ML19329C349

Applicants' Statement on Estimated Transportation Costs to Deliver Respective Document Productions to Washington,Dc. Certificate of Svc Encl

ML19329C349
Person / Time
Site:	Davis Besse, Perry
Issue date:	01/29/1975
From:	Reynolds W CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TOLEDO EDISON CO.
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8002130714
Download: ML19329C349 (8)

Text

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January 29, 1975 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

THE TOLEDO EDISON COMPANY and )

THE CLEVELAND ELECTRIC ILLUMINATING )

COMPANY )

(Davis-Besse Nuclear Power Station, ) Docket Nos. 50-346A Unit 1) - -

) 50-440A

) 50-441A THE CLEVELAND ELECTRIC ILLUMINATING )

COMPANY, ET AL., )

(Perry Nuclear Power Plant, )

Units 1 and 2) ,

)

APPLICANTS' STATEMENT ON ESTIMATED TRANSPORTATION COSTS TO DELIVER TEEIR RESPECTIVE DOCUMENT PRODUCTIONS TO WASHINGTON, D. C.

1. At the conclusion of the Prehearing Conference held on January 3,1975, the Licensing Board requested all parties to submit cost estimates on transporting to Washington, D. C., relevant documentary material produced by Applicants at each of their home offices (Tr. 938). In making this

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estimate, Applicants were advised to assume that their entire document production (in response to the Department of Justice, the AEC Staff and the City of Cleveland) would be trans-ported.1/ The Board asked that the cost information reflect 1/ See letter to the Board frcm Applicants' counsel, dated January 2, 1975 *

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both a single transportation effort, where the material is moved in bulk and a segmented transportation effort, where 15 file drawers of documents are brought to Washington for one week and then returned 5

2. Applicants submit the following cost estimates in response to the Board's inquiry:

A. The Cleveland Electric Illuminating Company (117 file drawers)

(1) ,

Cost of Bulk Transfer (by truck)

Over-the-road trans-portation $1,251.60 County fees 180.00 Load and Unload fees (other than 1st floor) 144.00 Release valuation insurance 75.00 Packing charges, in-cluding container use 365.80

$2,016.40 (2) Cost of Segmented Transfer (by Air Freight)

Over-the-road trans-portation $2,358.00 Packing and loading charges 792.00

$3,150.00 9

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B. Duquesne Light Company (175 file drawers)

(1) Cost of Bulk Transfer (by truck)

Over- M.e-road trans-portation $ 700.00 Packing, unpacking and loading charges 2,770.00 Insurance 3,000.00

$6,470.00 (2) Cost of Segmented Transfer (by truck)

Over-the-road trans-portation $1,420.00 Packing, unpavking and loading chargos 2,960.00 Insurance 3,000.00

$7,380.00 C. Ohio Edison Company and Fannsylvania Power Company (201 file drawers)

(1) Cost of Bulk Transfer (by truck)

Over-the-road trans-portation $2,469 50 Packing, unpacking and loading charges 596.00

- Misc. Handling 922.00

$3,987 50 (2) Cost of Sessented Transfer (by REA)

Over-the-road trans-portation $5,914.00 Packing and loading charges 596.00 Misc. Handling 922.00

$7,432.00 i

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. ~4-D. The Toledo Edison Company (58 file drawers)

'(1) Cost of Bulk Transfer (by truck)

Over-the-road trans-portation (includes $100 insurance per package) $ 409.20 Packing and loading charges 919.80

$1,329 00 (2) Cost of Segmented Transfer (by Fed. Express Air Cargo)

Over-the-road trans-portation (includes $100 insurance per package) $2,493.83 Packing and .'cading charges 919.80 4 $3,413.68 3 Applicants add only that the above cost inform-ation requested by the Board may no longer be particularly relevant to the matter of document delivery. Applicants have been advised by the Department of Justice and the AEC Staff that the produced material which the Government. desires to inspect further has been substantially reduced as a result of the general file review undertaken by the Department and l the Staff in the past few weeks. Accordingly, the costs associated with a possible transfer to Washington of Applicants' e

document production in response to the government requests, as limited by -the Department and the Staff, would presumably be less than anticipated above. By contrast, the City of Cleveland has given no indication to Applicants of a similar reduction in the quantity of produced material it desires to inspect and/or copy.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By:(L\  % ^3 h h \ % ._ Q f _

Wm. Bradford\Reynoldsn Gerald Charnoff Counsel for Applicants Dated: January 29, 1975 B

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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In.the Matter of )

)

THE TOLEDO EDISON COMPANY and )

- THE CLEVELAND ELECTRIC ILLUMINATING )

COMPANY )

(Davis-Besse Nuclear Power Station, ) Docket Nos. 50-346A Unit 1) ) 50-440A

) 50-441A THE CLVELAND ELECTRIC ILLUMINATING )

COMPANY, ET AL., )

(Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby. certify that copies of the foregoing "Ap-plicants' Statement.On Estimated Transportation Costs To Deliver Their Respective Document Productions To Washington, D. C." were served on those persons listed on the attached Service List, by hand delivering a copy to each such person in the Washington, D. C. area and by mailing copies, postage prepaid, to the others, all on this 29th day of January, 1975 SHAW, PITTMAN, POTTS & TROWBRIDGE By:- A . dbk Wm. Bradford Reyn91ds t _ c4L_

Counsel for Applicants

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. UNITED STATES OF AMER. A

- NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licencing Board In the Matter of )

)

THE TOLEDO EDISON COMPANY and ) '

THE CLEVELAUD ELECTRIC ) -

ILLUMINATING COMPA!IY )

) .

(Davis-Besse Nuclear Power ,) Docket Nos. 50-346A Station, Unit 1) -

) 50-440A

-) 50-441A THE CLEVELAND ELECTRIC )

ILLUMINATING COMPAHY, ET AL. )

) -

(Perry Nuclear Power Plant, )

Units 1 and 2) ). .

SERVICE LIST ,

John B. Fs skides, Esq. Mr. Chase R. Stephens Chairman .

Docketing & Service Section Atomic Safety and Licensing Board U.S. Nuclear Regulatory Cc=missior U. S. Nuclear Regulatory Conmission 1717 H Street, N.W.

Washington, D. C. 20555 Washington, D. C. 20555 John H. Brebbia, Esq. Benj amin H. Vogler, Esq.

Atcmic Safety and. Licensing Board * ' Office of General Counscl

. Alston, Miller & Gaines Regulation 1776 K Street, N.W. , U.S. Nuclear Regulatory Commissior Washington, D. C. 20006 Washington, D. C. 20555 Douglas V. Rigler, Esq. Robert J. Verdi co, Esq.

Atomic Safety and Licensing Board' Office of Gener:.1 Counsel Foley, Lardner, Hollabaugh Regulation and Jacobs- U.S. Nuclear Regulatory Commission Schanin Building Washington, D. C. 20555 815 Connecticut Avenue, N.W.

Washington, D. C. 20006

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Roy P. Lessy, Jr.

Office of General Counscl Atomic Safety and Licensing Regulation t Board Pancl r

' U. S. Nuclear "egulatory Commission Washington,.D.12.

U.S. fup pCommission Nuclear Reeula*m5_

Washington, D. C. 20555 .

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Joseph J. Saunders, Esq. Leslic Henry, Esq.

Steven M. Charno, Esq. Fuller, Henry, HodGe & Snyder

. Antitruct Division 300 Madison Avenue Department of Justice Toledo, Ohio 136011 1

Washington., D. C. 20530 Thomas A. Kayuha, Esq.

Melvin G. Perger, Esq. Ohio Edison Company 47 North Main Street Antitrust Division Department of Justice Akron, Ohio 114308 Washington, D. C. 20530 '

Thomas J. Munsch, Esq.

Reuben Goldberg, Esq. General Attorney David C. Hjcimfc1t, Esq. -

Duquesne Light Company 1700 Pennsylvania Ave., N.W. 435 Sixth Avenue Washington, D. C. 20006 Pittsburgh, Pennsylvania 15219 Frank R. Clokey, Esq. David Olds, Esq.

• Special Assistant Reed, Smith, Shaw & McClay Attorney General Union Trust Building Room 219 Box 2009 Towne House Apartments Pittsburgh, Pennsylvania 15230 Harrisburg, Pennsylvania 17105 John Lansdale, Esq.

Mr. Raymond Eudukis Cox, Lansferd & Brown Director of Utilities 21 Dupont Circle, N.'d.

City of Cleveland Washington, D. C. 20C36 ,

1201 Lakeside Avenue Cleveland, Ohio 44114 W llace L. Duncan, Esq.

Jon T. Brown, Esq.

Herbert R. Whiting, Director Duncan, Brown a Palmer

. Robert D. Hart, Eaq. '1700 Pennsylvania Ave., H.U.

Department of Law Washington, D. C. 20006 1201 Lakeside Avenue Cleveland, Ohio 41!11'4 Dwight C. Pettay, Jr.

Assistant Attorney General John C. Engle, President Chief, Antitrust Section AMP-0, Inc. 30 East Broad Street, 15th Floor Municipal BuildinC Columbus, Ohio 43215 20 High Street <

Hamilton, Ohio 45012 Deborah Powell.Highsmith, Esq.

Assistant Attorney General Donald H. Hauser, Esq. Antitrust Section Managing Attorncy 30 East Broad Street, 15th Floor The Cleveland Electric Columbus,.0hio 113215 Illuminating Company 55 Public Square Christopher R. Schraff, Esq.

Cleveland, Ohio 14101 1 'Assi-tant Attorney General Env3.onmental Law Section

.361 East Broad Street, 8th Floor Co, lumbus, Ohio 43215 i

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