ML20038A733

Interrogatories & Requests for Production of Documents Re Issue 2.Certificate of Svc Encl.Related Correspondence

ML20038A733
Person / Time
Site:	Perry
Issue date:	11/03/1981
From:	Lodge T SUNFLOWER ALLIANCE
To:	CLEVELAND ELECTRIC ILLUMINATING CO.
References
NUDOCS 8111160240
Download: ML20038A733 (7)

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!__ _. --- _ __ ___ j UNITED STATES OF AMERICA 7 E7,.$. . . .,

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Nuclear Regulatory Commission Before the Atomic Safety and Licensing Boag gg _6 p2 35 OAAL,

.n In the Matter of: ) Docket Nds .^ 3 014%.0n7.'.% --

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CLEVELAND ELECTRIC ILLUMINATING ) , ,

COMPANY, et al. (Operating License) [ \' -

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(Perry Nuclear Power Plant Units 1 and 2) ) ,j

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INTERROGATORIESANDREQUESTSFORPRODUCTIONOFDOCUMENTS]' "6 ' ' l 1 ' ~

OF INTERVENOR SUNFL0k'ER ALLIANCE TO APPLICANT PERTINENT TO ISSUE #2 s

Now comes Intervenor Sunflower Alliance (" Alliance"), by and through counsel, pursuant to the Atomic Safety and Licensing Board's ("the Board")

Special Prehearing Conference Memorandum and Order Concerning Party Status, Contentions, and the Adoption of Special Discovery Procedures dated July 23, 1981 (" Conference Memorandum"), the Board's Memorandum and Order dated September 9, 1981, and sections 10 CFR 2.740b and 10 CFR 2.741. The Alliance directs the following interrogatories and requests for production of documents to Cleveland Electric Illuminating Company, et.al. (" Applicant")

pertinent to Issae #2 enumerated by the Board in its Conference Memorandum, the so-called " financial capability" issue, only. Both interrogatories and requests for production are intended to be continuing in nature and are to be immediately supplemented or amended, as applicable, should Applicant obtain any new or differing information.

As used herein, the term " document (s)" shall mean all writings and l

l records of every type in the possession, control or custc dy of the Applicant or cf Appliant's attorneys, including, but without limitation because of p spec 14ication, letters, reports, surveys, tables, books, charts, voice 3 or tape recordings, diagrams, transcripts, photographs, correspondence, /p mps, minutes, notes, pamphlets, articles and all other writings, references t

8111160240 811103 PDR ADOCK 05000440 C PDR

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or recordings of any kind, whether or not in the possession, control or custody of Applicant.

Where identification of a document is requested, briefly delineate it by type, and give identifying characteristics, viz., name, title, author, number, date of publication, publisher, addressee, date of approval or drafting, and names and addresses of persons having possession thereof.

INTERROGATORIES AND REQUESTS

1. Identify the amount and source of Applicant's funds for the construction of the Perry units from 1970 to present. By " source" is meant: ratepayers (specify class), stock issuances, bond issuances, and other means of capitalization known to Applicant.

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2. Identify all relevant documents in your possession, custody, or control, and relevant page citations, pertaining to the subject matter of Question 1.

3. State the name, address, employer, title, and professional and educational qualifications of any person known to Applicant who could previde detailed information in response to Question 1. State the substance and/or relevance of each person's knowledge of the matters covered by Question 1.

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4. Identify the projected amount and source of Applicant's funds for f l the construction of the Perry units from November, 1981 through the I

j presently projected completion dates of Unit 1 and Unit 2, respectively.  !

l, See " source" definition in Question 1.  !

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5. Identify all relevant documents in your possession, custody, or  ;

,e control, and relevant page citations, which are responsive to Question 4 [

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l 6. State the name, address, employer, title and professional and i

educational qualifications of any person known to Applicant who could  !

l provide detailed information in response to Question 4. State the substance l

anc/or relevance of each person's knowledge of the matters covered by I

Question 4.

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7. State the projected percentages and amounts of funds expected r

, to be generated by Applicant's rate increases by class from November, 1981 through the projected decommissioning dates of Unit 1 and Unit 2, I

respectively. L l

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6. State the name, address, employer, title and professional and educational qualifications of any person known to Applicant who could provide detailed information in response to Question 7. State the substance and/or relevance of each person's knowledge of the matters covered by Question 7.

9. Identify all relevant documents in your possession, custody, or control, and relevant page citations, which are responsive to Question 7.

10. Give a detailed breakdown of the original projected total costs of completion of each of the Perry units.

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11. Give a detailed breakdown, by unit, of the pr>jected total costs of cocpletion of each of the Perry units as of Novembei.1981.

12. State in detail the presently anticipated decommissioning, dismantling, associated transportation costs and any and all other costs of shutdown of the Perry units, by unit.

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13. Identify the source and amount of the funds needed to accomplish the tasks named in Question '2.

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) 14. State in detail the projected costs of all phases of operation 1

of each of the Perry units for the first ten (10) years of operation of each unit, respectively.

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15. Identify and itemize the projected nature and costs of repairs;

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retrofits; technical modifications; operator and procedural changes; and l ' ,=-

changes in equipment, personnel and/or systems which would be necessitated f by regulatory requirements, in the first ten (10) years of operability of s .

each unit, respectively.

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16. Stcte the projectec inflationary rate in the censuner prire index for the same years for which rate increases were projected in respense te Question 7.

17. State the projected dates, anticipated percentage rates, size, purpose, and nature of any and all stock and bond issuances, sales, aplits, trades or other transactions which Applicant expects to occur between November, 1981, and the expected commencement of decommissioning of each Perry unit.

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TERRYy.fATHANLODGE Co-cou.4el for Sunflower ylliance 915 Spftzer Building Tole d(1,,j 0H 43604 CERTIFICATION I hereby certify that a copy of the foregcing " Interrogatories and i

Requests for Production of Documents of Intervenor Sunflower Alliance to Applicant Pertinent to Issue !!2" were sent by te via regular U.S. Mail, pestage prepaid, to all parties on the attached Service List this 3rd day of November, 1981.

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SERVICE LIST - - -

Peter B. Bloch, Cnairman Dr. Jerry R. Klein Atomic Safety & Licensing Board Atomic Safety & Licensing Board Nuclear Regu2atory Commission Nuclear Regulatory Commission Washington, D.C. 20555 .

Washington, D.C.' 20555 Frederick .:. Shon Jay S11 berg, Esq.

Atomic Safety & Licensing Board 1600 M Street N.W.

Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555 Donald T. Encone, Esq. Daniel J. Herron, Esq.

Assistant Prosecuting Attorney Assistant Prosecuting Attorney 105 Main Street Ashtabula County Courthouse

• Painesville, Ohio 44077 Jefferson, Ohio 44047 Tod J. Kenney Jeff Alexander 228 Soouth College St. Apt. A 920 Wilmington Ave.

Bowling Green, Ohio 43402 Dayton, Ohio 45h20 Robert Alexander 2030 Portsmouth St. Apt. 2 Houston, Texas 77098 Atomic Safety & Licensing Appeal Board Docketing & Service Section Nuclear Eegulatory Commis_sion Office of the Secretary Washington , D. C . 20555 Nuclear Regulatory Commission Washington, D.C. 20555 Charles Earth, Esq. Dan Wilt, Esq.

Nuclear Regulatory Commission 7301 Chippewa Road

-Washington, D.C. 20555 Brecksville, on /,4141

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