and Met-Ed Witness i
Carter both agree that this concept would be appropriate' (N.T. 2318-A; 2607-2610A).
Met-Ed's concept of " gradualism", which is synony-j mous with the ALJ/ Staff's, has been utilized throughout the past decade with respect to the customer charge.
The primary concern of Met-Ed is reflected in its Exhibit C-44 which shows the substantial mismatch between cost of service and the recovery of the appropriate costs through an e f f ec tiv e 4
rate design.
Met-Ed's Witness E.
F.
Carter pointed out that there was a substantial overrecovery of the cost of service from large users in all classes of residential 4
j service (especially water heating and electric space heating).
4 Specifically, there would be 112 percent overrecovery of l
costs from all-electric customers.
At the same time, the ALJ/ Staff's proposal would result in a substantial underrecovery 3
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(i.e.,
recovery of only 45% of the average customer cost) from the zero kWh convenience users of electricity (N.T.
2594-2595).
t j
Met-Ed has reflected both equity and " gradualism" in its design of the proposed cost-based rates so as to recognize the plight of the electric heating customers and other large users (farms) who have experienced substantially i
greater electricity cost increases than small users during the last decade.
b
. Therefore, Met-Ed requests that the Commission either (1) adopt the $8.00 customer charge proposed by Met-Ed, or-(2) adopt a customer charge greater than the
$5.75 level approved by the Commission in Docket R-7806-0626 and implement a two block energy charge of the form suggested by Witness Carter at N.T.
2607-2610A.
10.
Demand Provisions For Load In Excess Of 25 KW Me t-Ed takes exception to the ALJ's recommended decision at page 100 which would " direct Met-Ed to retain the residential demaud provision for loads in excess of 25 KW".
Met-Ed proposed a residential rate consistCug of a single energy block which recovers both the demand and energy cost components of esrvice.
Witness E.
F.
Carter stated that the load factoi relationship is constant over a wide range of usages based upon his analysis of substan-tial load research data (N.T. 2613).
No witness presented any evidence to the contrary.
n Because Met-Ed has nroposed to eliminate all residential declin1.ng block rates,in the absence of evidence to contradict the load research constant load factor relation-ship for small and large users, the Commission should permit Met-Ed to eliminate the demand provision in Rate RS.
1
. 11.
Non-Jurisdictional Goerations I
j Exception is taken to the ALJ's recommendation at t
i page 66 to impute revenues "to achieve equivalent rates of i
return for non-jurisdictional operations at the system average return requirement."
l Met-Ed presented evidence by Witness J. G. Graham which clearly identifies Met-Ed's wholesale customers as i
falling into two separate groups.
Group I consists solely of the Borough of Middletown; group 2 contains all other wholescle customers.
The second group of customers is presently paying rates which are providing a greater rate of return than that provided by Met-Ed's retail customers.
Me t-Ed's difficulties in achieving an adequate return from the Borough of Middletown are associated with a 1906 long-term agreement to sell power at a rate which is now well below the cost of service (Met-Ed Main Brief, pages 173-174).
Met-Ed represents that it has demonstrated that (1) the Borough of Middletown's contract represents a unique situation, (2) all other wholesale customers are paying adequate rates and (3) efforts to have the contract rate set
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l a sid e as unjast and anreasonable have been unsuccessful.
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l 21 Since Met-Ed has made a diligent effort to elimi-nate the inequity which currently exists 1. the Middletown f
contract, the Commission should reject the ALJ's recommenda-f tion and adopt the Met-Ed concept of sharing this inequit;r among all customers, both wholesale and retail.
Respectfully submitted, Samuel B.'hussell W.
Edwin Ogden Alan Michael Seltzer Frederick L.
Reigle Eric L.
B.
Strahn Ryan,. Russell & McConaghy 530 Penn Square Center P.
O.
Box 699 Reading, Pennsylvania 19603 James B.
Liberman Berlack, Israels & Liberman 26 Broadway March 30, 1981 New York, New York 10004
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