ML20204B779
| ML20204B779 | |
| Person / Time | |
|---|---|
| Site: | Green County  |
| Issue date: | 09/08/1978 |
| From: | Harding V NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20204B767 | List: |
| References | |
| NUDOCS 7811020333 | |
| Download: ML20204B779 (7) | |
Text
ATTACliilENT 2 09/22/78 U!11TED STATES OF AMERICA flVCLEAR REGULATORY COMMISSIOil
~ BEFORE THE _AT0QC_Sfd ETY AllD lICEllSING BOARD In the Matter of POWER AUlHORITY OF TiiE STATE OF
!!EU YORK Docket tio. 50-649 (Greene County liuclear Power Plant) x x r. x STATE OF llEW YORK DEPARTMEllT OF PUBLIC SERVICE BOARD ON ELECTRIC GLl1 ERAT 10fl SITillG AllD THE ENVIRO liMEl;T In the Matter of the Application of the POWER Aulil0RITY OF THE STATE OF
)
HEW YORK
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Case 80006 (Greene County fluclear Generating f acil 'i ty)
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11RC STAFF INTERROGATORIES T0, AllD REQUEST FOR PRODUCTION OF DOCUMENTS FRON, LElllCll PORTLfilD CEMEl!T COMP _ANY Pursuant to 10 CFR 02.741 of the Corumission's Rules of Practice, the NRC Staff hereby requests that 'Lehigh Portland Cement Company (LPCC) answer separately and fully in writing and under oath the interrogatories set forth below.
Pursuant to the rulings of the Joint Boards in this proceeding, responses to these interrogatories should lie signed by the person (s) who prepared them and footnoted to the sources upon which they are based.
The interrogatories attached are to be considered LPCC's continuing obligation.
Accordingly, if, after LPCC has answered these interregatories, 78F1030333 i
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2 additional-information comes to its attention with respect to any of the answers, the answers should be' amended to provide such additional infor-mation.
The llRC further requests that LPCC, pursuant to 10 CFR f;2.741, provide copies of, or make available for Staff inspection and copying, any docu-ments not previously provided to the Staff which are designated by LPCC in response to the accompanying interrogatories.
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1.
liarket and Sales lil.
what is Lehigh's approximate share of the Northeast ceraent market for each of the last three years?
I42.
What percentage of Lehigh's national cement sales does its Northeast sales comprise for.cach of the last three years?
14 3.
What percentage of Lehigh's national cement earnings does its Northeast earnings comprise for each of the past three years?
14 4.
What.- relationchip doco Lehigh's Northeast marhet performance have to Lehigh's overall market viability?
II.
Considerations of the Lehich Board of Directors Ll.
IIns the Lehigh board of directors given any consideration either in formal or informal proceedings to the loss of its facilities et Cementon as a result of the construction of the Greene County Nuclear Plant (GCNP) at the Cementon site?
L2.
In the event that the GCNP is built on Lehigh property at Cementon, has the Lehigh board of directors determined either formally or informally that. Its production facilities at Cementon must be closed permanently?
L3.
In the event that the GCNP is built on the Lehigh property, and that such a development canses t.he closing of the facility, has the Lehigh board of directors given consideration either formally or informally to what alterna-tives the company should take in response to this closing of its facilities?
L4.
In the event of such a loss of the Cementon 1;acilities, has the Lehigh board of directors either formally or infornally determined that it is not feasible to construct an entirely new facility at a virgin or "greenficid". sit.c?
L5.
11au the Lehigh board of directors initiated or caused to be initiated in any way a ocarch for a virgin or "greenficJd" site?
If so, in what governmental jurisdiction is the site located?
L6.
In the event of a loss of the Cementon facilities, has the Lehigh board of directors either formally or informal 3y discussed the feasibility of pur-i chasing the existing (operating or non-operating) facilities of another cement. manufacturer?
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'If such discussions have occurred, what candidates for such purchase have
,been identified, and where are they located?
L8.
In' the event of a loss of the Cementon facilit. des, has t ac IIchigh board of z
directors either formally or,informa]Iy discussed the feasJbl31ty of pur-l chauing the adjoining proper ties of the Alpha and/or Marquette companics?
L9.
In the event of such discussions, has the Lehigh board initiated or caused to be initiated any analysis of the feasibility of a purchase of either the cdjoining Alpha or Marquette properties?
L10, lias the Lehigh board of directors initiated or caused to be initiated any direct or indirect, formal or informal contacts with Alpha or Marquette off f cf als regarding a potential Lehigh purchase of either of the conipanies' adjoining propertics?
Lil. In the event of the above described loss of Lehigh's production facilities at Cementon, has the Lehigh board of directors formally or informal?y determined that a purchase of the adjoining properties of Alpha and/or Marquette is not feasible? On what basis was such infcasibility estahH shed for each company's property?
III.
_ Considerations of the Heidelberg flanagement Board f
. Ill, llas the lleidelberg management board given any consideration either in formal or informal proceedings to the loss of its facilities at Cementon as a result of the construction of the Creene County Nuclear Plant (CCNP) at the Cementon nite?
H2. In the event that the CCNP in built on Lehigh property at Cementon, has the lleidelberg management board determined either formally or informally t. hat its production facilities at Cenenton must be closed permanently?
113. In t.he event that the CCNP is built on the Lehigh property, and that such a development causes the closing of the f acility, has the lief delberg management board given consideration either formally or informally to what alternatives the company should take in response to this closing of its facilities?
H4. In the event of such a loss of tlhe Cementon facilities, has the Heidelherg management board either formally or informally determined that it is not feasibic to construct an entirely new f acility at a virgin or "greenfield" site?
115. lias the !!cidelberg management board initiated or caused to be initiated in any way a search for a virgin or "greenfield" sit e? If so, in what govern-mental jurlsdiction la the site located?
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3 H6. In the event of a loss
. Cementon facilities, has t12 Heidelberg manare-ment board either fc or informally discussed the f easibility of pur-chasing the existinr,
- ating or non-operating) facilities of another cement. manufacturer?
117. If such discussions have occurred, what candidates for such purchase have been identified, and where are they Jocated?
118. It. che event of a loss of the Cementon facilities, has the Heidelberg manage-ment board either formally or informally discussed the feasibility of pur-chasing the adjoining properties of the Alpha and/or Marquette companics?
[19. In the event of such discussions, has the Heidelberg board initiated or caused to be initinted any analysis of the feasibility of a purchase of either the adjoining Alpha or Marquett e properties?
1110. Has the Ucidelberg management board initiated or caused to be initiated any direct or indirect, formal or inf ormal contacts with Alpha or Marquette officials regarding a potential Lehigh purchase of either of the companica' adjoining propertics?
!!11. In the event of the above described loss of Lehigh's production facilities at Cementon, has the lleidelberg management board formally or informal]y determined that a purchaue of the adjoining properties of Alpha and/or Marquette is not feasible? On uhat basis was such infeasibility established for each company'n property?
IV.
Considerations of Other Groups 01.11as any Lehigh or licidelberg vorking group given any consideration either in formal or informal proceedings to the loss of the facilities at Cementon as a result. of the ccustruction of the Greene County Nuclear Plant- (GCNP) nt the Cecenton site?
- 02. in the. event that the GCNP is built on Lehigh property at Cementon, has any Lehigh or Heidelberg working group det ernined either formally or informally that the production facilitien at Comenton must he closed permanently?
- 03. In the event that the cCNP is built on the Lehigh property, and that such a development causes the c16 sing of the facility, has any Lehigh or Heidelberg vorking group given consideration either formally or informally to what alternatives the company should take in response to this closing of its facilities?
- 04. In the event of such a loss of the Cementon facilities, has any Lehigh or Heidelberg working group cither formally or informally determined that i t is not feasibic to construct an entirely neu facility at a virgin or "greenfield" r:ite?
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'05. Itas any Lehigh or Heidelberg working group initiated or canned to be initiated j
fn any way a nearch for a virgin or "greenfie]d" cite?
If so, in what govern-uental jurir. diction is the site 3ccated?
- 06. In the event of a Ions of the ceacnton facilities, has any Lehigh or Heidel-berg workian group either formally or informally discussed the fencibility i
of purchasing the exist.ing (operating or non-operating) f acilities of another cement manufacturer?
- 07. J f such discuusions have occurred, what candidates for nuch purchase have been ident.lfied, and where ore they located?
- 08. In the event of a lasc of the cementon facilities, has any Lehigh or'Heidelberg l
working group cither formally or informally discussed the feasibility of purchasinh the adjoining properties of t;he Alpha and/or Marquette companies?
- 09. I' the event of cuch discusnionni has any Lehigh or naidelberg working group initiated or caused to be initiated any analysis of the feasibilit.y of a pur-chase of either the adjoining Alpha or Marquette properties?
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010. Han any Lehigh or ucidelberg working group init.inted or caused to be initiated any direct or indirect, formal or informal contacts with Alpha or Marquette of ficialn regarding a potential Lehigh purchase of either of the companies' adjoining propertics?
011. In the event of the above dencribed loss of Lehigh's production facilities at cementon, has any Lehigh or Heidelberg working group formally or informally determined that a purchase of the adjoining properties of Alpha and/or Marquette is not feasible? On what bas:Is was such infeasibility established for each company's propert.y?
V.
Documentation Dl.
Submit any documentation which provides a basis for the answers given to the interrogatories listed above.
Respectfully submitted, lllCl:i$! NoAaN' M Vicki R. Harding i
Counsel for NRC Staff r Dated at Bethesda, liaryland this 22nd of September, 1978 i
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