ML19250B789

Statement of Objectives by PA Public Util Commission,Per Aslb 790921 Order Re Subj Matters for Participation. Discusses Operational,Managerial & Financial Limitation Matters Which Should Be Developed.Certificate of Svc Encl

ML19250B789
Person / Time
Site:	Three Mile Island
Issue date:	10/22/1979
From:	Levin J PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7911050238
Download: ML19250B789 (9)

Text

gMC DUCWM '

UNITED STATES OF AMERICA / lI D NUCLEAR REGULATORY COMMISSION 4 S

N.'j- .c?

-

'c*** \T ATOMIC SAFETY AND LICENSING BOARD ff-gC ggyp" OC12 Ivan W. Smith, Chairman Dr. Walter H. Jordan *

• M%g /h/7 a*

,

Dr. Linda W. Little *

/

.

. In the Matter of: )

)

Metropclitan Edison Company )

) Decket No. 50-289 (Three Mile Island Nuclear )

Station, Unit No. 1) )

STATEMENT OF THE PENNSYLVANIA PUBLIC UTILITY COMMISSION The PENNSYLVANIA PUBLIC UTILITY COMMISSION ("Public Utility Commission") hereby states, pursuant to the order of the Atomic Safety and Licensing Scard (" Board") dated September 21, 1979 setting the special prehearing conference, D

-

the subject matters on which it desires to participate, and

, alerts the Board and the parties to matters which should be developed on the record, as follows:

The Order and Notice of Hearing of the Nuclear Regulatory Commission ("NRC " ) dated August 9, 1979 and the unique circumstances of this proceeding require that the Board go beyond the technical and engineering requirements 1270 '>02 7 911050 d 3 @

b

_ _ _ . _. ___

-

.

of safe operation of TMI-l to develop a record on and fully consider the operational, managerial and financial ability of the licensee to meet the requirements to be set by the NRC. The existing obligations of Metropolitan Edison Company as licensee of TMI-1, and of TMI-2, are definite, relevant limitations of the resources of the licensee. In addition,

.

Metropolitan Edison company is a public utility subject to

• the jurisdiction of the Public Utility Commission and is required to provide safe, adequate, and reliable slectric public utility service at just and reasonable rates. The licensee's concurrent Pennsylvania statutory obligation to provide safe, adeqr. ate and reliable public utility service at just and reasonable rates is a definite, relevant limitation on the resources of the licensee available to fulfill the requirements to be set by the NRC.

The Public Utility Ccmmission desires to participate in these proceedings to develop an adequate record on and urge full consideration of the operational, managerial, and financial li=.tations of the licensee in meeting the

- requirements to be set by the NRC, and in particular the obligations imposed by State law on the licensee as a public utility. The Public Utility Commission's parti-cipation will be directed toward the following subject matters: ,

A. With respect to actions required to maintain TMI-l in a safe and stable shutdown condition:

(1) the costs associated with those actions, (2) the tining of such costs, 1270 ',03

.

-. -

.

(3) the effect of those actions on the licensee's operation and maintenance of its generation, transmission and distribution facilities, (4) the sources of funds required to finance those actions, and

.

(5) the amounts and timing of rate relief

.

requests necessary in order to finance those actions.

B. With respect to actions required to permanently shutdown TMI-1:

(1) the costs associated with those actions, (2) the timing of such costs, (3) the effect of those actions on the licensee's operation and maintenance of its generation, transmission and distribution facilities, (4) the sources of funds required to finance those actions, and

-

(3) the mmounts and timing of rate relief

,

requests necessary in order to finance those actions.

C. With respect to actions required to convert TMI-l to a non-nuclear generating facility:

(1). the costs associated with those actions, (2) the timing of such costs, 1270 104

-- . . . - -

- .- ..

. - .

.

(3) the effect of those actions on the licensee's operation and maintenance of its generation, transmission and distribution facilities, (4) the sources of funds required to finance those actions, and (5) the amounts and timing of rate relief requests nocessary in order to finance those actions.

D. With respect to actions required to start up TMI-1:

(1) the costs associated with those actions, (2) the timing of such costs, (3) the effect of those actions on the licensee's operation and main?.enance of its generation, transmission and distribution facilities, (4) the sources of funds required to finance those actions, and

,

(5) the amounts and timing or rate relief requests necessary in order to finance those actions.

E. With respect to actions required to operate TMI-l after start up:

(1) the costs associated with those actions, (2) the timing of such costs ,

%

\qL ]i i'tJ '\ ) )

~

._ _

.

(3) the effect of those actions on the licensee's operation and maintenance of its generation, transmission and distribution facilities, (4) the sources of funds required to finance those actions, and (5) the amounts and timing of rate relief requests necessary in order to finance those actions.

Because of its status as a smasi-judicial adminis-trative bcdy, the Public Utility Carmission may be required to hear and decide contested issues with respect to the public utility service, facilities and rates of Metropolitan Edison Company. In the interests of affording all potential litigants before it adequate opportunity to present arguments and defenses, and to preserve the due process of law, the Public Utility Commission cannot decide issues not presently before it. For that reason, the Public Utility Ccmmission reserves the right to decline to argue or take a position on specific issues raised in this proceeding to the extent that such actions may be

-

1270 '06

_3_

_

_

. - - .

.

inconsistent with its responsibilities to hear and decide matters within its jurisdiction.

Respectfully submitted, Pennsylvania Public Utility Commission b its attorneys:

,

LU (jd 'u'_ {W

/ John A. Levin

( Assistant Counsel Steven A. McClaren Deputy Chief Counsel George M. Kashi Chief Counsel DATE: C, dbV h P.O. Box 3265 Harrisburg, PA 17120 (717) 783-2804 3 , y n ,I U ln7 I .I J

.

__

.

.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

'

)

METROPCLITAN EDISON CCMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

-

. Station, Unit No. 1) )

L .2crl:1CATE OF SERVICE I hereby certify that I have caused to be forwarded the attached " Statement of the Pennsylvania Public Utility Commission" upon those persons as shown by the following Service List by deposit in the United States mail, postage prepaid, this 22nd day of October, 1979.

M (Jghn A. .T.evin

' Assistant Counsel

. Pennsylvania Public Utility Commissicn

~

A-(yC" @'d>s.

ye .,

,- c.. c4 : v l- .c s -

• 21 OGT#'57Q_eg .d2 yk c.s e:'O' x?

a." sf e4

is.w.s' 1270 ;08

_ ..

~

.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

. M POLITAN EDISON COMPANY ) Docket No. 50-289

)

(Three Mile Island Nuclear )

Station, Unit No.1) )

.

'

SERVICE LIST Ivan W. Smith, Esquire Marcia Mulkey, Esquire Chairman Office of Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Cor=21ssion Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Cot: mission Ms. Marjorie M. Aamcdt Washington, D.C. 20555 R. D. #5 Coatesv111e, PennsylvaMa 19320 Dr. Walter H. Jordan Atomic Safety and Licensing Ms. Holly C. Peck, Leg. Chairman Board Panel Anti-Nuc' ear Greup Representing 881 West Outer Drive York (ANGRY)

Oak Ridge, Tennessee 37830 245 W. "hiladelphia Street

• Yor', Pennsylvania . N04 3r. Linda W. Little Atomic Safety and Licensing h.s. Frieda 3erryh111, Chairman Board Panel raalition for Nuclear Pcwer 5000 Hermitage Drive ?lant Postponement Raleigh, North Carolina 27612 2610 Grendon Drive Wilmington, Delaware 19808 James A. Tourte11otte, Esquire Office of the Executive Legal Mr. Robert Q. Pollard Director Chesapeake Energy Alliance U.S. Nuclear Regulatory Commission 609 Montepelier Street 3altimore, Maryland 21218

,

Washington, D.C. 20555

.

Docketing and Service Section Karin W. Carter, Esquire Office of the Secretary Assistant Attorney General U.S. Nuclear Regulatory Commission 505 Executive Ecuse Washington, D.C. 20555 P.O. Box 2357

,

Harrisburg, Pennsylvania 17120 George ?. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge Walter W. Cohen, Esquire 1300 M Street, N.W. Consu=er Advocate Washingten, D.C. 20006 Department of Justice Por: Licensee Strawberry Square, 14th Floor Harrisburg, Pennsylvania 17127 12/0 700

-

_

.

,

Dr. Chauncey Kepford Karin P. Sheldon, Esquire Environnental Coalition on Nuclear Sheldon, Har=on, Rois=an & Weiss Power 1725 I Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 16801 For: PANE Robert L. Knupp, Esquire Mr. Steven C. Shelly Assistant Solicitor 304 South Market Street

. County of Dauphin Mechanicsburg, Pennsylvania 17055

.. P.O. Box P, 407 N. Front Street

,

Harrisburg, Pennsylvania 17108 Theodore A. Adler Widoff, Reager, Selkowitz & ^_dler Mr. Marvin I. Lewis 3552 Old Gettysburg Road 6504 Bradford Terrace Camp Hill, PA 17011 Philadelphia, PA 19149 For: Three Mile Island Alert, Inc.

Jordan D. Cunningham, Esquire Ellyn P. Weiss, Esquire Fox, Farr & Cunningham Sheldon, Har=on, Roiseman & Weiss 2320 North Second Street 1725 I Street, N.W., Suite 506 Harrisburg, Pennsylvania 17110 Washington, D.C. 20006 For: Newberry Twp. TMI Steering For: Union of Concerned Scientists Committee A

.

.

127 'i0