ML20079C846

Forwards Ofc of Consumer Advocate Addl Data Requests

ML20079C846
Person / Time
Site:	Seabrook
Issue date:	06/10/1991
From:	Holmes M NEW HAMPSHIRE, STATE OF
To:	Haffer E SHEEHAN, PHINNEY, BASS & GREEN, P.A.
References
NUDOCS 9106260198
Download: ML20079C846 (5)

Text

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• I THE STATE OF NEW HAMPSHIRE

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CONSUMER ADYOCATE

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$ ASSISTAh"f CONSU'1ER ADVOCATE MlCl{ AE L W. H0!Jh ES o ( JOSEPH W ROGERS d4 0FFICE OF THE CONSUMER ADVOCATE j 8 OLD SUNCOOK ROAD ,

CONCORD, NEW IIAMPS!!!RE 033015185 (h 7711172 10 June 1991 Edward A. Haffer, Esq.

[0-khD Sheehan Phinney Bass & Green, PA 1000 Elm Street P.O. Box 3701 Manchester, Nd 03105-3701 RE: NDFC 91-1

Dear Mr. Haffer:

Attached you will find the Office of the Consumer Advocate's additional data requests in the above styled docket. The attached discovery are directed at the following New Hampshire Yankee I witnesses:

1. Thomas S. LaGuardia (including cost study by TLG Engineering, Inc.)

2. Vincent P. Wright l

3. Judith C. Dunn Please contact me should you have any questions whatsoever concerning the interpretation of the attached.

Sincerely, 4

h l$ael W. ,olmes, Esq.

Enclosures CC: Service List 9106260198 910610 jl PDR ADOCK O'300044J p PDR

STATE OF NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION office of the Consumer Advocate Additional Data Requests T_he following data requests pertain to the testimony and cost study of Thomas S. LaGuardia and TLG Engineering, Inc.:

1. Please refer to page 9 @ 12-21 of Mr. LaGuardia's Direct Testimony. With specific reference to the statement:

" . . .there are efforts underway to develop multiple new regional facilities. Unfortunately, although cost projections for these new regional facilities are substantially higher than the fees being currently charged for low level waste disposal, the final pricing structure is still an unknown. In addition, the fees that will be charged by a f acility's operator will depend upon a number of site specific f actors, . . . As such, for a cost study,-the waste disposal cost is directly related to the assumptions used on the location and type of facility selected as the destination,

a. Please indicate:

1. who is'in charge, by region for the US, of e'fforts to develop multiple new regional facilities.

ii. what is the status of these efforts, 111. the documentation for Mr. LaGuardia's basis for this statement and iv. what Mr. LaGuardia believes are reasonable upper limits'on the " final pricing structure".

b. Please indicate where NH low-level waste is disposed of at present,

c. Please indicate if Mr. LaGuadia is aware of a model designed by EG&G Inc. for the DOE for the expressed purpose of forecasting low-level waste-costs.

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RE: NDFC 91-1 Additional Discovery Requests to New Hampshire Yankee

1. Please refer to page 10 @ 1-6 of Mr. LaGuardia's Direct Testimony. With specific reference to the statement:

"In an EPRI report, the principle investigator J.N.

Vance, calculated the value oi $139/ cubic foot as being a reasonable basis for projecting costs for the disposal of low level waste resulting from the decommissioning of Seabrook Station. This value is a f actor over four times higher than that used in the earlier estimate."

Please indicate how sensitive the J.N. Vance-study is to the development of future facilities. In addition, please indicate the forecasted volume of low-level waste emmitted

! from Seabrook Station for every year until 2036.

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l RE: NDFC 91-1 Additional Discovery Roquests to New Hampshire Yankee The following data requests pertain to the testimony of Vincent P. Wright:

1. Please refer to page 2 of Mr. Wright's testimony. Please provide the supporting docwnentation for the statement:

" Experienced engineers have suggested that waste disposal has escalated in very recent times by as much as three or four times the current inflation rate." Also please provide the support for the statement that " ...the situation stabilizes (at) a rate of 4.10% for the balance of the 46 years."

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. RE: NDFC 91-1 Additional Discovery Requests to New Hampshire Yankee The following data requests pertain to the testimony of Judith C. Dunn:

1. Please provide the status of Congressional legislation permitting NDT's to invest in taxable investments while remaining tax-exempt.

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