ML20062J618
| ML20062J618 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/21/1980 |
| From: | NEW JERSEY, STATE OF |
| To: | |
| Shared Package | |
| ML20062J617 | List: |
| References | |
| NUDOCS 8011030635 | |
| Download: ML20062J618 (140) | |
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\O us2 1 VOLU:G 16 O NEW JS332Y DCPART!'I::" OF E:12MGY 2 DOARD OF PUT.LIC UTILITIES 3 3E'<rAa.e., :friI JunS2r TUEGDAY, OCT032n 21, 1990 4
5 In the Mntter of the Petition of a Jor. soy Contral Power and Light : OAL D0CKET NO.
6 Company for Approvs1 of an Increase PUC 3518-00 in lutas for til2ctrical Service and :
7 for headmsnt to the Lev,alized SnorrJy : 3PU DOC'.<DT Mo.
Acjustnont Clause and Facter for such : 304-295 8 serrice. : 007-408 9
CEFORC: 30:1. ST!dP:IE;i G. PAPJH!ALL 10 3
AD:tI!!ISTRATIVO LM JUOGO 11 i
- 12 j A P P G A R A Il C U St O -
13
- f. Fcr tho ,?otitioner, Jersey Central Power
- la and Light Co
- :.pany, apear-
$ 15 KIRST2:J , F a1 3 0!!A:: 5 CHORI11, 2000. ,
i DYa JAC.< 3. KIPJJTE!!, ESQ., and E 16 DOLORES DSLADAa, !?S2.,
17 Academy Strcot 17 :lewark,: Tow Jersey 18 and 19 '7ILLI.L'1 ? . !!YLVID, 300., Of Ccuncel J.t*C3 D. LI3CP2tMI, E32., Of Counsel 20 21 22 J. !!. SUEliR2R G A:iSOCIATE3 24 Commsrce Gtreet 23 IIewark, New Jaraey (201) G23-1974 24 0 25 5
801a oso 6 35-
i (5
1753 1
A P P E AR A N C 3 S (Continued)
O For the Department of Public Advocate, D M aion of .M e Q m el, appara:
3 AL7ED L. H.UDELLI, 3SQ.,
Deputy Director
' 5 10 Co:merce Court Newark, New Jersey 6
For the Doard of Public Utilities Staff, 7
appears ,
8 I. PAUL SLEVIN, Supervising Rats Analyst 9
and cabLA VIvIri 3ELI.0, 250 ,
i Deputy Attorney General 33 i
12 i
( 13 ,
- 14 5 15 3
5 16 i
17 18 19 20 21 22 23 24 O' 25 l
l _.
[
1754 l
l 3 JUDGE M.uSHALL: Ccod morning, centle=en.
(] 2 This is a continued hearing in the matter of 3 the Petition of Jersey Csatral Power and Light 4
Company for an increase in rates, O?.L Doc % t 5 liumber PUC-3513-80, with Stephen Marshall 6 presiding as Administrative Law Judge.
7 I believe, Mr. T.iraten, you viah to g present your witness, Mr. Paber, today.
9 Mn. XIn3 TEN: Yes. Mr. Rabar, I do not 10 bslieve, was previously sworn in this precaed-11 #9*
i 12 MARVIN R A 3 3 2, mforn en behalf of Petitionor, 8
' testifica as fo11cvst
{ 3,3 DIRECT EXXt! NATION i
- Di un. Y.13STCNs
- 15 j 16 O Mr. M er, will you please tell un the position 37 that you hold with the GPU system?
gg i A I am Manager of Forecasting and Supply Planning 39 with GPU service corporation.
20 21 I
o e.
21 h G 0 O ! '
25 j I
t
8 Rab r-dirset 1755.
1 Q Mr. Raber, did you prepare a docuzent entitled
() 2 " Testimony of Mas sin Raber, ?otential Conversion of TMI-2 3 and Forked River Nucicar Facilitica and Coal-fired Plants"?
4 A Yes, I did.
5 MR K1RSTEN: May we have that marked?
6 It has been pre-filed,-sir. May we have that 7 marked Exhibit JC-5007 8 JUlX)E IIESPALL: It shall bc =arhed 9
JC-500.
10 (Prepared testtrony of Harvin Rober, i II j referred to above by lir. Kirsten, is received 12 g for identification and =arhed Erhibit JC-500.)
I3 km. KlRSTE3: Uc will provide copica
{-} { 14
[ for tbc reporter.
t j 15 Q Did you also, in support of that testincny, r 16 Mr. Raber, prepare a nu:1ber of exhibits slaich had been 17 numbered for identification purposes as JC-501 through 18 JC-503, inclusive?
19 A Yes, I did.
20 Q Was JC-501 through JC-503 prepared by you or 21 under your direction?
A Substantially, yes.
23 There arc ~ certain notabic enceptions, hose.ver, 24 s including the estinatos of cicaning up Tt11-2 and restorin3 ;
Os 25 . I it to service and the study of anthracite fuci prospects
Rabar-direct 1756.
I I for converting Thl-2.
(]) 2 These studies vere not done under my directicti 3 but I have adopted the resulta of tusse studiae for the ex-4 hibits that I'm sponsoring. !
5 Q Do you have any correctd ons -- strike that.
9 6 If you were asked the c,uestienc, would you 7 give the responses today that cre set forth in JC-500 marked l 8 your testimony?
9 A Yes, I would.
10 Q Do you have any cor:cccions or additions which
$ 11 you would want to make to that testL:cny todayl i
. 12 A Yes, I do.
j 13 Q Will you please cell us what the corrections C) "
- 14 are?
$ 15 A On Page 6 of JC-500, the last word shown oa i
i 16 that page is "our." The following words shculd be incerted 17 in the line below the last line chcun on that page: Present 18 intent is to defer a final decision to," and then the son-19 tence con:inues correctly en the fo11cwing page.
- 20 JUDGE 1%RSIL\LL: Verhapa ycu should do 21 it one more time.
22 THE WITIESS: Let me read the entire l
23 sentence.
24 JUEGE FMRCllALL: All right.
() 25 Tun WITN235: The sentence should read, r
Raber-dir:ct 1757.
y "Our present intent is to defer a final A
(-) 2 decisios to restore or repisce IM1-2 until thc 3 fuel in removed, now cargeted for 1903."
4 JUDGE E\RSIMLL: Does anybody want a 5 repetition of that?
6 (No response.)
7 JUDGE 11ARSIBLL: Okay, thank you.
8 Q Just to nake aure everybody has it cicar, it's 9 just one more line which has been added to the bottom of to Page 6 which reads, "Present intent is to defer a final
$ 11 decinion to." '
12 Are there any other corrections?
i A
{') 13 Yes. On Page 11, Ices B, under 5, the nu=ber j 14 should be 1,150 million rather than the 1,100 million that's
- 15 typed in there. ,
r 16 17 18 19 20 -
21 22 23
() 25 1
1 i
Raber-direct 1758 1 A (Continuing) On page 27 under the fcurth 2
lina up from the bottom, the word should be "appropriete" 3 with two Ps, and on page 28 in the middle of the fifth line --
4 Q Will you go s little slower, Mr. Faber?
5 M2. MARDELLIs Yes, ticuld you repeat 6
the "appropriata" One, pleas,s ?
7 i T3E WITNESS: That's en page 27, "curth '
8 line up from the botten.
9 Pege 20, in the niddlo of the fifth 10 line down from ths top, delets the word "desa".
i i
2 11 Tnoso are all the corrschions I have i
. 12l: as to JC-500.
- I l
()
1
- 13 Q ticw, as far as ths o=hibits arn concerned which a .
l 14 l Ve have just marked, !!r. Rabor, JC-501 through JC-303, do you!
- i
- I i 3 15 ; have any corrections in respect to thcno exhibita? {
5 16 I
A Yes, I do. ,
17 l
In Exhibit JC-502, I have the following .
18 corrections:
19 On page II-14 under the column headed 20 Convert TMI-2 and under the column below that headed Coal, 21 the figuro across from Total should be 1365 instead of 22[1355.
0 23 !! On page II-6,
!! tha next to the last line,I 24 0 the word should be " Pennsylvania".
( !
25 And, on page --
i d
I
.. Raber-direct 1759 II i j i
I O Just a memont. Are you deleting the "Naw Jersey-( 2 Msryland"?
3 f A No, I an correcting the apelling of Pennsylvania.
4 Q It should be spellad with an extra " A" . All 5 right, go ahead.
6 A on pago IV-3, seven lines up from the bottom, 7 the word should be " hierarchy".
8 I have one correction to Exhibit JC-503 9 and that is en Table D-4, which is near the very and, in the 10 very right-hand column of the first lina under Coal there is
! 11 a year listed thora. The year should bo 1990.
12 Hn. NARCELLI: Uhat table is that?
- i
- 13 I T113 UIT.iEGS
- D-4. It's just a few
[ a i j I4 : pages in from the back.
s !
5 15 I
Mn. NARDULLIs Ma dodt havs it. It E
16 ( never was part of my oxhibit.
i l
17 ' JUDG2 HA3SUALL: Off the record.
1 18 (Whereupon, there waa an off the record 19 discussion.)
20 JUDG3 MARSHALL: Back on the record.
21 DY MR. KI2 STEN:
22 O Do you have any other corrections?
23 i A No, I have no other correctiens at this tir.c..
- 24 Q Now, Mr.
- tabor, this testimony was filed in w
I 25 July, is tha rrect?
l l
1 i
Rabor-dirGet 1760 4
I A That's corrtet. .
2 Q Do you wish to update that testimcny in any 3 way for anything which has cecurred since that tint?
4 A Yes, I do. There ars three areas whors events 5' have continued to evolve since the przfile testimer.y was 6 prepared, and I'd like to update thet tentimeny with regard [
7 to these more recent events.
8 Which are they? '
Q 9 A These thrse areas are Jersey Central's capacity 10 needs over the next two deccces, Ontario Sydro tie, and ths 11 impact of updated esticates of the cost and scheduls for
- i
- I 12 TMI-2 recovery cn ths, av91untion of the TMI-2 dispositica 13 options.
i 14 i i !
i d 15 l
. i I 16 i !
17 IS ,
19 20 21
,I no n l
23 :' { i t i ,
I t
24 I (2) 25
e Kabor-direct 17Cl I Q First address tite load foracasts and capacity N
2 useds.
3 A Yes. There la presented in JC-500 cn pages 4 2 through 4 a discussion of Jar 2ey Cen:rsl's capacity needs 5 over the next 10 to 15 years and the exhibit JC-501 is called 6 out in that discussica.
7 The objectivo of that particular discussion 8 was to present a picture of whon Jersey Contral will naed now 9 capacity and how nuch will be needed so that altornativos 10 regarding THI-2 and Forked River can be visualisad in a broader 2
11 f planning context.
' , 12 l The Jersey Contral total capacity cbli-j i 13 i gation line that is diuplayed ca the chart of Oxhibit JC-501
{}7a ,
l j 14 q was based on a load forocaat that van cada in April of 135'J. '
- I 15 l dince that timo vs have re-examined the !
, ir 16 short-term sales forocust for Jarsay Contral and found that 17 a downward adjustment was acadad for the noar tara.
18 The dasnvard adjust:;cnt la das primarily 19 to the current recession and to a alower economic racovery 20 in 1981 than had been incorporatad into the April forecast.
21 ! As a raoult of the lower projection of 1
22 sales for the near term, the poux load forecast was also 23 adjusted downward and, accordingly, the long-tars sales and 24 peak load forecasts woro leevred soneyhat in order to reflect 25 this short-tern reduced sales. ,
l 4
- I
Raber-dir0ct 1763 1
The downward adjustnent to the April 1980
() 2 long-tsrm psak load forecast is about four percent.
3 In addition, it appears that the latent 4
load and capacity data frcm the PJM ccmpanies collectively 5
may resultin a slight rsduction in GPU's allocated reserve 6 t*.
rgin obligation in the timeframe of the late. '30 's and early 7
1330's and alJo it appears that the T:tI-2 forced outage will 8
serve to ahlf t soms of Jersey Central's 3 hare of GPU's capacity 9l cbligation to other CPU companies.
10
- i Tha not racult of theca factors is to
- i
- Il j chift Jorsey Contral's total capacity coligation lino that was i j
12 I displayed in JC-501 dernwardslightly in tha order of 400 I
()j 13 i asuavatts in the 1990 tinofrsme.
I4
. This is shown in another exhibit that I'd,
} 15 i like to entor now.
i 16 2 Do you have this? <
17 A I havs a copy. Thank you.
Ib l MR. KIRSTra May wo have this oxhibit 19 which has just been referred to by Mr. R4ber, 20 which is an update of the Jorsoy Contral 21 l
installed capecity and ebligations, markad 22 Il as Exhibit JC-3047 23 JUDGE MAttSilALL: If there is no cbjection, l
24 4 it shall be so marked JC-504. '
(';
(,) 5 r
(Cne-pago document entitled " Jersey 1 ._
, f Raber-direct 1763 .
I i Central Installed Capacity And Obligation", ,
O 2 i
referred to above by Trir. Kirsten, is rocalved i
! 3 for identification and mark,ed Exhibit JC-504.)
4 1111 you continue, Mr. 7:aber.
l Q 5 Tho now Exhibit JC-504 ohcws the reviuod Jersey A !
6 Contral capacity obligation line and also shcvs installed ,
e 7 c.apacity asca:[ing that T:1I-1 returno to cervice by 1982 {
8 and ElI-2 roturna to nervica by 13Cfl. :
i 9 {
10 ;
- II l
. 12 l l
! l O; ia l
= lt j 14 t !
15 1 r 16 17 I
18 19 ' f 20 l 1 21 ]
22 23 i 1
I
~~
.O. 2s
i 2D Rabar-direct 1764.
I A (Continuing.) I'd like to point cut that the 2 capacity plan for trade in Exhibit JC-504 is a course of 3 action that I think Jersey Central should enbark upon ao a 4 minimum.
5 Regulatory recognition of the need for this 6 plan or something similar to it, along with imacdiate and 7 ongoing support are essential. -
8 It in Laportant to nate that althcugh Znhibit 9 JC-504 discusses a plan which would rccconably enable Jersey 10 Central to meet capacity cbligatiens by the late 19 dos and i
11 carly 1990s, this plan still mehes Jers+y Central a net 12 g purchaser of energy throughcut this period and beyond, and (8) i 13 that is shown in another exhibit that I uculd like to intro-
- 14 duce as well.
j 15 MR. KIRSTEN: Ihy we have the exhibit I
16 to which Mr. Raber has just referred, which is I
labeled " Jersey Central Poucr & Light Energy 18 Sources" identified as E:thibit JC-305?
19 JUEG2 MARSHALL: It shall be so :mried 20 JC-505.
21 (One-page document entitled "JCPUL Energy Scurces," referred to above by Mr.
23 Kirsten, is received for identificction and of p/ carked E:thibit JC-505.)
N-25 Q Would you proc ed, Mr. Paber7
Raber-direct 1765. ,
1 A Energy purchases will be needed in the time-2 frame of the late 1930s and 19903 because ruch of Jersey 3 Central's capacity is oil-fired or intended to the inter-o 4 mediate or peaking service and is not called into operatica 5 as of ten as nuclear or coal-base load units within PJM's 6 economic dispatch hierarchy.
7 On Page 6 of JC-500, I r.ade a statement to the 8
effect that it is GPU's intent to hecp open the option of 9
new coal capacity at sites otner than Three Mile Island Irf 10 maintaining the Scuard 7 Plant en a 1987 in-service schedule .
11 It now appears that Penelec will not be able g
12 to support the 1937 in-service state because of zcver:
/~T 13
(_/ 1 ILmitations on funda available in 1901 cad perhaps in 1982.
i -
14
[ Seward 7 is, therefore, chown to enter service
- 15
. in 1989 in the two exhibits that I've just encared. These 16 are JC-504 and JC-505.
I7 Q Now, would you also a=plify your refarence to 18 the status of the Ontario Hydro tie?
19 A Yes. The same general discussion in ?chibit 20 JC-500 mantions the Ontario ilydry tie. It identifies the 21 major energy purchase period as being seven years, extending 22 from January 1935 almost through 1991, 23 Since my pre-filed testi2any was written, a 94
~
(]} new draf t agreement has been discussed with Cntario liydro. ,
25 This specifies a major power purchcoa for a period of 9-3/4
Raber-direct 1766.
I years from the norninal in-service date of the inter-(.) 2 connection, which is still taken to be Decczber 31, 1984, 3 and extending through September 30 3 1994 and dhis is also 2
4 illustrated in the two new exhibits, JC-504 and JC-505.
5 The observetions that were originally pre-6 sented in JC-500 remains substantially correct. They =ay 7
be modified just a bit by this updated information.
8 For c.-ampla, on Paga 25, four and five linca 9
up frca the bottes, I might accad those worda to read 10
" Jersey Central's need for new base load capacity any bc II k deferred until 1931 to 1992 or later."
. 12 r~s.
L-) ;
I4 15 lb -
17 18 '
19 20 21 22 23
)
25
Raber-direct I
gS Q Weuld you slao refer to t!.0 ccenent on tho O 2 status of the DiI-2 restoration cost estimates?
3l A Y6a. The studius deacribed in my profiled 4
testimony wat9 based on clacnup and recovery evat estitsates 5
that ,;ro nada in 1973.
6 In my pret_ lad tostimony, specifically i
7 in JC-500, on pago 14, I stated that "while the coat and schedala 8
assumptions are generally cptiv.istic for cach alternative and recent information suggests that restoration will cost 10 appreciably more and taka longer than originally ascured, i
II
! the overwhelming eccno:aic advantage of rostoration la such t
g I' l that the study conclusion should not chansa evnn if the cost
() ;
13 and schedulo ectinatos for rectora tion increase significantly."
I I4 t
Sinco tha nov eaticato for cicanup and 15 : restoraticn was not availablo whon ny profiled tcatimony van P: !
r i 16 !
I preparad, I'd lika to olaborato on thia statenant in light !
II of the revised schedula which ia longer and tho higher coat IS}lfigures for returning T!!I-2 to acrvica.
I 19 The original July 1973 estimats for 90 t restoriIg TI1I-2 was 0400 million with an accured startup '
21 dato of Ja1.uary 1934. Of this total $263 million van related i
22 l to decentamination and cloanup activitics, whila tha balance o3 covered restoration of tha unit to operational status and l a i r~s 24 0 ruplacecant of the fuc1 coro.
\]
n os
~'
When estimated incurance prceadds, 3300 5
naber-direct 1760
, I million maximur, were taken into account, the net cost of 2 restoration ca e to $100 741111cn and the unavoidable costs 3 of cleanup and decommiss!,cning, if restcratica wac not pursued, 4 under the convert or repisce optiens, were asacned to be 5 covered by this insurance.
6 The :ccently devoleped August 1930 t 7 estimate for completion of cleanup and restorntion of THI-2 8 totals $1 billion, including 1979 cxpenditures and escalation 9 on future expenditures. Cornarcial operation was assu=ed 10 to begin at the end of 1905.
$ 11 Cf this .71 billion, approximately $670 i
, 12, million is cleanup related, and in this study va assu=ed this'
() 13llexpense would be incurred reg;rdless of whether the unit is 14 restored, ccavtrted to coal or decommiasioned.
- I l 5
15 l >
The new estinated c0st of refurbishing
- )
~
16 the nuclear unit, nnzely $330 million, replaces the S100 l
17 l million used in the original study.
i 18 l For simplicity in assessing the impact 19 of the now cost estlasts on the relativs economics of the 20 TMI-2 dispcaition options, the $330 million was assumed to I 21 be reasonably cenaistant with a retnra to cenmercial operation L -
22 l date of January 1,1937, which is one of the sensitivity 23 scenarios described in the preflied testinony.
3 i 24 In the profile testinony, I statad that 25 the fix option could sustain a capital cost overrun of $1150
,. _ . ~ . _ . ..
l naber-direct 1739 ;
I 1 million for a 1937 startup bofors the average 10 year cost j 2 of electricity frca the ref t: ence block of clipcity exceeded ;
3 that of the usarcst econenic competiter option, '<hich wa the 4 gas / coal conversion.
5 6
7 8
9 10 i
! 11 -
- i, 12 i I i Ol 4 ia !
14 l l
5 15 !
i r 16 l l 17 l l
18 i
19 20 21
- 22 ilh p
23 !
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n i
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! 25' f
i
2E Raber-direct 1770.
I A (Continuing.) In this care the cost penalty 2 to a typical Jersey Central custecer who uses 500 kilowatt 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per month of not pursuin;; the restoration of tiI-2 4
would average about $1.30 per menta over a ten-year period.
5 Using the new recovery cost estimate, tha 6
sustainable capital cost overrun is reduced by roughly 0230 7
million to about $920 million, with a corresponding reduc-8 tion in the customer penalty for not purcuing the restored 9
option to slightly over $1 per =cnth. Mien the comparisen 10
, is made against the off-site cost optien, the sustainable i
11 i
capital cost overrun is reduced frca 41450 sillion, which I
j corresponds roughly to $1.70 per conth penalty for not
() .
choosing the restore option, to about $1220 million which, 14 i in turn, corresponds roughly to $1.40 per canth penalty.
b 15
- The selection of off-site coal as the second I
16 best option is still valid on a rich basis and is not affected 17 by revisiens in the cost esticate for 211-2 restoratien.
18 We recognt=0 that there are still risks and 19 uncertaintics in rostoring TMI-2 to service. Delays in ap-20 provals from the NRC, unforeseen technical problems, and 21 financing difficulties could further delay the start-up and 22 increase dhe cost.
23 llowever, the incrc=catal cost of restoratica os f})
would have to nearly quadruple, fron $330 uillion to $1220 25 million befuro the econemic advantage of fixing til-2 would
Raber-direct 1771.
I be eliminated. Consequently, the conclusions that I atated i O 2 in my pre-filed testimony are still valid, ncrsely, that on 3
the basis of invest:sont requirecents, customer cost impact::,
4 and other factors, the return to service of TMI-2 cs a 5
nuclear unit is the best approach.
6 If restoration was not' feasibic, the cecond i 7
best "optien would be to replace T!!I-2 with cool capacity 8
located elsewhere. This latter conclusien reficcts our be-9 lief that the slight economic benefits of conversion to 10 coal are s:nall when contrasted with the large rishs and i
II
.i uncertainties inherent in this unprecedented conversion I
j project.
The final decision on t/nich cou ce of action I* 14 i to follow uill not be made for another tuo to three years 5 15 g since the clean-up =ust be ccmpleted in any event, and this 16 will take at least that long to acce=plish. As the cican-17 up nears ccupiction, we vill gain valuabic infor=cticu on 18 the feasibility of restoring LII-2 to service thrcugh a 19 more thorough inspection of tha physical ccnditica of the 20 plant, and we will also presu= ably have the benefit of a 21 resolution of the status of the undas sed TUI-1 by tha HEC.
22 MR. KIRSTEN: Mr. Raber is available 23 for cross-exasinatien.
os
~
JUEGE MAES11ALI.: Chay. !!r. Hardelli, 25 -
would you like a feu coments to go ever your
ilaber-direct 177,..
I notes? .
t O y
- HR. W.RDELLI: No, I don't believe so, 3
t 4
5 6
7 b
8 i
9 10 3
j 11
, 12 3
'3 O .: t l 14 15 I
16 17 18 19 20 21 22 23 24 25
hber-crosa i
1773
, }' CRO3S EXAMINATIO:i f
b 2 BY !!a. liARD3LLI:
f 3 Q Mr. Eaber, you said that your estimato for the f
i 4 cleanup and rsstoration of THI-2 back in July of 1979 was .
5 $400 million.
6 A The total cost, that's correct.
7 0 And a year later your estimato is Si billion?
8 A That's correct.
9 Q Given that phencuenal increase in one year, '
10 aro you optimiatic that your oct1=nte of S1 billion is going l j to hold up for very long? 2 i 12 : A I think that that is an estimato that la sounds 5 g 4 i 13 based than the original eno, and in particular, t=kas into i 11 < account an updated and probably more realistic anaecament of { i ! I d 15 , the schedula that is required for this recovery, and this i ! E 16 schedula is predicated largely en regulatory action that the , original oatimate really did not foreses. I 17 l I think 4:he later 18 i estinata la cortainly r. ore raalistic than the earlior one. 19 Us are gaining infermation by entries i i 20 into the containnent building. Whether the estimst:a vill 21 increase beyond this one renains to ha seen. 22 N"erthaleas, our studius show that an 23 [ additional further increase, a very largs further increase, L I o4 can be cuatainod bafore the conclusion regarding recovery l 05 ! as the baut course of actica is no lenger valid.
- s I
i
aaber-creas 1774 l l I Q What in-sorvico date for a restored TItI-2 is b) v assumed within your estimats of one billion dollars? 3 A That estinato assunes a return to commercial 4 ' operation at the and of 1335. 5 Q Sut you yourself have exhibits that cocm to 6 placa doubt upcn taat 1985 date, do you not? l A The exhibit that I havs introduced assumos that 8 ! it would be delayed further until the beginning of 1983. 9! And =ay I also assume that the changs in tho
! Q
- 10 l projected in-service data for T;tI-2 from 1905 to 1903 would i
II j i' also increana tho astinato of one billien dollars for the j l' costs? (} J 13 A Thatislikely,butnotnearlybythefactorofj l I
!* alnost 4 needed to chango tha conclusion. I i
15 0 Yes, but I think you can caswer with a stronger '
- l t
16 l word thaa "likely*, Is there any way that a desarrent of ' i 1I ' the in-sorvico dato of TMI-2 for three years frcm 1935 to ! 18 1903 vill not increase your ono billion dollar anticato? i 19 ' A It's really only two years. i "O i Q Pros the end of '35 to the beginning of '387 21 ~ A Yed. I can postulate circumstances. oo :
-- ll For exampla, thors wers certain assump-i
...; i-' c tions nada rega'rding the conditien of equipment turns cut to l 21 ] ba betterthan had been postulated, ths eatinats would havs
'5
~
l overstatad those, but -- l
I
, naber-crcus 1775 1 Q Yas, Mr. R2ber, but ycu know as well as I whct
) 2 I am asking you is to censider the sar.a assumptions about l
~3 oquipment and everything else that vent into the one billion .
4 dollar estimate and the plant in going into service at the 5 end of 1985 and just shif ted down the road to the beginning 6 of 1338, and trouldn't we have a subatantial increase just in 7 the carrying costs that would add -- that would make the 8 final total substantially more than one billion dollars? 9, A There is likely to be an increase, yes.
.p 10 Q You seem to have difficulty with my phrase i .
i
! 11 i "stbutantial inersaae", no lot me be specific. I i !
l l
, 12 l Ehst order of magnitud3 are we talking l I
! l
()
! e 13 about, giion the carrying chargan for two yeara? f
. o I
! 14 i A Let's assuma that inflation will precned at I
- I 15 !
conething lika 8 porcent por year, so that would be 15 per-
- 16 ! cent inertaso for two years.
I' 17 I O And 16 percent of one billion dollars is a lot 1 18 l cf monoy, isn't it? 19 A Yso. But, it's not enough money to change the 1 20 l conclusion. 21 Q Mr. Ribsr, this estinato of one billien dellarsg ' 22 is that in 1900 dollaro? 23 , A No, that's in ascalated dollars as expended
.l i l O 24 dollars over the course of the recovery project.
s-t 25[j , I4 i t
4E , Raber-cros: 1776. 1 Q Now, when you made the estimate, and when I O 2 say "you," I am using the plural "you," meaning you and 3 your colleagues and cenaultants -- when ycu made the esti- l 4 mate of $400 million last year, you have now told us for 5 various reasons that wasn't such a good estimate. You men-6 tioned regulatory problems, but cay I assuas that there were { 7 also technical probicms chac led to the inadequacy of that 8 estimate? 9 A Yes. Remecher the first esti= ate was made a 10 i very shortly after the accident and there had been caly a 11
. lLaited amount of tLne to assess the possible condition of 12 g equipment within the plant.
() a Q But has the Company resolved all the techni- ^
- 14 g
cal difficulties that would impact upcn the final coat of 15 the cican-up and restoration of TMI-2? Aron't there still r 16 i unresolved difficultics? 17 A I would ansuer yes to that, yes. 18 Q And isn't there still a fair amount of specu-19 lation involved in the estimate of what the total coat would 20 be? A Some. 22 Q Now, you have spoken of the cbst of not re-23 storing D11-2. May I assume that you are cecparing that to os (]) - something elsc7 25 A The other options uere to convert it to coal
Raber-cross 1777. 1 or deccomission the unit and build coal capacity cisewherc ,O other than at Three Mile Island. In pursuing either of 3 those other two options, there are still sccie azount of 4 costs incurred at Tirce Mile Island for cican-up. 5 Q How, when you talk about the cost of not re-6 storing D1I-2, are you talking about the cost to the Compan-yl 7 A I am not sure I understand what you =cen by 8 the cost of not restoring MI-2. Tae cost that I have given 9 hers are customer cost increases associated with pursuing to
- one or the other options; so these are costs to the cus-
$ 11 i temers if we were to do one or the other alternative, namely ,
12 l convert or decer:nission and go off-site coal. f Q You have helped no with your answer because
! 14
- you said custccer costs.
5 15 j A Yes, r 16 Q And so you are equating custccer costs with 17 Cocipany costs -- I withdraw that. 18 When you present these varicus acenarios, you are assucting that the customer will bear the ccat of these various opticus 7 21 A I have assu=ed that a restored III-2 uculd 22 go into the rate base. I Scve assumed that a converted TMI-2 would go into the rate base. I have assumed that an I] 25 E# 7E * "" 8 #
- that the fuel ecsts and operational cosca associated with
t i i , Raber-cross 1773, ! ! r t 1 i any of those options would fall upon the custc=er in the ; I 2 usual :nanner. ! i i 3 l 4 3 i 4 i i 5 l 1 , i ,
- 6 i !
i 7 I t 8 i i 10 O 4 f
- . 11 i i e I 12
'I i U a 14
- l b 15 -
t : ' E ' 16 , 1 4 17 i 18 i i 19 ? l 20 , k i 21 . t 22 ! 23 - i I
- 24 25 J
4
,r_ - . ,.. - . . .,-., , . . , - . , e,,,.=,e.- , , . , . , -r---, -
Rabe r-crosa 1779 I Q Okay. 7.nat asaumptions have you raade about
/,~
V) 2 who would bear inc cleanup costs for THI-27 3 A I have rada no assumptien whatsoever. I have 4 not addra.; sed that issue in this study. 5 It is not nccessary to do that because 6 tney are cc:r.on to all three options. J 7' a You're anying that no Latter what "MI-2 x.ust 8 be restored? 9 3 ;.!uat be cleaned up.
; 10 J Excuse me, cust be cle.aned up?
[ 11 A Yan, I'm caying tnat.
. 12 ! I'm acauming thct for the purposes of I
() l j 13 { the study. 14 Q But is it irrelevant to your study as to who , I 15 ! must ocar tha burdan of sno cost of cleaning up THI-2? f r 16 Yes, it is, since the costs are the acma for A 17 cach of the options whern I have assum2d that they would be
~
18 l the name. l 19 l Q Ian't it possiblo -- first of all, are ycu I 20 awara of the ordor of tno Pennsylvania Public Utility Commis-21 sion whereby they stated that ratapayers are not responsible I l 22 for the cleanup costa of TMI-27 23 -lj A I da awaro of the order, yee. g-) 24] Q Ncw, if that order ccntinuca to be upheld and ,
\_/ *
- i o"r if the New Jersey Board of Public Utilities takes a similar it
Raber-cross 1780 ; I I position, might not that increase the costs of restoring l fi uJ IMI-2 in torns of the cost of coney to the Cenpany for I I 3 restoring Ttti-27 ! I 4 A I suspect that I am not the appropriate witness: ; to address that issue. 6 i O Now, you said that you assu=ed that the mcney ; i 7 spent to rostore TMI-2 -- we've been talking about cleaning 8 up and now vo're talking about restoring it. 9 i You said the mcney spent to restore 10 l TMI-2, you mado the asausption that that would be providad
, l i i
.i II I by ratepayers to the degi ae that whon it was reatcrad, it I
3 would go into rato base and ratopayers vould pay a return on () ; 13 ' 1 that rata base. l i 1 14 j ! Is that a fair characteriestion? l I- il A That's correct. l i ' l 16 , Q What if there's a regulatory dotsrmination by ! I7 the Psonaylvania Cc=miscica and/or the Nov Jersey Commisaica 18 that the Cenpany caused the accidant at Thres Mils Island and, 19 l thorsforo, tha Cospany via its ateckholdarn must bear ths
'O
- l burden of restoring the plant to its pre-accident condition? Ii l
'l O
. A It asers to me that tha savings to the customor I
22 l under those circunctances would bc even grastor than my
'3 I!!
study has shown, if tha rsatore option were then pursued. li O 2'I (J I
-Q Realistically, Mr. Raber, would the Company be
'5 sble to restore TMI-2, if it were dacreed that no ratapayar .
V Rab0r-cro30 1781 ' i 1, monies were to be used for it? O 2; A I'm not in a position to answer that question. 3; MR. HARD3LLI: Judge liarshall, cculd 4 we go of f the record for a r,cment? 5 JUDGE MARSHALL Sure. 6' (A discussion was held of f the record.) 7l JUDGE MARSHALLS Mr. Rabsr, will you 8 new step dcwn and we will open the hearing 9 i up to sny mcchers of the public who wish to I 10 l spank.
! 11 l JUCCI: MA3SHALL: Off tha record. l E
12 '
! i (A discussicn was held off the record.)
( j I4 : 15 ' i, !, ! s
- 16 l I
17 18 19 4 20 21 22 ll
- l 23 ll
}1 0
' t 25 e - n - . - - . , _ _ -
2F Fahey- 1782. I D1ANE L. FAHEY, 285 Boeing Drive, 3rickto a, O 2 lieu Jersey, eppearing as a Public Witness, 3 being previously sworn, testified as follows: 4 THE WITNESS: I want to thank Your Honor for 5 latting ma come back and I assure you I will take a 6 very, very chort ti=c. 7 The main reason uhy I'm bacic today is beccuse 8 I'm deeply concerned about this deposit money that 9 JCP&L is using at their diacretion to pay their debte . 10 I think it's unfair, unjust. I think that it i II i is causing entreme financial problets for the people. 12 j I think it's probably extortien since this deposit O V
~4 13 money is being used solely, as far as I can see, to
- 14 i pay the debts of JCP&L.
d 15 g What incentive does that Ccupany have or tdv.it b 16 protection do we have frem escalating deposits when 17 they can use it at their discrecion? Therefore, I
'- 18 am urging Your Honor and the Public Advocate to hane 19 this money placed in a special acccufte specified
.. 20 solely for the use of -- to be returned back to the 21 people, the ratepayers of the State of New Jeracy.
~~
t Secondly, I on deeply concerned about this, 23 too, because of JCP&L continuously anneencing bank-94 (]
~
ruptcy or the possibility of bankruptcy. Financial 25 disasters come upon this Ccmpany.
I Fchey- 1783. , 1 I also would like to =ake a re= ark, too, about () 2 , Three Mile Island-2. I can't possibly see in the i 3 future how this nucicar plant could ever be restered 4 and supply us with ciectricity at a cost censiderably [ l 5 lower than what we're paying now. 6 I think the cost of having it restored will 7 he entirely too high for any ratepayer to absorb in , 8 ! this state. It's ce=pictely cut of our hands and ; 9 ! I'd also like to testif3 too, that I believe that 10
, JCP&L or GPU will enly get this =ancy frem the peopic '
11 i j of the State of New Jersey; it will not came frca e 12 j any banks. () { I can't foresce that any bank would ever icnd 14 iu
, them money, and I think that indirectly or directly that we, the pecple, are paying for th2ir -- possibly l l 5 16 '
for their short-tern loans at a very high interest 17 rato. 18 Before I read secething, I also would like 19 to say semaching else. We, the peopla, pay for 20 everything when it ccmes to these nucicar plants. 21 It takes up to 20 or 10 years to build one, 20 or 22 30 years life's expectancy of a nuclect plant, and 23 then we have to caelose it or centain it. 24 N I can't possibly see where this can possibly , (~Y
% 25 bring us a cheaper ccst of c1ccericity to the
Fahr.y- 1734. . m I customer and then, accondly, I'm deeply concerned
) 'l 2 about thi4 spent fuel fund.
3 To my knowledge, this is supposed to be in a 4 separate account, too. It's supposed to be there 5 and available when they have to get rid of this 6 nuclear wasta. 7 To my knowledge, all they do is ce=e bcek, 8 use that money for something elce in the interim, and 9 when they need it, they como 'anck to the ratepayers 10 and say, "Your llenor, we need this increase." i 11 This is like the second eine we'va been goused. 12 we re continually bcing gouged. a This ecncy is not ()' : 13 in a separate account and I firnly hope this coney 14 uill be placed in a separate account, or show mo to-15
. day or the near future what account this noney la in.
i 16 Are we going to pay for this again? 17 On the long-ters basis and each and every I8 increase I believe, to cy knowledge, that it's in-19 corporated in there, too, for the containacnt of the "O
~
plant. They're supposed to put certain amount of 21 money aside for this plant to be containad after it's 22 not useful after 30 years or =aybe a little bit more. 23 IIow many times are we paying over and over 24 i p and over again for that? 25
)
Fahey 1785 I T!!2 IfIT.'!20S t (Continuing) Your Honor, this V ' 2 comapny is so nisnanged. I am urging that all tap ! l 3 executives are asked to Isava. I am urging you that 4 all prsforred stockholders ir.=sdiatoly do not reesivs
)
5 dividends that, if anything, they should turn to the 6l preferred stockholders and get the money frem this, 7 not the ratepayers. I 8 If this does not happen -- you're asking 9! senior citizens for up to $300 a =cnth, on fi::ad in-10 comes, and rising to pay a utility company. It's a i j 11 i sin, it 's a downright sin, and thers's conothing else, i t
., 12 ! too.
Oli 13 i x thinh wh.e shoule s. con ieorca =co
; 14 l 1s how :nny monopolics wa are under. 'To are under a ;
l : 15 ' wetor conopoly, unds: a nuage monopoly. :14 are under 16 l a gas =cnopoly, undsr an oil =cacpoly. 17 All of the::e conopolies we need. They'ra 18 i all necessitics of lifa. i i 19 The toicphone is naedad to appoint, to 20 have thers, but we do exclude the telephone company 21 out of thic, but the rest of it is a sheer naco:sity 22h of life that la coating dearly, and avory time we k i 23 ' have an increase in electricity, you have to ,take into p 21 y censideration that we'ra also under another controlled O l! i 25 ' monopoly, that is, water or the gas company, and as ll
Fahoy
! 1756 ,
i /~T 3 vs well know, most recently the gas company had a ! { (_) 2 tremandous increase, I beliqve up to 30 or 40 pe: cent! i 3 This has a terrible effect on all the people. 4
,3 I am thoroughly against any legal 5 i monopoly in the State of New Jernay and eventually
{ 6 Ihope to change the system which we're under. l l 7 3 Dere is the now fora that we're with-8 holding on deposits. It randa as suchs
. 'We the people',
9
'captiva payer', of a ' utility monopoly', JCP&L, ars 10 { i i==cdiataly protacting our daposit money to guaranteo gg rsimbursemant.
12 l E I
*I as withholding" -- and it's a said
(~'s , 13 ! amount - (_/ * "which repreacnts p art or whole said deposit, j j,3 }] and/or said arount equals my dopoait. ! i P
- 15 ,
- i "Taka further notices Just and ranson- :
! 16 i I able deposits are non-oxistont, en the contrary, 37
'aaid dopoalt' la extortionate, which varies from gg i ratopayar to ratepayer without any company policy.
19 *
' its the people' are taking said 20 actien, because JCP&L publicly announced ' drastic 21 financial probicca', and JCPsL does not have said 22 deposit protected if Dankruptcy occurred, on tha 23 ' i contrary, said deposit money is singled with other 24 rev nuo and used at JCP&L's discretion, when, in fact, 0) 25 l naid monoy (doposit) should bo placed in an escrew ,
I i i
! I 1 1
)
i l l'ahey 1737 1 e 1 account. O 2 "JCP&L must be forced to place said [ i t 3l s.oney in an escrow account designated 'for deposit i
'I money only' which cannot and will not be used by 5
JCP&L.' .
?
6' I have a sort thing hsre, if I may f
~
i l continue to read this or -- f i < 3 JUDGI RUL3dALL: itall, if you wish to. t 9 It would est up time of your five minutes. You can I i 10 jist ask for it to be efficially noticad and intro-II f duced into the rScord. i , 12 l i O:.
'3 1
i
- 11 l 1
I d 15 l 3 ! E 16 I L7 18 l 19 l 20 21 l : ; 22 ': > I 23 L l N 2.i p! O ' 25 N
Fahey 17;g 1 THE UITNE30: This would take up cy O k- 2 five minutes, then, if I were to read this? 3 JUDGE MAPMALL: It locks lengthy. 4 TI12 WIT:TESS : Okay, I'll just finish . 5 this and that vill be it. ! l 6 JUDGE PAPCFALL: All right. , 7 T " r W I T Iir.E S : ;ihy should any electric 8 or gaa or for that ratter, any utility be so eppowered , 9 to decide what is life cuataining? , 10 Why do we have to relinquish cur Civil i j 11 aiJhts to privacy and defend ourselves against our 12 own governr.cnt and private corporations? J N. j 13 nc legal tenopoly, no cartel and no
- ! 14 corporation should ho allowed to decide destiny over 5 15 ! any one individual.
I 3
~
16 It is all too involved and ccr. plicated 17f, to Jolineate and label ' life sustaining." i Curely the n2cessity of a telephone in 18 l' I 19 an accrgency call for help: the thraat to public health i i 20 by thn lack of good water and dioposal facilitis; ,
+
21 l the need of sustained living confort to prevent t
-22 illnets and accidents in proloncing life -- the list 23 ! can so on as well as the lista 'fer liabilitics and ,
i 24q violations that could ensue. I 'l l og It is, tnerefore, highly advised and l
.v -
,. , - , ,, y -.m
Fahey 1789 I reccessadad that no utility be allcwed to discontinue O 2 servico of any nature. 3I This vital sever should undsrgo dus l 4 procans of law, asmandatedbytheU.S. Constitution,l and, if so determined, that order should come from 6 a court of law. 7 Let's not relinquish the power of judga 8 and jury to those who should not possoas it. 9 It would as a graat help to many if 10 l tr.c Board of Public Utilitica would ccaply with this II code and be made to onforce the very issuance of a l ~') g : discont:inuanc's notico that was utopped by JCPEL as l
' l C{*
14 i a cenpany policy sc=o cima ago. j l By simply allowing a cocpany to dia-I 15 ! continuo service on a deli.:quency notice, which is l l: r I' 16 not even mentioned in t:ho coda, but was prchably 17 instituted as a more pleasing and loss offensivo 18 manner of doing businwas on the part of the utility, j , 19 I the Board is squally guilty in allcwing auch a prac- j i
"O tica to exist.
21 l Past exporiencos with discontinued cuatcmers revealed that a good faith effort to pro-o.;'" !l j vido the custcrcer with an opportunity to en*ar into i o
g i.
d a reasonable caforred paynant agreement was arbitrary O -s and one-sided, of tan intimidating and menacing. i __ l
j Fahey- 1790 I I To provent axtortivs practices, b 2 especially where despondent utilitien are concerned 3I and not add unexpected costs into a reasonable ! i 4 deferred paymsat agrocmont,changa the due tica of l 5 i the 25 por:ent limit. from "the agramment is mada or ; i 6 exe cuted" . f 7 That is nov -- I'm finishod, but I do 8 have cne other thing to say. 9 I don't understand the paper that says 10 the 25 porcant dcwn paymont on deforrad roaconable 11 l dafarred payment -- the dsferrad pay =ent program 12 mentioned in the paper says this was availabla, and l 13 ' l I callad tue 30ard of Public Utilitics up and they a i
' l 14 [ = aid no, it's not available.
y 15 ' I told them they were misrepresenting l 1 i
- 16 tho=selves in the paper because tsny cC our people I i
17f ! vent devn to ths utility company and offered 23 18 ! percent for a reasonablo deferrad payment en past ; i 19 due amount that they owed to no avail, and I was quits l 20 l sure that this was available and it's definitely a f 21 misropresentation in the paper. 22 If not, I vculd hope that ths Board of 23 ., Public Utilities would then make a statement in i 24 the paper and lot it be knewn that ths 25 parcent f')T x 25 is not available. I i
4 , I
- j. ra hcy. 1791. q
. s 1 ES. SELLO: Judge '-farshall, what she in talh- ! 2 ing about is a proposed rule change. It has nce Secrt 3 adopted yet, cc it's just in the pro;:osal stage rightl l i 4 now. 5 1he witaass then, I believe. .perhapa then if 6 20 could have that placed in'the newspapers, o ' e-7 cause all the newcpaper articles that I've, you know, 8 read, it refn:c that it applies. In fact, it's 9 clear that it's available right ner.7 10 57,. ?'ARDELLI: l'cu :=y alco wi h to urge the j 11 Heard of Public Utilities to adopt that. 12
; T.IZ UITNESS: I urso the Board of Eublic
' ; I3 C::llitics to definitely adapt that rule and to de-i I4 l flaitely stcp all diccentinuance of service until a 15 f: full public disc 1ccure and 1::vestigation la con-r 16 pleted, which is known as that hhita Faper, and 1 I7 don ' t thin': it's fair that lacreanna nheuld he 18 grautod unica:: all infore.ation'is availabic to the 19 cuat<n:cr.
9 _ '0 JUDGE P16 SWILL: Tnank ycu for your cc:ra.ents. 21
- 12. EDSTill: I have a feu cuestions, if I 22 nay, Min: Fahey.
93 CR053-CM1111ATIC3 24 SY 2In. KILSTEti: ( 25 4 You'ra suggesting that ycu're in favor of the
. . _ . . - _ _ , ,_r. __ ,...m
Fahey-cross 1792, I przfiding of electric service done by cocpetitive. cx2panbr, l 2 rather thcn regulat d companies? Ycu're to clizinate the 3 replative conopoly? 4 A 1 can see where ccsepetitive ccepanies would l' 5 not be that good, but 1 can ace uhcre lint.n or what-ht.ve- - 6 you should be open to the public for public bidding. I 7 don't think a =enopoly of this etch centrol is any good. 8 Q So, you're suggesting that you chould have a 9 g ,gg , acing abic to deal uith any company that's will- [
.g 10 ing to provido the service. la that correct} i-i II i
~
A Well, I think that our ultimate goal is to v
~
19~ j here the people take over, liito I believe in Illinola uhere O! ec7 oma che ut1ut7 cc= san 7 i 14 i Q Uell, if the people sun the utility cecpany, d 15 g it would 'ce a coecerative? Is that what ycu're talking-16 about? i 17 A Pight. 18 Q Ncu, snauld peopic uha are the recebers of the 19 cooperative have to pay all of the costs of the operation 20 '
.i of the utility?
A That's correct, btt I firmly believe th2re o,
^^ '
are seniors ~~ cur acnica are very knowledgeable people 23 and ue will nat have a profit in ils -- 24 Q l's sure thrt arc. 25 A -- crucalzat ten. 9 /
i
, Estey-cross 1793.
I Q 3ut in such a schere, would they have to pay O
'd 2 t all et the costs. i i
i 3 A They woula. W'a , tne people. vould have to pay, ; 4 cot -- exc=pting Three title Island-l and 2. I uculd ar.st: o l 5 you weuld have to abandon that. 6 4 l'a trying to get your view. If they wculd 7
, pay all the coats, would they also have to bear the cosca i of uncclicctable acccuntai
'9 A Surely, but hopefully uc'll canade cur ccapany 10 nr.cn betuer. ile von t have thnc tanny.
8 i 11 j Q Nculd in be a teat of good n:aca,;esenc to try I 12 i to liait the neser of uncollectable accountal O! . I 14
. a r..at
. s cor m t.
i y . tad what uould you consider as a reanenable
$ 15 j j race to liuit the rer.ber of tocollectable accow.ts, the
- 16 burden of uhich uculd have to be intposed upan the other i 17 l ratapayora? What vculd you sur,esci 18 A Chay. First of all, I's a very confident 19 person and I can leek back at this utility cermany sc.ne i 20
, yearn ago and people weren't in this discster. It's cince
/1 .
ll n.rac Ilile Island. Uc uculdn't have Tarce Mile Inland. 2.! ' i 19'd be proporly canaging our eccpany, i 2J We would not have to have all thcae uncol- , 4 24 [ g lectabled bceause it would be affordabic. 25 l You see, right ncv it's net affordable and l I
1 i:ney-cross 1794; I that'u why you have sli thone uncc11cc:cbles, beenuse of your :itictaica at .,.ree _a L9,e
.u Ast rad.
3 Q Set as par: .af ;oad .:2:wg;;:ent, uc,.ldn't ycu 4 say that gw! .rtita3e2:ent tr. quires O.nt there ba ec:o en-5 forecicit of callectien',' .:culda'c that bc cae of the indicia 6 e f .';cc 3 Ianc3"Jant i 7 8 9 10 ! 11 12 3 3 4 13 d e 14 , 3 15 l
- l
- f I
16 !< 17 i 18 19 20 21 oo
==
23 24 25 i i I
yFahey-cross 1795 .i i i A Sure, I agree, out it should be through the i
} 2 course. The Judge shouldiccide if cce owes a utility company, 3 I
- cney . They should have the due process of law, really, !
. . 6 l
4 like any other bill collector in the state has to do. j 5 I Q If it's an unregulated company, thars wouldn't i t 6 I be any regulation which would decide it. ; 7 A We wouldn't need -- 8 Q You want it regulated? l 9 A We wouldn' t need it regulatod, no. I' { 10 Q Dut you would hava to have sona m'2ans of en- I 3 I II f i forcing it. Would putting up a security doposit bo a 19~'1 g reasonable maans of helping to reduce the number of encol-() { . 1ectible accounts, Mrs. Pahey? 14 j A You have a security deposit, it should be i l 15l, placed in a designated escrew account and abould be considerably 16 j lasc than what is available right now. I Q Sut thors should be a cacurity deposit? I8 A If there's a security deposit, like any other -- 19 if you buy a car and you put a deposit, that deposit noney
-39 is going for the car.
I 21 ! If you chocae to pay inter 3st, it applies 22 towarda intereit.
3 l Now, in this cass whora a deposit is 24 given, say it's $75 or $50, it should be in an account which
( - o5
~ l draws interest forthe customer of 9 percent er 10 percant, l
i i l 1
_y l, k Fahey-cross 1796 1' which I assume is available right now, and it should be f 2, returned within a year, and I think if the company is managed i I 3 properly, we wouldn' t have exorbitant or escalating increases! . 4 So, therefore, it would.he affordable. t 5 Q Do youbow that undar Public Utility Regulations i 6 that tne utility is required to pay interest on security 7 deposits? 8 _ A sure, I know that, Titlo 14. I 9I Q Do you know that in addition to paying interest [ 10 on sacurity deposits, that customar deposits are a reducticn i i 11 j of rato base, so that in effect the monsy dosa not earn r,cney 4 12 for the utility? Do you knov that?
$ i 13 A Well, I disagree with your statseent en that. };
14 I Q Are you awars of it? i 15 A It's supposed to be that way, let's put it thad i 16 way. I I l 17 0 You do know it's supposed to? i 18 A It's supposed to. 19 Q Do you know that ths Public Utility C0cmisaicn . 20 enforces the fact that it is that way? all 21 A You know, we/have different sets of Scoks, i 22 don't we? Q I'm not asking you that, Mrs. Fahey. 2.1 ,A 24ll A Right, but -- i 1 , t 25 Q Are you aware that the Public Utility Cc=sission -- II
\
rahay-crosa 1797 . W l i
)
q. I A I'm avere they were supposed to. e 2 C Do they enforce tnat regulation? If 3 A They aro supposed to. f t 4 Q Co you also know that the diaconnect regulations [ 5 are regulations of the Public Utility Co,tmission in order f 6 to redaca the snount of uncollectibles that will be charge-7 able to othar cuctomers?- 8
~
A Thaso uncollectibica that arc charged to 9 other custccers, I'm glad you brought this up. It is, to
, f '
I 10 my knowledgo, that overy time JCP&L entsru into a neN increase
) 11 or conca for a now incroace, a lot of those ancolloctibles f i '
12 ar2 entered as debts or roney due to the conpany. 8 i () . 13 n
- low, right after the Judga granta you I
. 14 , incr2asa after increase, except for the last ons, you go out l l
15 and ycu collect thoso uncollectiblia by turning off poople. ; ir ! I 16 ' ' lot only do you collect your uncollectibles, 17 l the money that's due, but thon' you darand this daposit up to t 18 5400, in business up to considerably higher. Ycu see what i 19 I mean? a 20 Q Just/ minuto. 21 A today when you're saying -- 22 0 Whan we turn off ccm-sone, we write off tho 23 debt. Wo don't collect it ca a result of turning it off, o4
~ do we?
/~T %-) 25 A Decause you're getting increases hero based on i i
Fahey-cross 1793 1 the fact you have all those uncollectibles that you didn't O collect, then right after you got your increase, you go out 3
- sud turn off those people, and on top /it we're paying you 4
for these people that suppossdly did not pay. 5 6 7 8 9 10 i
! 11 I i
I' l i 3 3 O: i ia 14 ! i , i l 15 l 16 I l 17 18l l l 19 i 20 21 22 j; 4 23[ I, I 24] 0- 25 " h i
I 7? Cabay-cross 1799.* I Q Le 's :;et so we undaratand each other. Ycts .. O V 2 understand when we tu n off scuebody, it's becauce we have 3 no: collected the ncney. 4 A That's correct, and that's an uncallectable; 5 carrecc. 6 4 liow, when we turn sancone on, dcn't ycu think 7 it's reasenable :hac we 3et paid f : the rarney that ic owed 8 na cr accc indicatica that we cre coing te gat paid shca 9 ue st .:t giving pcuer ta thic cuctcent again? 10 A Dcn't I thick that --
-i i
Il Q I'd bc glad to ict you caswr aay explanation, ; r 12 g but first cnswer my qucntion. ; O! 3 14 Don't 7cu tht=h ta=t tr 7cu ucre r=n=t=c thi> i Ccr.peny and ycu hud scncene, for :hatever reasen, who was d 15 i g nat receiving a acrvice and new requested service again, t 16 that you would cck fer payrent before ' jeu rectored servica? 17 Do you think that's unreasonabla? 18 A That's definitely unrcasonable. 19 Q Unreasonabic. 20 A It's unrencenable. You inicu phy? Becauce yoJ 21 have entirely, in this instance, ycu.hnvc entirely tco high 22 billa. Wat's why they vers turned off; they're not afford-23 able. 24 p y 3ut that poucr that's being prcvided for that V 25 person for which they' 2 nec get:ing paid is being paid for
I Fchey-crosa 1300. ! I by the other consuncrs, isn't that soi , O V I 2 A And then ;uess what? You cc:ao here today , 3 again and you put it down as uncollectable and guaranteed, , 4 after this increase is 3rcated, you'll go and shut off a 5 few acro people and collect your uncollectabica, get ycur 6 high deposit money, plua ycur increase. 7 Q Are you cuare thac there is a law in the State 8 of New Jersey that cskan it a crine to obtain property, in-9 cluding power, under false pretenses? 10 A Under false pretenses, sure. j 11 Q You said before that anything that's done 12 g should be dcne according to law. Didn't ycu say that? ' O: ^ ca=rece-I4 Q Uculd ycu cenaider it impreper for canconc to 15 obtain the rencuni of electric corvice by a representation 16 that they're going to pay shen they do rot have the inton-I7 tien to echo that paynent? 18 A Uell, it depends on how much and I think I 19 answered this before, and how much of a depeait, you kncv, 90 are ne discusaing here and --
l Q Ie.t's accuac that, for the uke of argunent, ,
t 22 the Public Utility Cctriission cays that before servico is i 23 to be restored, you're suppocod to provide X-dollars, and 24 4 in order to got that servica, this particular party issues , ' 05 a chech for X-dollars and than stops payaent on that check. l l
Fahey-cross 1801. I fJauld you consicar that ImproperI ( 2 A Like I did? 3 Q Pardon act 4 A 1 did that. 5 y You did that? 12id you do that both in to:=a 6 of your deposit and in te us of cho pay ent for pact-che 7 cerytces? i 8 A i stopped peytaent en can of 1r/ checke beenuse 9 I uac not -- I was denied due procesa of lew Ond 1 did not 10 have an itemized bill. I { 11 Q hhen you asked for service to be raatared, l ~ i 72u did so with the intentien that check uculd be stopped?
' 13
'S. F M dLLI: Cbjection, Judy: Itar:; hall.
14 g Ihis is a hearing en a race increcue and ue new sce::t d 15 g to be moving in an atte.pt to pronecute Miss Fahey 16 for an alleged thing she v.27 or .27 no: h wa dane. 17 1 don't think ua rhould be allctred to purnus 18 this area of percenal behavior. I would carcainly 19 vant to give Mics Fahey warning of har con titutional
'O
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righcs before she proceeds, and I al=o don't thinh 21 it's proper for us to go into this percenal =attor no
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at a hearing on a rata increase.
- 72. KIESTS
- 1his witncss hus on acvcr.21
! 24
,_ occasions accused this Cc gr.ny of inprcper conduct l' ( 25 in the canner in which they collect accounts, 4
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]
Fahey-cross -1802. ' I particularly with respect to security depeaits. ,
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2 Indcod, she has repeated that today. She said they - 3 use this m0ccy ingroperly. . 4 I think that her conduce goes directly to the 5 ,etcht of her testhsony e.d *incther it should bc 6 considered to hevo cny validity at all. i 7 Indcod, if anyone he:: acted heyrcperly,1
- 8
' think by liisc Fahny's ov:n teatf.can7, it is she.
9 New, I think that the is misleading t.% public 10 2nd this Cce:1.a:tien bf her cenduct.
- 11 DM WITNESS: /,tthis ceint I uculd 11ka to
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12 l g defend nyaelf. Your Cergany -- ::ce, vi at happened, I3 l 1
, Mr. Tiraten, we that I placed cyscif in the position 14 j of a custecer coing dcyn and van trying, t2 enter j 15 into a reascnable deferred paynent --
16 I!A. KIRSTEN: Tccre's Scen un objectien made 17
'oy Mr. Nardelli and I'm 4aiting fe: a rulirg. I's 18 raiting for a ruling from His IIcr.or. -
19 1 i 20 I 21 x r 22 t i 23 24 n V 25
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Fchey-cro00 1803 , 1 JUDCE MARSHALL: I think it might be m 2 to your benefit just to, sines ycu don't havo 3 a lawyer here, to adviss you of ycur full 4 Tifth Anondnent rights. 5 It 3:ight be best to cut this questioning i 6 shorter and it is also well noted there are f several other no bers of the audience who have !
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7 8 addressed a wish to cpoak. 9; Mn. K!rcTE3: I will withdraw ths quos j I l 10 tion, i i !
!I HR MAROSLLI: Ev3rything is b3ing l 1 ; 12 l transcribad and Oculd be concsivsbly used l
O; 13 ssgainst you at a lator tica. V ; a i i 14l It =ight be in your best intersat not 15 ' to prcceed with this until you have a chanes 9 f I 16 to give it Ar2 thought and censult an l i i 17 l attorney. ! 18 i Tnc iTITn2SS: Okay, 19 MR. KI2STZN Thank you. 20 JUDG3 MARS"?,LL: Thank you very much. 21 MR. !TARDELLI Mrs. Valeria Walch. 22 VAL 2RI3 If A L 3 D, 1329 3ay Avenue, Toms River, i 23 tiew Jersey, appearing as a public witnnss, being l II 24 duly awcrn, testified as follows: Ov 25 THE WITNESS: I'm here basically cn l
Welch 1004 I e more personal basis because of things
- hat n
2l had happened to me as a custccer. I 1,i uow, I an not denying I didn't owe any 4 money, there 's : o denying it. 5 Coing into ancther home, buying another 6 home, you have to have electricity, so you do 7 try to make pcytonts or the best you can because l 8 ycu knew you havo to have it turned on again ! 9 anyway. lot 10 Where we lived beforo, ws had n/of l 3 l j 11 p; chloro paying it. 111th having a high cil j
- was ;
12 I bill and high electric, it/just what do you 13 have, one or the other, either oil or the I electric, and wo picked oil. 14 l E 15 We han threo children. Anyvny, when ir ! 16 l we noved. into our new heca, we did have a bill j 17 e d no wanted to pay for it, but before that i 18 evan got out of our mouth, 0400 deposit, 19 ! right off the bat, they say we're a credit l 20 riak. l 21 My husband vent into the offico and - l l 22 a man walked in, didn't ovan knew his name, ! J l 23 3 and he said I would like electricity put on l j i 21j to e,y hons, and the can said or the manager ! O o
-- r, 1 i said, whatsysr, well, thers will be a 3400
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t I Malah 180s ; i
! ,seposit riease, i O- 2 So, whet.her it's a credit risk or not, i
[ 4 3 ' what's the reasen for this. 4 If there is other people with bad debts, 5 fino, but what about when you : rove in a house a d 6 finally you wait all your lifo to get what you i 7 vant, you have to support three children, and 1 8 you have to put $400 out plea your bill. 3 1 9 That I'm not denying. Okay, f i 10 ! It got to a point whare they ahut u's II off. He didn't unt any billa and they said I 12 g hocause wo did not give then 0400, we're not Oi . 1 a con 1'iered a custo=e= a d we'== ueine their I4 i i clectric illegally or without their paraission. I { 15 l Mayba va voro, but we didn't knew where to . I
~ ! l 16 ' turn.
17 tie couldn't put out $400 plus 200 18 comething, which is in excess of alnost 19 0700. i I 20 ! So then I said I'm going to go to l 21 court. I have to pay $25 to DPU. On top 22 of it, I put out $162 to get it turnsd ca, 23 okay, a nd I paid BPU $25, and a week before l i 24 I come to court, what do I get in the mali 25 l but five bills in a row.
i Walsh 1806 f i I Defore I got no bills, I was not con-2 sidered a customer, but I got five bills. 3 Plus, when they shut r4 off, they didn't even f 4 warn us becsuas I wasn't considersd a custor:,er. - 5 llow, va made agreements with these 6 people, with the electric company to pay them. 7 okay, we ' re doing it, but they're killing us. 8 tia're paying 075 plus back bills. It's running 9 in excess of $125 to $155 a month. 10 ' g 11 12 O!3 14 ! 15 - 2 > 16 l t I : t
. 17 ! ,
18 19 i 20 21 22 23 !.i h i 24 ; O 2s " 4
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G Ualsh- 1807, 1 ng '.J1'l:::dS: (Con muing.) licu , thic ;uat . (s7 2 su:a2er w used our air conci icning thrce days and 3 cur bill was V9'). Me cvca turned off '.he het uncer 4 heater su chat we ucralda'c hase cn e.:tra bill. 4 5 of now, :o this date, uc do not have any oil in cur 6 bcuse. We don't know when the heck we're goins to -- what are we going to do? l 8 ' 1 weke up this norning and it was 43 degrees in the house. I cm not crying poor-x uth or any-thing, ey husband haa got c job. Uo are not -- Ne
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11 j can't collect any kind of help. Uc can't 3ct any l j subaidy because we are not pocr. We can't get a - qa 13 bj ruSaidy becauce ve are not old, ycc they say, you ! i 14 i knew, giva us that ncncy, cnd we are doing it. Wo d 15 j are doing it by law, exactly what they are telling r 16 us to do, and at the same ti:ae uc are not en::ing 17 properly and just to take tr.atters worse, ue vera 18 rahbed Friday in cur hone, Juat to nahu it an incul4 19
- o injury, and there is no placo that we enn turn to 20 anybody beenusa we are the middic person.
21 So, when we finally did cece to the CFJ, 1 22 told ycu I paid $25, and uhen I asked clus shculd 1 23 have a lauyer to help =c, th27 said no, that's not 24 -Q really necessary, this is :n inforual hearin:;. Chy, so when we walked in the dcor, there was JCPSL'.s I
Walah- 1808. I businces canager, his two associates, and his lawyer. 2 Ilo, we didn't need any lawyer, we didn't need 3 eny help, and there was the BFU representative trying. 4 to help us. Their iden uns, well, if this goes to 5 court, 1 don't think it would be a good idea; you 6 would have to put a lot of money out, and we were 7 scared because uc had nobody to protect us, and we 8 could be totally right or we could be totally wrong, 9 but at least to have scmebody there represent us, nad 10 we didn't have anybody. g 1I I ashnd if there was sonchody there that could 5 12 represent us and they said no. The 32U said they O! had ==dod 7 . eo cha='a use== vour coasta=er==== see f I4 l nway with hurting people lika this. f 15 So far, since the middle of August, we have
! l 16 ande a 162 pay:ent to turn on, $11 connection fee, l 17 $25 to the '37U, 430 locc in a day's pay for my hus-I8 band to coma down here, $126 for the first month's 19 payment, uc cade an arrange:nent, and that came to 90 4404, a $150 depocit that we still haven't made be-91 cause 1 don't kncu vhere I can get the coney fer
'2 thnc.
'3 llow it started at a $400 deposit and then it o4 n
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went to $240, and then down to $150. This shows you l U 95
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l how confusing their policy is. They can just up it I
Walch- 1E09. f I, when they unnt and dom. When they tent. I am 31 :d : f3 , b) 2 that they took it down to S150. But, I really think ; 3 that's too c.rch, and I Istow that there are peepic ' 4 sito are taking up the ? lack fer the other people -#ao ! t 5 didn't pay, and just beccuse these peepic didn't pay, 6 uhy should I nuffer? I tried to naho arrangccents 7 with those pceplo to try to pay off cy bill, tut 1 8 couldn't. They didn't want to hen all that. 9 I l.nvo got thrae littic kids at Lccc that ara 10 hungry, and that's the truth. Thef are really hungry. k II 1 am not pulling anybod7's leg. L::t aight I had l'
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i macaroni and checsc, two benes for five peepic. !!aw 13 {- do you tell acy kids that, l':a sorry, thnt's all we (vQ : , . 14 r i have got, and your husband verka for a utility. 5 15 g No i, I ara cold , too . My hide are celd. 1 r 16 had to put three blankets on ny baby last night and i 17 fcur on my husband and I heause ve httd thin anc.-i, 18 l but that's uhnt happent. Ycu have vt ycur ccnglerer-19 atos and these .Tays that hva got all the answern, 20 and then there is peop12 lihn us :ho are tryin~ ve2ry 21 ' y 'hard to work it out and neNdy vill give then a
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cecond chanco. That's cli I have to cay. 23 MR. K1RSTE!: May I have your addreas, piense? g 24ll TliE WITIiESS: 1329 3ay Avenue, Tcas Eiver, V 25 i New Jersey. I
Ualsh- 1810. I There is one other thing. I have got these O 2 Iisa tilla cud ansia I ra considered not a customer 3 Lad I hrve got five bills, and now I am paying 9972 4 plua 75, U2 plus 73, 3067 plus 57, 7758 plua 75, 5 7933 plus 73. 6 it.2. 112..iT G : .uy i see those bills, please? 7 Ill ' ini;:/o.3: And not to mention that the 8 peaple aren't very nice when you talk to them, 9 einhor. '/aca ny husband went down to the office to 10 r.iha soaa acrandc.enca, the man do m there looked i
! 11 ) ae q hu.abraa liir.e, why don't you pay your bill, 12 l
; dr. :lalahl Coca ou, Mr. Ualsh, why don't you pay O l"
'3 !
j C.sc. o b".lls, and ucas. of these -- they don't know j 14l j l ena: problo2.; we ham witn cur lives, and then that
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j ! s u makes it clear to my nusScud, ha nakes it clear I 16 I thac :ay husi:anu tore or leen was a "deadbest," and 17 ue are noc. We cun a hcce. We have a car. We havo 18 19 tuo cars und un are telling one now. We can't afford to keep ic up. 20 So, i chlak scambody better do scmething and 21 help chcse pespin c1.t are oicher going to die frca 22 noc having enough oil to keep var:a or they are going to dio crc 2 atarvacion. Titac's all I have to say. 24 O 25 1
. Slotf 131; m
Il M R . 11 M D E L L I : Miss Kiitherir.e Sloff, b 2 please. [ 3 K A T II E R I U U C L 0 F T, sworn as a public witnous, l f i t i 4 testified as followa: j 5 Tan cTrt:cott;&nna Please st2te your i I 6l name and nddross for the record. 7 TIIE WIT: CSS: Katherine Sloff, 10 8 Silver Creek Lane, Silverton, !Tc.*i Jorcoy. 9 , Hs11, I am hero becauso va are hurting. 10 My husband and I are rstirod, and wo are living 11 l in 40 years back according to the aituation 12 8 i that JCPSL has caused us. ' p ; 13 ' I am on disability. !!y husband is kJ a i i 14 ; retired. We have to cut devn on food. U3 j 15 ' havo to cut down en cedical hills and we can't j i i i 16 i do any washing. 17 Last year -- I haven' '. ucsd ths unchinJ 18 nachine but twice since we moved, anc' thnt was 19 a year ago in October. And, we hava baan 20 away, well, I'd say about four =onths of that 21 ; time, but we still got high olectric bills 22 to the affect whero we have to cut dcwn en 23 g food, essentials, codical bills. 4 24 I haven't been to a dcctor 21.00 January /^\ V 25 with ny problem, which I cannot afford, and j i o I l l
Sloff 1312 I ites just tsrrible. IM thought we wculd retirs 2 and have an oasis: life, but it's not that way. 3 We find that we can't afford different things, 4 and va just have to stay hond, vt have to livs 5 like hern.its which is disgraceful to the senior like 6 citisens. And, J.t's just tscrible to live / thia.' 7 A $155 alactric bill which ws can't afford, 8 we are en fixed incomes. Whers ws lived before, i 9 our bill was $75 -- $75 during the wintor and 10 ~
$36.38 during the su::.er, and new vs ce=0 to 11
- a placs lika this whars JCN L is just taking 12 avorything out of our lifo. They cight as O; '
weit serr u= dec ==e == ere cotae *o aio or i
; 14 cold.
1 l i 15 ! No alapt is alcaping bags on tha living ! i: ! 16 i l roo:a fl or last year bocacae ne shut off the ! l t 17 cthar bodrocca and had just the bath, this 18 roca and the kitchen and the living room that 19 was heated. I 20 when my kids would cone up they would 21 any, what happened to you? What happened here? i a 22 l And I just said, well, this is the way we have 23 fj to live becauco our incera does not allow us i
!I i 24 to live any other way, and I think it's y a i
25 ter.1blo what they aro doing to the senior l I
1
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01cff f, 1813 I 4
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, j citiasns.
<m k- 2 That's ell I have to acy.
t 3 MR. 7I 13TTI: thy I hava ycur adtiress, { 4 P1 "U'07 5 TW !!ING : 10 Silvor Cr>.*sk Lane, j 6 Silverton, Jaw Jtracy. 7 d3. i(IR3T;;1: Ia the account in your 8 nace or your husband's name? 9 ':12 't1T.i233 : In ny name. 10 ::E. KI2.;TP!: Thank you. .
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$ 11 JUDG3 :n23 HALL: 1 hank you.
I ! I 212 . JAR 3::LLI: Mr. Donald Dmita. 12 l 4 13 I A VOICn; Ec said ha wculd be right - (~)%
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J e -l ; 11 j 14 , back. t s 15 MR. ?!.i n C C L L I : Then ho can spaak later. i 16 i
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I don' t see the first nane here and I Icn't 17 knew whether this is a lir. or a }das Blanchard. I I 18 i A :1 ! 3 L A il C !! A R D, cacrn an a public witn033, testifics , 19 as folicws: 20 Ti3 JIT12S3s :4y name is Ann Dianchard,, 3 og 2116 elew Street, Toms River.
~ j 22 We the people of the Paople Utility-Fight .
t i 23 , faol the rates of the energy adjustrent charge ;
; i 24 13 horrandous dus to the poor misninagement of 25 JCP&L. The working peopla do not get raisea i
i
Llanchard 1814 I in their salaries as of ten as JCP&L raises 2 cur energy charge which brings a hardship 3 to many customers. Since this Chras Mile 4 Island mistaha, we the people are oaying a 5 ridiculous enargy adjustrent charge which is 6 really getting our of hand. If nuclear power 7 is want we need, then why take ao long to get 8 oyster Creek in dew Jersey repairod? The 9 longer it is shut dcwn, the nora the peoplo 10 have to pay which again is horrandous. i
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11 JC?LL Jo far haa pu:rped 5 million
, 12 . gallens of water, fresh drinking vacar, into 3 8 3 /~3 3 13 the Barnegat 3cy. Apparently the wells that \J =
r 14
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. the people hava in that area u111 be running 15 j dry and they still vill bopunging frash water j
16 wit.) and 1 caving the pecplo who have tne wolla/the f 17 possibility of not having any water. This is I 18 another incident of poor mirranagement of which 19 JCP&L and a vaste of our waterfis a naturval 20 resource. 21 This water could b) easily used to 22 generato power in tho most economical and jI 23y inexpensive means. Unfortunately, the coat ! 24 d la not intentional or there is no way to -- () 25 wall, thereforo, tas initial cost would not I
alanchard 1815 , l i enable JCP&L to milk our pockets and it would 2 not be conducive to a conglocerata in c utility monopoly such as JCP&L. I also think that all of the deposit a mency chsuld ba laft in sacrow and not be used by JC2&L to pay thGir dGhtS. 7 I also feel that the ratspayers have 8 been paying an exorbitant a= cunt for deposits. 9 I think I have covered everything that i I wanted to say, j IIR. KIMTEN:
- II May I ask cao question?
i 12 i l CRO33 EXA}iINATION i ' O:. 13 : '" *" "'"'""' g' O tihen you say if nuclaar power is what wa need ! 1 d 15 ; in respect to Cyster Creak, would you as a ratepayer of i i i t 16 l Jersey Contral Pcwor and Light be in favor of but. ding anothed nuclear station at cyats: Creek, in order to reduce your i electric bills? A Hot if it's :nismanaged. 9 Q I &M 30t SuggSating that. q I am trying to stick to your statement,
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22 that if nuclear power wasthat we need -- are you suggesting, I 23yassuming good :tanagement, of assuming an offective nuclear sta-24y tion, are you in favor /Eilding another nuclear station at ~ 25 }(rfstar Crack 7 l [
t
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31anchard-cross 1816 ! i i 1 A .ioll, if that's th2 only uny you people can O 2 get our pcwar from. I .ean, what other resources have wn l i t 3 90t? I i j -4 MR. KIlGTEN s All right, thank you. a l
; i 1
l 5 JUDCC ?!AR311ALL Ihank you very much. l i I 6 t a 7 l, i 8 ' 1 i I 10 1 .
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i l1 l 1 : I ! 12 O :. w'
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i 16 l 17 i, l 18 i i n 19 ' l 20 : i 4
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21 l 1 22 s ( { 23 i t l; I ! l l l 25 - i l l il l i
l
. Kirby 1017 !
I l b 1 Mn. NARDELLI: Ms. Ilizabeth airby. , 2 C L I Z A3 TU K I 3 3 Y, sworn as a public witness, , 3 tastifios as follows: 4 TUE S"CU0CRAPME2 Pleaso state your 5 full na.:n and address for the record. 6 THC UITUL53: Elizabeth 1:irby, 31 7 Pers1ng Place, Xeyport, !!ew Jezsey. 8 I s d like to taank the Court for per-I 9 mission to speak and I would also like to 10 aay to you, young msn, you are doing a great i j 11 j jcb. It's good to JCC our young p?opla
, 12 fighting for us.
3 () 13 Fe are frustrated, and when I say a i 4
; 14 we, I as speaking of the residents of !!cnn.outh 5 15 County, the reside.nts of X*yport.
i: 16 l A few ninutos ago you said that when 17 you sign a centract for the purchano of power 18 from JCP&L you do it in good faith. This is 19 l Very true, we do it in good falta. I 20 l> Last year my energy charge for January 21 was $1.64. This year my energy -- and, by 22 the way, the bill was $36 and something in 23 , January,'70, and this year it was $03.73, 24 and tha energy charge was $26.71, and that's t 95
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fron 01.G4 in one year; now, that's a high l l l
i t I r.irby 1813 [ e t 1' jump, and I didn't expect when I contractad [ O' 2 with JCP&L to pay such nn incr+3se. I 3 I had my lights turned off en my own i 4 doing by holding back my energy charga for I l i 5 the last four months, Iputitaway,butIdidl ! 6 so to try to toll you peoplo that we are tired 7 of payLng for errors. 8 I maan, you ha';e had Oyster Creek -- ny i 9, husband worked on it 12 years ago, building i 10 it, and it has not been in operation, I would 5 11 i say, half of tho -- I meca, how cany years i !
, 12 l has it actually -- total years has it been ! i
() ; 13
,1 operating to give um pewor?
l 14 'f ot you are asking to build another ' 5 15 ! nuclear plant. If you can't run the cno that i ! 5 16 l you have, hev can you run a new one? t 17 And, I am not opposed to nuclear power, 18 I no. ! 19 I haverare in ny possessicn a resolution 20 drawn by tha0brcuch of Xeyport. I don ' t know 21 whether the Advocate's office has a copy, but 22 this was drawn up cu Itay 6, 1980, and I 23[ could send one to the PUc, where they ars 24 opposed to any increase until the audit in C^) i 25 i 'done, the final audit. I would lika to present. i
i Kirby 1819 1 this to the Court, if I may, sir. b) v 2 JUDGU !:ARSHALL: Okay. I will taka 3 official notics that this resolution has an 4 identification nu=ber of 106-80. It is now 5 included in the record of the case. also 6 THE WITNESS: Thank you. I/have in my 7 possession, if the Court would allow me, with 8 your per=issica, a patition signed by the 9 citizens of Monmouth County and a copy of this 10 was sent to Govsnor of New Jersey, Drenden T. 11 aryno; sonator Harrisen :fillians: Senator Bill e i l i 12 Bradley; Congressman Frank Thomp3cn; Assenblynau O 13 i aion==a va=x e=er> ^==emstv=== w111t2:= 71r==> k 14 l and tha ?iayor and Council, Dorcugh of Kayport, i i d 15 l and the Doard of Chosen 7recholders. There is f E 16 I I also a petition frco the residenta of Xayport I ' 17 which I would like to -- they are asking that 18 , senathing he done to halp us, and I would like 19 to present this to the Court also. I 20 JUDGE ffARSHALL: Okay. I will take 21 { official notico cf the petition and the first 22 ons which is dated the 19th of May 1930 and h 23 L the second one of which has an identification 0 f 1 24 g date of May 8,1980. x.) > 25 THE WITNESS: I would also like to say
Kirby 1820 I that when the ccapany's representativo, "Jecrgs 2 Metzger, a spokesesn for Jersey Osntral, whors > 3 he criticized -- nou, I am not a ra:ther of 4 PUF, and I will say that they ara working hard 5 at sorething they believe in, and those ara l 6 people who are verking hard to correct sons- ! l 7 thing which they foci ve have a problem with, 8 and I resent tho statements T.ade that he said 9 that their action: "go against the foundation 10 on which thic society is built". I recent
- 11 , .-- th a t .~ I feel that's a threat that we should 2
i
; 12 l keep our truths chut.
13 I kncv cany people fool this tray. i i j I4[ I also feel right ncy that we are faced with 5
, 15 l a monopoly.
i l 16 l I feel it's a type of r.cnopoly to ths 17 ! extent that we are not consumerz, wo cannot I 18 purchase, we cannot shop cround to purch:ce 19 our power at anothar place. I don 't know the 20 solution tc this. 21 I I a:a a lay person. Many of us in the ' 22 county are lay persons, and we cxmot suggest, 23 we don't know, but wa are asking that wa be i O 24 taken into considerar1on. Wo.are older and V ' 25 we are getting still older looking for a i
Kirby 1821 - i l ~ retirer,ent, and I don't wmt to have to live l O 2 in faar of having to nove into a senior citi-3 zens ' building away from ny fxnilies. I don't ! t 4 want to live in fear of not being able to cover ; l 5 sy ccanitr.ents. ; 6 I have nothing more to say, L 7 l 8 ' 9 ' r
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11
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1 ?. 4 O; ! I 14 l I k i 15 . t I i
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16 L 17 18 l 1 19 r 20 ; i i 21 ! 22 [ l l 23 I I ! 24 a O ,> .
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8 F _ _ _ _ _ _ _ _ _ _ . _ , ___ . , , . ,m_ - - _ , - - . . - - - m _ . _ _ _ .__,. - __ ____-_ , _ , _ . ,
4G n Kirby-creas l 1 i CROSS-EXR4INATION 1822.! i 2! 3 I ny tc, gL".syzI;; J 3 Q ::7 ,
\ y 4 :c,1g , .jou :.c:itioned in .Iar.uary 1979 j, your energy charge 1.cc fl.04. '
5 A Pight. 6I 1 Q 7 Do you incu that cha reason t. hat it was so 8 1:w van that t.t chc ti= .;asey Lencral haa the benefit of 9' three cucicar p:mer cea: Lens and thac cncrcy ic very loa cae cost of that 10 So jou ruccgilae t. hat?
- A i Il I r.n aorry, I .'ca't we why we have to pay
- for that anargy at all.
12 i I don't set d y ve hrwo to pay you
. to fir 2 13 sur clectricit/.
iha ac.sc thi.n3 1.s you uculd sant pd, 14 j} uJ to pay the fa:=ar for the ::.nture to grew his i planta, for the starcowner to 1.5 .
=
15 lI cnd to - - as La tha store to purcunse our 3codug i 16 i j Q k'c11, v 17 l aan feu go to tta store ounce to pur- l t 18 chase the goods, do you have tc pcy fer thc=? ' A J
' a pay for che scods. l 19 l s Q
20 tind then we huy t, coda to provide we have to pay for it. power to you, 21 A 22 You are a busineaa. Yau cock rhia upon your-23 acif when ycu contracted for -- I Q 24 I And then '.inen we would sail it to you
, wo p
25 veuld have to get paid for it by yc:u, wculdn't we7 J A For tha: 1 is.ve u::.:d, not for what you have t
K Lrby-crer.r 1323. 1 1 cluded in =y costs. om.n, that's your fault. U,, 2 g f=g tgnt 7,u were using in January of 1979 was 3 low-cont nucicar ge nr. " net y7u're using in January 1930 4 You recognize that, was higher-cost ceal and oil power. 5 that that la the reason that there t.m that big difference? 6
.\ l '.crm -4.at ycu are caying.
7 Q Hau, ym: indicated that in response, I think, 8 to the previous witacas 22t you vare not opposed to nucicar 9 power but the: 7ou era c meeme:1 sith our ability to cupply ' 10 . . ..
. .r.:c i:1 ;cuer. -1 sue -I.u c you --
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- 1. Z:st's ::r200.
12 A i. 1 70 7:n ".:: m: that the first cces:creial nucicar U "y 13 pets station in th: :crid una built and operated by Jersey 14 e . - .
~catra.i t,cuer a L:.c;tt i,capany.,
s d 15 , 5 l i Eir, that =c.y be co, but they didn't say that
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16 Jtv.: '.mm? how to --- 17 Q Y:n arc nar cpposed to listening to quacks cnd in =aking judp: cats, are ym:? 19 A 5:, I am cat. 20 s tid ycu know sica y:n c:me to that conclusion 21
- .: "; Jersey Wncr ti Pouer a Light Ccepany was the first to .
22 build anel a,Nrcte a cc.:nercial nucicar power station in the 23 uorld? Did ycu lnc.: that? o 24 V A 'Ibct's grect. 25 I "
; rid ycu knew that that station, Oyster Creek,
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k 1;irby-cross 1824. j I has been opera ing since Decembcr of 1969 and it has one of I f3 V 2 the best on-line re. cords of any nucles power station in 3 the United States? ! 4 A Well, these are your - ycu arc <iuocing, ycu ; 5 I are saying this under oath, 1 presu=c, tiso. ( 6 Q I a:a asking you if y:n kncu that.
- 7 A I don't 'aiow if it is -- nell, this is a fact? l 8 I Q Yes; and co you knew that in January 1979, '
9 over 50 percent of the power that Jersey Central una aupply- 1 ing you was cocting fron nuclear pcwor stations which Jersey
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11 j Central ouns and operated? T.co you knew thett i A No, I didn't know that. /7 I 13 V j Q And do you know that those staticas operate i 14 I with sese of the highest on-lino and maintenanco recorda of d 15 g any power stations in the Uni:ed States? 16 A You are talking nuclear, now? 17 Q Yes, ma'aa. 18 A Okay. 19 y So, that knowing that, wculd you say that 20 Jersey Central I'ower & Lid ht ha3 Proven by its record its 21 ability to operate nucicar power staticas officiently? 22 A Not in licu of what has happened. 23 Q Not in lieu of what has happened in respect 24 O 25 to the Thue d'; . acident? A And all of the nucher of ti=os that Cyster
l'-trby-cros s 1825. I Creek has been chut down. No, I do not. \-) 2 Q Co you have any knowledge of the reasons for 3 -Ac accident at Three Mile Ialand or the reasons for the 4 Oyster Crack abutdcun in recent conths? 5 A Other than what I read, no. 6 Do you know that therc'has been extensive in-4 7 vcatigationa by the President's Ccc=iasion, by the Congress, ) 8 by the 12C, and by others in respect to the accident at 9 Three Mile Island? 10
.\ Yes, I realice this is going on.
i i II Q llave ycu read those reports or have you familiar-bed ycurcelf at all ith the conclusiene of those investi-O 13 kJ .! gations7 I i 14 l A 3cm . 15 3 Q Ms. Kirby, are you auare that half of tha I 16 power that cones frc:a tha Three Mile Island station, which 17 includan two unita, wculd cece frca Unit No. 17 You are 18 aware of chat? 19 A Yea, I am. Is that our unit, by the way? 20 Q Jersey Central has the name interest, 25 per-21 cent, in that unit as they have in Unit No. 2. 22 A Bu*:, Unit No. 2 was functioning properly but 23 it was shut down because of schooling. o4
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o) i 0 No, n u have it reversed. Unit No. 2 had the 25 ' cecident. Unit Mo. 1 is the one that has not been allowed l .
Kirby-cross 1026. I to restart, but it uss not effected by the seeident. U 2 A Because it's on the scue coolinr, syste=, then? 3 Q Fo, bect.use it's On the snue sitt , I assumo. 4 A You asswte? Tcu fea': kncu dcfinitcly? 5 Q Because there are rentart hearings going on 6 right now, and you are au2:e chte the unit is in cc way 7 connected phyaically tith Uait No. 2; it's junt that it's 8 on the same site? 9 A Wait a minute. Ycu didn't answer me as to 10
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the reason why it really was shut down. 11 i Q l can answer the reason, if ycu'd give ne a i chance. I am not testifying. I ou cu;f,cating to you that
. the fact is that the caly rco:Icn Unit 2!c. 2 is .not --
i 14 i,.
, Unit No.1 is not worki:L3 is because the h?O has not per-3 15 g
mitted Metropolitan Edison to rectart that unit, that they 16 are in the midst of restart proceedings nou. Are you aware 17 of that? 18 A Yes, I heard that. 19 Q So that the availability of at least one-half 20 of the power frem that total T11 unit is beinF, cenied Iersey 21 Central ratepayers solely because of E C restrictions. 22 A May I ask you maething? Is Pennsylvania 23 part of this nuclear plant? 24 f') 25 Q It is in Pennsylvania. A Is it part of -- do they draw frem it? l l
I Kirby-croas - 1827. 1 Q OE couroc. 1 2 A Then why are their racepayors -- why do they t 3 not have to p.2y the increase for the :nistake at Three Mile i 4 Island we in New Jeracy have to? Is this fair to Jersey 5 residents? Again, wo are getting it. 6 7 8 9 I 10 2 f
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p Kirny-crcaa 1823 i 1 Q Mrs. :;1rby, the burden, if any, of ths rMI O , plants would fall en all of tha cernors equally, Jersey Con-3 tral has 23 percent of it. :etropolitin Idison has 50 per-4 cent of it and Pennsylvania 1:loctric has 25 percent of it. 5 But, tha deta;;rination of how thoco burtjens would be assesced 6 has not been determined aither by Pennsylvania or New Jersey 7 as of yet. Right ncy, !!ra. %irby, there is no part of the 8 cost of TMI-l or Til:-2 in your rates. 9 MR. MAED!*LLI: You mean the cleanup 10 coats.
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!!2. XIMTEN: Mo part of the cost.
2 1 12 HR. NARD 3LLI: tiell, certainly the C, j 13 repiscament cost of the power noodsd to
.: :l I4 l- i replace tho daraged plant is in the rats.
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; la I :ta. XI33T2N: I'm sorry, nr. Hardslli, j
+
r 16 i bur it may bo a cattor of semantics because 17 they are paying for power which is required 18 becauss we don'e havs T:!I. T:!I costs are ! 19 ' not included in your ratos. 20 Q Do you understand that? 21 A 30, I don't agree. Again, I have to agres 22 wit:h thaty2ung gentleman thers. It is not part -- it's part 23 because you are forcsd to purchasa your power and you cannot 24 servies to without purchasing your pcwcr. g d 25 Q The power that we are purchasing is not from I i
Kirby-cross 1820 I l 1 TMI, it's, because we fea't hsve IIII. O ; 2l 3 tr.d:rstand the.t. I fully underocand that, 1 3 but you are forced to purchasa -- 4 Q Mrs. Kirby, a:;o ycu saying the ycu do not 5! trant to pay for the pcuer th.it. we nrc required. to give you 6 which is not related to or cor..ing Irca 1:'I, but < cring fro:n 7 other sourcea? Io than your scnition? 8 A Mo, that's not what I mid, May I repeat what 9 I said? I aaid I do not Icot that, wa should have to pay < 10 i an incresso due to tha IL:ce Mila I21and ciataho and that's 11 exactly what wa art { dcIng when you are fcrcod to buy yor.r powar 12 ,13ethara. 13
; Q 2.1:actly, tha t' 3 --
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14 } A 3 scausie of a ni.itaka,
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15 ! l O You cr> cayingthat you want to haw the icw .
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t 16 cost nuoloar pcwar frca 'NI ava113513 to you, is that what j 17 l you are trying to sugg0.st? 18 A What I r.m saying is that it should ba f air to 19 all consumers of the Erno fiIlo Ialand mishap, it should be 20 fair to Pennsylvania and to Jcw Jerrsey residants. 21 Q And you are sugguating, therefore, are you not, 22 that you unne to have lover bl.Hs because you want to havo - 23 available to you nucicar po,ser which provides thcao bills, A 24 gis that right?
\'j i j 25 A Well, you cru pushing nucisar pcuar, and I don't
i Kirby-cross 1830 1 cara how you get your pcVer to ma, buddy, but just got it O , to rs. 3 Q I ttcan, if nuclear ;c.ter i.s mors resconsbie - 4 1 Fcichsver is provan, lot's put it that way, to 5 be the rest reasonable. I nenn, I as taking you to shop 6 around for r.e, but I'm also asking you to do it with goed 7 management. That's what I at: asking for. I don't feel Jersey 8 should pay just lika Pennsylvania is not paying. I think 9 that -- 10 Q I just want you to tnew that wo agros with
; 11 , you completely, and if you stay here to 113 ton to Mr. Raber's 12 tastimony today, he will tell you that it is the pocition of i
O: i
! *ne co= sear **== *ae ca>=se== sc er 11**1e *> **e c=#ou=er j
14lI12 from nuclear power. f 15 ! ;\ Sure. .
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- i 16 l >!3. KI3GTHN Thank you vary. r:uch.
17 CROSS EZNIINATION IS , 37 NR,riAacgLLI: I 19 ' Q lirs. Xirby, may I impose on you for two minutss? 20 Are you aware that in this rata proceedi:g the coreany is 21 ses: ting to havs Thros Mile Island Number 1 put back into its il 22 y rate base and have its customsrs pay a rcturn on that plant 4 il 23 j even though it is not opetrating for the censumsr's bsnsfit? i 24q A Yes, I gathared that today. O 25 Q So, the Advocato has takan the position that i
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, itirby-cross 1031 l, '
1 TMI-l should not go back into rate base Decauce as long as h 2 this plant la not <Jonerating power for cucto.strs, they should j [ 3 not hsve to pay a return en it. May I assu=e you agree with 4 the Public Adyccate's position? 5 A Most cortainly. 6 9 one last thing. You rentioned son.e dif ficultics i 7 with the Oystar Creek plant. 8 iiere you alluding to the fact that the 9 Oyster Creek nuclear plant did not cporate from January 3 of 10 l 1930 to July 20th of 1933, an outage of some seven conths?
! l l
j 11 j A Yes, that vsa onc of th?n, yes. 0 l M2, MABDZLLI: l
, 12 I hava no further ques- ; ! i
(])* L 13 I tions.
) }
i 14 J JDCGC MARSHALL: Thank you very much - i 0 I a 5 15 . for tastifying.
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i r 16 l 113. NARDELLI: l i I!r. Donald Smith. ; i 17 D0NALD S M I T d, sworn as a public vitness, testifies ; t 18 as followa: . I l 19 T'13 S2ENOGRAPHt2: Please state your ! i 20 address for the record. E t l' 21 , T!!S UITl!ESS: 69 Plum Stroet, Tinton ' I 22 Falls, tiew Jorsey. 23[ Your Honor and men and wenon that ara ' 21 present here today, as wo all know, we have
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25 been tau (jht growing up that there is a r.atter l j j l i,
i 2mith 1932 3 I of life, liberty and the pursuit of happiness O 2 but now, today, you see, it appears that it ! 3 should be perhaps life, liberty and the pursuit 4 of sadness. 5 It's a very sad commentary in the way 6 i that things are going, looking at the world li 7 in which we live today, looking at the power 8 brekoro that be and that are trying to dictate 9 1 to us as canauzers the way we are supposed to 10 live, you see. 3
- 11 l And, by dictating to us what they are !
- 4 I
12 ' conotantly doing is thay're trying to drain l () 13 all of our rouources that have been cade i
! 14
- available to us citizens of thona Unitad ,
i i
- r 15 Statan, in tor =s of financo, in terms of !
} j i r 16 j oconocies, and I grant you tho inflation rata l l
17 , has scared, and whatovor raises wa havo sotton, 18 j - our raisen have not kept up with the inflation
! I 19 l rato. I 20 !{cwever, by all means, when we look 21 at our utility billa, and I say this is uncalled 22 l for, and, you aco, to give a good example, in !
l, 23 March of 1979, I paid an adjustment rate of !
"! i g) 24 j 58 cents, okay? %) .
t i 25 N , 9
C 1833 , I mith i I I checked my bill for Merch of 1930, 2 and I paid an adjust:nont rate of $5).55, quite 3 a drscatic increcas, you 300. 4 5 6 7 8 9 10
. 11 e
12 I l
- I i 14 w i
$ 15 ,
16 17 18 19 20 21 , 22 23 24 O 25 l l
I 6G Czith 13S4, i I TdE WIT.iESS: (Continuing.) I as horn O 2 today primarily concerned abcut the adjust- t 3 cent charges that wc arc being, I say, isrced 4 l to pay, on adjuat.r.nt chargc that we don't j 5 i lcno r about, : sally, you aca. We are only 1 1 6 eblo to accep: what cha C apar.y tell us, you 7 1:now, and we have had to pay so cuch, X-accunt 8 of dallars for oil, feu seu, but we have to 9 set an iranised hill that wa paid so cuch for 10 oil and we paid no ruch for envelo,aes, and
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11 ue paid to cuch for 7:perc11pa, and we paid 12 y
- for parhin3 tiehnts, and we paid for the a Presidw.c or the Vice frecident of the Ccepcny
- 14 i ,
to 30 cut to vi::it Tt:huito en a huoiness 15
- ' trip and u::e tha: co an enpenac. Ycu knou 16 uhat I nean, to g bc ch: e 1cvich parties, 17 and so forth, at the enpenso of the cocct::ers.
18 Chay? Ycu ece, acv, T. havo in ny hand 19 several billa, you see. I undcratand after 20 contacting the 32U that the adjust:acn: char 3e 21 beccco legal in October 25th of IMO. Pricr 29~ to the adjuct=ent charge beccuing icgal,1 23 , have centinually been acked to pay cnd 1 paid 94
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f] the adjustment chsr.se; okay? lbw, I'd liko 25 sc=cene to tell se w:s it illegal for an as a
D.aith- 1835. I consuser and other cc.ns=.er using the utility O 2 to have to pay adjustacn charge: ca ;nr ething 3 that has never beca declared legal? 4 And, if this la co, thcu therefore you 5 owc us c.onef, =ncy returned, you see, ca that , 6 adjust:nent charge. 7 !!aw, I :s raising that mesticn. I'd 8 like scacone to ec11 cc. It warn't legal ac 9 of Octcber 25ch of '30 to pa; the adjusterne 10 chargeo, and what happens to the other adjust-k, II nent chargon the.: I puid and also the other 12-
,i sembers in this rcen have paid?
(' '. 13 ( { 12. E S1E3: Are you fiaished with a 14 i .. i your crrant:s
$ 15
- LIE U l T.123S : Tain is the quetition I r 16 a:a raising right now, you ccc.
17
- 12. 12RS*'2:1: Uell, uh7 den't jeu ceu-18 pictc ycur tes:inony and then ue will try to 19 answer it for you.
20 21LE WITS 253: Chy. Then I tea chat 21 looking at the 5111=, there la cu:h a dia-22 crepency in terms of the c= cunt of kilowatta 23 that is uacd as opposed to the e.cnrat of 24 O v uaonies that are being paid; chy7 25 Lc nc cito en enampic herc. ilarch
Smith- 1836j i 1 of 'SO, I paid on adjust:nent charge -- a ' 2 service char y of $39.74 for 715 kilowatts 3 unage, and in April, okay -- czcure me, that 4 uce between Jcnuary 23rd and February 23rd, 5 uhen I paid the $39.74 for the 715 kilowatts 6 used. 7 From February 23 to March 24, I used 8 70'3 kilowatts and paid $39.34. There is such 9 a discrepancy, 715 for 39.75, but only 708 IU for 39.34, and as far as I an concerned, there 11 In no cennistency, yeu see. 1' i ITcw, f ca March 24 to April :.4, I used O:- ia 633 kil:uatts, paid 30.41 for service, but I 14
- % A:ril 24th to May 24th, I used 635 kilo-d 15 g vatts, paid 35.29 -- that's 26, rather, and
- 16 still there is a yeat deal of difference, of 17 variance in the bills; okay?
18 Mou, I c:2 here to find what is going 19 to happen, ycu know. How are ne expected to 20 live? Pcm are wo expected to provide for our 21 f:cilica if we are only going to uork for the oo
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Cetpany, for the utility, you know, you sco. 93 l Scaething han got to be done, you see. o 24 l C 25 Chay, Your Honor. i J1EGE liimSIL4LL: Thank you. F 1; l
Smith-croco L337. , 1 CROSS-C.2111MTIC11 bV 2 gy 1<a, gI;iSTEil: 4 l 3 Q I migh: cay, lir. Sr.ith, you were quite cicquen e i 4 in your ataccuent about the principles of God and ccuatry. , 5 Co ycu also beliwe in a representative d:rceratic govern-6 ment? 7 A Sure, i belicie. 8 Q And to you does tha: teaa that ycu will rely l upcn the deter =inations of your ciccred represen:atives? 10 A Ucil, that all &pcnds. II
! Q You ::ay.o a decision a . to .4uther or ao: ycu j
12 - l will? Io you nean it depends -- that ycu will decide whether
/l V
13 I k { you will or will not acccpt the decisions of tha c:ajority of i i 14 l your elected rcprocentativcc W.cn they are -- 3' 15 g A Just a coct.nt, sir. I~ i didn't elect John
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16 Doa into office, then I ca no: coins to rely on Joha L'oa. 17 1 feel that i uc,uld havo to 3o out and sco what Jchn Occ is 18 doing, to see his record, and then so t, ace Jach John's 19 i l record, and if I did not vote for hin and I don't like hi: 20 principles or his stand on certain things, then, you knou, 21 of cource I am not going to go for it. 22 Ycu ceo, other people hava voted his in, ycu 23 sce, and I dida'c voto for it, you ace, but I fact i:i's cy 24 (]
' right to challenge bl.a. vhocvar it is in office, ycu kna9, 25 in ceras of like whatever.
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Unith-cross - 1838. 1 I Q 2ut you understand that a dcr.ocratic repre ' O 2 sentative society ccana that the majority electediwill be 3 the onen who have the decision-making power and ycu will 4 abide by that decision. Can't that a principle that you 5 uould abide by? 6 A Chay. 7 MR. liA5DELLI: Well, Mr. Smith can 8 also rosarva for himself the right to uork for 9 the defeat of that person who is espousing 10 principles that he disagrees with. f II HR. KIRSTCh I want to understand if , 12-lir. Smith belicves that he in< obliged to abide j b7 the <ecisten ee the =>3eriey. ae uoed the O3 , i 14 ! t term that he was forced, and I wcuder if you E
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.s aro equating the agreement to abide by the j
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! rules of the majority; is that the kind of 17 ,
pressure ne means. Q kb you understand what I mean? 19 $ A Wait a minuto, wait a cinnta. L =ean, are ue 20 here talking about the electricity or uhat politicians that 21 ne get? Are ae talking about primarily about the Jersey o,
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Power Cenpanics2 23 Q '!o, sir, I an asking you as far as your tes-24
') ticony, you vara quite eloquent saying that ycu were forced -
(~J ( 25 7ea said that the power brokers dictate to you and you don't
i l Smith-crons 1333, ; 1 vant to be dictated to,.2nd were you referring to your (uly 2 2 elected goverreent officials dictating to you? 3 A y .,,ill tell you something, sir. If y:u vere . 4 to really -- I aculd really like to see you on the cida to 5 , really tell you shat it's all txuc. .. , 6 i y . 8 4 s 10 i
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U smith-cross 1843 1 0 I would too, sir. /~T I kl 2 h Because right now you have put me in a position ! 3 whereby I don't roally have all the time to, you know, spend 4 taking up your time. 5 I think that it would actually be 6 fruiticas, really, be.cause you are still going to take what-7 cver position you are taking, you see, and, of course, we 8 have got to realiac that you are hired by tha Cor.pany and so 9 forth to reprocent then. and so forth, you see. i l 10 I Now, I haven't been abic to pay ocmsbody i j 11 or whatsvar, to hire them to represent me, you knctr. I mean, e 12 you ucrh for the Company, right? j IS (-}
\/ e Sut, thon I got a letter in my nail fron 14 the Jaracy Contral Powsr s Light Company which la dcwn in 15 ny area, which is located in ned Lank, you ce.e, and of course ,
i: 16 ; tolling ne diat ny service is going to be shut of" as of 17 today because of my failing to pay. You sco, whan I got a 18 bill from then, the bill never says, okay, like you paid the 19 servico, but you cue us for the adjustment. I o, it says 20 it's a bill like you owe ua money, you are delingue.nt in 21 your paynsata, lika I an a criminal, like I am a delinquent 22 in ny paymenta, and that I didn't pay the Ccrpany at all, 23, so anyono 1 coking at this would say, by gally, he's not 24 paying his billa, and yet I have paid for what I used, but 25 they are tolling et that I nave cet to pay then 723 for the. 1
Smith-creas 1841 1 adjustment, and I want to know why they don't tell me that 2 cil coats no much, that they put that down on my bill, you 3 see. ' 4 I mean, if I use something, that's all 5 right, I have to pay for it. That's fine. I will go alcag 6 with that, aco. But, I am Dat telling you that thie whola 7 adjustment thing is nothing but a ripoff and is very loose 8 as far as the law is concernod. 9 The Ccapany, so to speak, have all of 10 um over tho barrol as connu=ars,and you can say you have to i j 11 pay this and you havo to pay that, but hew do wo know? I g 12 lrAan, what do we actually pay for? We really den't knew. I 13 IIR. KIESTE:! That's all the questions 14 I have. 15 :1R.11ARD3III : f I have one quastion. i t 16 DY IG. liA2CLLI I 17 0 fir. Smith, you sro a customer of Jersey Centrnlj IS correct? 19 A That's correct. 20 Q Hero you given a choice as to who you could get 21 your electricity from? 22 Was there an election se to who you could 23 chcono to got your electricity frca? 24 A lio, no. 25 0 You were forced to use Jersey Central as your I
Smith-creac 1842 I provider of electricity? 2 A That's correct. 3 MR. NARDILLI: I have nothing further. 4 JUDGE MARSHALL: TIlank you for your 5 co::::ents . 6 TSB WITNSSG Okay, Your Ecnor. 7 - MR. NARDELLI: Is there anyone else 8 hero who is a nenbar of the public who like 9 to speah? 10 MR. ALBRECHT3 Yes, I would like to
- 11 =nke a few cc=nonts.
e 12 CaIS ALBR3CHT, p cviously sworn, testifion further g (~N j 13 33 go11et,3,
- V I4 Ma. KI23T 3 Mr. Albrecht has been 15 provicualy suorn, Your Honor.
i ! 16 I THE WITNESS: I liva at 18 Golden 17 Lane, Baslet, New Jersey. 18 I hava not cene hora to testify hora 19 today, but I'd like to make a remark, if 20 the Judge permits. 21 I was listening to the testimony and 22 listaning to the praise thnt Mr. K1:stan 23 has been giving the nuclear plants of Jeracy 24 Contral Power and Light Company. The Oyster (s s 25 C:sek plant which he says is such a wonderful I l I i
Albrecht 1843 1 plant, has such a wonderful operation, I have ("i (_) 2 statements that were made by the Nuclear 3 Regulatory Commission that the Oystor Creek i 4 plant is the worst plant of six, that it has l 5 been out as cuch as it has been on1 ' 6 As I canticned trhon I was hare bsfore, 7 tha Oystor Creek plant, after being out for 8 months, could not be started until tha 7 9 Muclear Regulatory Board fined them for laxity. 10 their accurity, by cne of their cwn i j 11 nacurity men, said that th3 security at that 12 plant is the worst that he has over seen, i
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; 13 Thase are the facta. These are not fictions, 14 those sre tnings that --
- I am like the lato 15 Will P.ogors, I caly know what I road in ths
{ i
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16 l newspapore. 17 These stataments that I have tade hava " IS baan nado by poopic frca the federal govern-19 mant. As far as Thren Mila Island is concoracdc 20 I have a statument by the Nucloar nagulatory 21 Eoard that Threo Mile Island will taka savon 22 years or more to get back into operation, and 23 the officials of the GPU say that Three Mila 24 Island, that it may stay in limbo, it =sy navar b\- 25 return to service. It's alrsady coat over
Albrecht 1844 1 $300 million,eccording to the report, and as , !3 v 2 I heard the testinony here, it's going to 3 cost over one billion dollars,and it may never 4 be going backinto service. Why should the 5 ratepayers hava to pay for something that is l 6 not going to be of any use in the futura? 7 I'd like to know what position JCP&L 8 is in at the p ccant tir:3. " 9 Ecw =uch power la JCP&L producing on 10 their own?
- 11 I talked to Mr. Bartnoff at the hearing 12 up in Morristown, and I had asid at the tino
() 13 that Oyster Crsch supplica 35 porcent of f: 14 their power, which I had read from a stata-f 15 nont given by ena of the authoritics. i
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16 Dr. Bartnoff said it was caly 12 par-17 cont of JCPGL's pever, at that particular timo, 18 anyway. , 19 Now, Cyster Crsok is out = cat of the 20 time. Three Mila Island is out prchably 21 pernanontly. 22 So, JCPAL is no coro than a middleman. 23 They are importing olectricity and they ara 24 paying a high price for the cloctricity, () 25 nuch over the cost of production, and now i l
Albrecht 1845 1 they have to make a profit so what they are O 2 doing is charging us for another profit en 3 top of what they are already paying for it, 4 and they are not producing it, just salling 5 it. It's like a newspapsr. The newspaper 6 boy deliveres the paper. He doesn't print 7 it, and I can't see whers JCPSL is a productiva 8 company and I don't eco why thay should stay 9 in businces, and we have to pay them to import 10 electricity from somo other source.
- 11 e
12 O.:. 23 j 14 5 15 3 a
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17 18 19 20 21 P 22 23 () 25
dC Albrecht- 1846. 1 Tile WITNESS: Oyster Creek itself has O 2 been in existence since ten years or so and 3 I was talking to sotte technicians and engineers 4 working for a utility. They said after 15 5 years Cyster Creek will probably he out. 6 Ve have the Forked River plant. It 7 was supposed to be in operation I think some-8 where in the '80s. Af ter ten years of buitd-9 ing the plant is only 5 percent ccmplete. 10 Tais is according to the statement of people 11 froa JC26L. 12 Mr. Laird, as I mentioned before, said O; ' thc7 me=e t=71 =s == sett enuig=ent f=== the 14 f y g g,1 River plant beccuse by the time the 5 15 1 i plant uculd be built, the equipment would be 16 ! choolota. 17 Now, the ratepayers are paying for att 18 these nistakes that Jersey Central ~ Power 6 19 Light Cccpany are caking. They stilt consider 90 themsorves a viable comoany. Ve, the people 91 of Men Jersey, the people using Jersey Central Power & Light, and I represent the senior
3 citizens of the Day Shore arca of Menscuth 94 County, we feel and we vant the canagement of 95 JCP&L out. We want the cocrpany reorganized,
1347 Albrecht-1 and if there is no other way, for the public ; OP 2 to take over. 3 I a:a noc a professions 1 rz.:n in this re-4 spect but I a:s sure that the public, if they 5 took over, we could buy our power anybe a lot 6 cheaper thuu Jerney Central is buying it for 7 and pay for it at a loc less expense. 8 1 think that's all I have to say today, 9 Your lioner. 10 JULGE W6GMLL: Tharh you for your i j Il cuanenta, Mr. Ali>recht. l ) y 1 think this would be a 3001 tine to O; ; i take e breca. 14 l hl. XIRSTE'i: E:wase ne, air, beforu 15 l we do, while Mrs. Fahey is still in the roc:n, r 16 I have been asked to acvisu her, and that this 17 he on the record, that the Ccspany has received 18 her checks returned frc2 the barlc ::arked "in-19 sufficient funds," &nd I was instruc:cd to 20 advise her that unless she pays $133.85 in 21 cash, n;oney order or certified check within i 92
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43 hours, that we will discontinue her service. 23 I was asked-to =aka ths: stateacnt 94
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p while Mrs. Fahey uns :till hero. ! 25 MS . FidLU: Lot it be on the raccrd, i 5 I
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1 I 1848. I too, that the one che.ck for $100 was insuf-U 2 ficient beccure the d pocit was ::;ade in the 3 bank and they did not get the deposit into my 4 ccc(unt us.til three days after the deposit, 5 but alco on the record that the $55 check 6 tihich rcprcsonta 1:hst I~ cati:2ated it repre-7 nents the energy adjectsen: chcrge was not 8 uced by ve, and I paid for w/ actual kilowatt 9 huurs, not for crf energy adjustment charge 10 estich I cacinated. II Uould it also be en the record that my
.i 12 bill, when they teruinated cervica April 24th, 13 O'v - that I cred the utility ecmpany $98 at that a
i 14 s *ven ti.ac and t; hen I ucnt down to pay ry bill, i d 15 g for c=c rencen it increased to $155. I don't I 16 inou where that extra noney ecco in. :
' 'ih n I una diccer.aceted on April 24th, 18 there r,ac a deposit on top of the $98 uhich 19 vao - -lus there vac $11 for reconnection, 20 and that's way I ctayed out in protest of not 21 paytv, en17 that part of the conzy to the 22 i I et111:7 ecm.pany.
23 j Also, ice it be knoun on the record 24 n) t that I asked for an itesi=cd bill the day that l 25 they were tu ning off rf electricity, uhich
F 1349. - 1 uss Octcher 3, cnd I have bcen deniec an itc:-
/"%* 'J 2 ized bill, the day that they were turning off 3 my alcetricity, which vas October 3, and I 4 have been denied an ite=1:cd bill. l 5 Also on the record, I =2de four phc 4 6 calls to the Scard of Public Utilities and I 7 spent four hours en the phone, of which the 8 3 card of Public Utilities tald nc that they 9 don't have to give 20 an itanized bill, which i
10 l 1 was told that I had to pay Cao 4135 and i I
$ 11 l which they don' icd ce reasenable deferrad pay-
! l 12 j ments at that givea th22, and I :111 da not O: i I3 have cu it<mized >t11. und heve info ==cd the l 14lI Eocrd of Public Utilities that I do not hcyn 15 l the money but I will pcy to have 27 cicctricity 16 restored, and since thera in a diccrapancy in 17 all of this, that I stopped paynent on ene of 18 i
the checks, and let that be en dbo record that 19 it va: -- y:n vere vell infer cd, Scenuaa I oo
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think you hcve a copy of that, and I daa'c 01 thini ysu should coac out there und turn off on
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my cloctricity in 43 hours, sir. 93 F5L. KIRSTIM: I just vanend to ict you 91
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knou that that 1: the status, and you h.2ve (-}
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been notified that unlesc vc hcvc roccived , 6
1850. I payment in cash, money order or a certified O 2 chech in ha hours, you will be disconnected. 3
' lou can do or take whatever action you think 4
is appropriate. 5 IES. FidlET: I think there already is 6 actico; there is already action at the Board. 7 I have ashed for a hearing en this probica, 8 i co I assume that I cs entiticd to due process 9 of law first and I don't think that you have 10
- the pcuer to coco and turn me off when it is
! 11
! highly <Iuactionable, my whole account is ex-12
- tremely questionabic, and the 4100 you will 4 13 A,
N J ". b2ve, j 14
- JU"GE MARSHALL: All right, now that d 15 j thcce c~ccc: cots have been placed on the record,
- 16 tre vill take our 15-ninute break.
17 C* herr.! pen, a reccco vas taken.) 18 19 20 21 22 b 23 24 25 - I
Rabor-cross 1851 i 1 (After the receaa.) 2 JU003 MAR 3 HALL: Okay, back on the 3 record. 4 11 A R V I N R A 3 3 2, previously sworn, resumes stand.
.5 FURTUCR CRO3S EXAMINATION 6 BY MR. NA2DELLI:
7 Q nr. Raber, you were discuscing a comparison 8 of a restored TMI-2 with a coal plant at another sito. In 9 that the comparison? 10 A That was one cf the comparisons, yes. l 11 Q In fact, I holiovo thut's your second favorita l
., 12 option, a coal plant at ancther alto?
O
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4 13 A That's right.
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j 14 Q In order to na%s thoso comparisons, you had to i J f 15 caka covaral aJ3umption3, did you not, about the coat Of thu " i: 16 restored THI-2 plant and a now coal plant? 17 A Yes. 18 0 In that not truo? 19 A That's correct. 20 0 And new you havs told us about your estimata of 21 one billien dollars for rostoring TMI-2, but I as=una when 4 22 you nada these ccat comparisons it was over a period of ti=o 23 you compared ths costa, the projacted costs, correct? 24 A The energy costs vera comparsd en a -- over a 25 13 year period of ti=e frca 1934 through 1996.
I Raher-cross 18S2 i I And what made you choose 19847 Q f 7-
\_/ 2 i A WCll, in tha esticates that were mada last year 3 of the restoration effort,that was the in-servica date that I 4
resulted from the study, that was the data at uhich that f I 5 study indicated TMI-2 could return to servica. i 6 - O Your best estimate now on TMI-2 would be what ! t 7 . year? t 8 A The last cfficial estimata, I believe, was tha 9 beginning of 1985 -- no, the end of 1935, I'm sorry, and j 10 that is cenaistent with the billion dollar figure that I i II i quotad befors. , 12 g Q To the dagroo that this in-service dats slips, l {} { 13 what does that do to tha ostinata of energy coats? I4
! A The energy costs frca the resto od TM 7
- 1 15 g 7,3, l
16 A They would probably incronso. I Q How would they increase vis-2-vis the coal I8 costs if the period we nro ecmparing would olip? I9 A Nell, the numbars that I quoted in tarms of 90 break even costs for restoring TMI-2 wers based on a slippage 21 to 1987 and still indicata that we could tolerats n subatantial 22 1 increase over and above even the now estimata befera tho costs 23 were equal. ; 24 l In cthur words, the cost of restoring ' O 25 the energy costs from a restored TMI-2 would still be seme-t
i Rabor-cross 1853 > i I what lower, substantially lower then the energy costs frem i 2 other coal-fired facilities or from a co.tysrted TMI-2 unit. l-l 3 ' 4 ( l 5 l t 6 } 7 i f 8 [ 9 10
. i 7.
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12 l I: ' E O !. i i 14 !' d 15 f I !
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16 f 17 l 18 f 19 i 20 21 7 5 22 ' k t 23 : i l l 24 O 25 i
I il f.
.1 Rab:r-cross 1854, j j
1 Q What's the significance of the period of 13 4 O j V years that you used for cc:nparison purposca? s 2 l f 3 A The 13 year period nos chesen to begin with i 4 the earliest date forescen at thin tine for the return of , 5 TMI-2 and extended for a nertinni ten years 'seyond the earliest 6 in-service date that was forescen for a converted pirnt. 7 Q Now, when you talk about a cenrorted plant, 8 I thought you were talking about a coal plant at encther 9 site. Isn't that your reference? 10 A That's the uay the st;.dy ent'ed, yen; Ue j 11 looked at all three options, rneurn to 211-2 to service ac 12 a nucicar unit, converting it to fossila-fired or nirply 3 Ola 13 huildins coal-fired capacity at other at::cs. co, we really i 14 studied all three.
} 15 Q Uhat auctanptions did ycn nahe rega:-dir3 the i
- 16 capacity factors or cperating ra:ca?
17 A The capacity factor -- ict cia chech my notes 18 on that. 19 58 percent for the coal and 53 cercent for i l 20 the restored nuclear plant. The other eptien that we j 91 studied was the posnibility of utilizing gaa e . fuel in a no converting pinne for a short period of tir.e, and that vaa , i 23 assumed to have a higher capacity factor, abcut 35 percent. O v 24 Q 58 percent ccecs rather law for a coal. picnt,
'5 How did you reach that number?
l
j Raber-cross 1855. 1 A That is consistent with practice or consistenc Q V 2 vith czperience for large coal picnts. A large number -- 3 a large percentage of the population of coal plants in this 4 ccuntry in the past year ran at about 58 percent, for ex-5 enple, GFU's or the plant that GPU owns partially; the large 6 units are also experiencing capacity factors in that range. 7 ;his is a reasonablo annessacnt. 8 Q 'Jhen you talk about averaging like that, 9 these acr2aca are dominated by the old plants, are they 10 aut! j 11 a Plants withcut flue gas desulfurization 12 , 373:cg3, 733, i 13 Os , Q lira you sug?,csting that with the flue gaa ' f I4 l afstems, thia ni:;ht have a negative icipact upon capacity { 15 factoral i 16 3 7e 21g3g, 7c3, 17 Q So, ycu venid not be optimistic about a new I8 coal plant with all the newcat technology being able to 19 ochirta core than 53 percent? oo
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A Bo. The 58 percent vaa selected for the pur-o
~l pese cf the study. Uc would hope to achieve that cmch.
22 The ccal plants that we vould build would be designed to 23 cp. rate at as well as we could possibly design them, reasen-24 chly design thca.
" 0 ~
~5 Q Where did you get your 58 percent for the
Raber-crosa 1155. . I nuclear plant? L by 2 A It una : elected to be cqual to the coal pisnt 3 and it's conservative, that la to say, lou, ralative to 4 GPU's experience with Oyster Orcah and "hrca Ilile Island-l 5 prior to the accident, and the population of at: clear planta 6 in this country over the last Ic'.: years have been better 7 than 58 percen::; co, that ::as c'acaen ta ba a conscr/ative number. 9 Q Do you thin': the reatcred III-2 could -- ua , IU could look forward to aa high a capacity factor as va could f II frem, let's say, a nucicar plant built frc : scratch? 19
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i A l'::1 casuning that tha reator.Ition vauld bte ip) , 13 v d doubic enough so that that could indaed happoa, ye2.
- 14 i Q ' dave you ::;tda any aar,trr;;1cns about CS.i costs ,
t 15 l
- for the nucicar and tha coal plant!
- 16 I
17 . 18 19 i 20 l 21 i 22 I 23 94 O ' t/ 25
I l 4 Raber-cross 1337 1 [ A They' were talan from budgetary projections of J 2 i OEM costs for similar plaats en the system based on a budget , 3 , that existed at that time. . 4 Q What about the costs of uranium and the cost i 5 I i' of the coal? Did you make assumptions regarding that? 6 A Yes. Wa make projections of the coat of 7 uranium as a function of timo, taking into account existing - 8 contracts and projecting into the future baycad that cad ths 5 9 same data that we use for the other plants was used in these 10 studios.
. 11 ! Q How extensiva i= the backup r.stsrial on these 12 j various assumptiens we've been dincussing as to the coat of a f nuclear plant versus the cent of a fossil plant?
j 14 A The cost of ths coal plant, for instanco, was
$ 15 j pradicated on the cost estimate for Seward 7 which ie a plant r 16 that we havo planned to build in west 2rn Pennsylvania for 17 some numl>ar of years.
18 The coat of operating nuclear units 19 is again;redicated to some extsat on our cwn prior experienca. 20 So that there is a reasonablo basis for 21 all of these estimates. 22 ~ Q Now, during your opening raparks, you did rotar 23 to Seward 7. Were you saying that there had to ho a slippago 24 in that in-service date? l 25 A Yes, that's what I said.
e I lRebcr-cro30 1850 I i 1 Q ticv, in thers any doubt in your mind that the /~') 's - 2 G?U system needs Geward 77 l l 3 A No. 4 0 Is thers any doubt in your mind that Seward 7 ; i 5 la aceded by Jeracy Central specifically? ' 6 A You msan Jersey Central's 10 percent share of 7 Suvard 77 Yoa, I think Jersey carthinly needs capacity in 8 tha tir.sfrsre of the early 1990's, cortainly will need 9 capacity in that timeframe. 10 Q Then you would not be in favor of the ranewal l of Jorsey Central's petition of earlier this year to sell its
! 11 l 12 l 10 percent shars of Scward ;iumber 77 i
(')
\/ ; 13 A The potition, as I recall, was predicated on f 14 financial censidarations, and to the extent those fiaancial d 15 cancidarations still prevail, than I'n prcbably not the right
- 16 witness to address that, but if those financial conditions 17 still prevail, than I would be in favor of the switch, yes.
18 0 Laaving acido financial conaldoratiens fer tho 19 ncn nt, would you agree that it night voll be beneficial to 20 Jornay Central to cwn mors than 10 porcent of Seward :Iumber' 21 77 22 A In tha sense of that plant being abla to fulfill 23 soms of Jersey Cantra18 3 capacity ne.eds, than yea, but on the 24 cther hand, thm Pennsylvania ec:.paniss may al.ro need that 25 capacity. -
Raber-cross 1859 I Q In fact, Mr. Raber, isn't it true that at one 2 point Jersoy Central did own ccrs than 10 percent of Seward a 3 Number 77 4 A I believs that's true. 5 Do you knew the details of that as to how meh Q 6 it at ena point owned? 7 A Frankly, I don't. 8 0 Dut you would accept, subject to chock, that 9 at one point Jer3sy Contral ovncd ors than 10 percont? 10 A I'll accept that. i j 11 Zia. KIRST';U: I might say, A1, that in 12 rsspect to the history of that, if you're O; '3 intereeted in taat, n=. n< ton, I thin *, 14 would bo better infor: tad of that. 15 Ita. NARD 3LLI: f Thank you. i
- 16 Q Mr. naber, lat'.3 turn to pago 17 of JC-300.
17 In thc last full paragraph there, you 18 stats that it nay alasta possiblo to utilisa existing 19 nuclear plant fo:ndation work for a coal plant. 20 Any oxisting equipnent at Forked River 21 oxclusivuof tho turbine gonorator, which is a potential use 22 in ,a coal plant, vould be utilised, if cost justified. 23 Isarot so cure I understand that last 24 aantencs. Uhat are you saying there? O 25 . l - l l
Raber-cross 1060 1 A Well, a.saumin; that tha nuclear plant at Fork 2d O ,
- tiver was not to be constructed, thera would be some equipr.ent 3
available that's alrancf boon delivered that would need to be 4 disposed of in some manner, shape or form. 5 6 7 l 9 4 10
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4 17 18 19 1 i
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!!aner-cresa 1051 :
I 1 A (Continuing) Scre of this equipecnt - a sirple ' (VO k 2 osarip1'e might be pipir:g, valvoa, pumps, things of that naturo -- 4 1 3 night u. usaalo in a coal . lant built there or anywhers else. I i i 4 If the ecut of incorporating that equip-5 cent into the coal ,lant design did not override tha value of 6 tno osulpcent, ne wculd likaly use the equipicnt in the coal 7- plant. 8 ancther r:1 rnative, of ccurse, is to 9 sell the equirnant. Thiche n: ,sroducad the host ra:cnomic 10 benefits, I presure tht.: wcula he the courso that wo uould
$ 11 follCW-12 Q !!ow, icu're sayin;:, than, th;t if tha Forked s
- iver nuclear plar.t uere abapCcued na a nuclocr plant, thera 13 l 14 would he ti acivage valua, be it by cal? or by usia
- ; it in
$ 15 another coal plant?
16 A SM-17 Q ideve you Cons any a tudit a to determine what 18 thia -- and I'll use the terr. 'scivrie valuo ' as a generic 19 torn to cover both a:llin, t!.e equic-ent of f an 2 by using it 20 in another plant. u 21 Dave you dcne any ctudica to detornine !l 11 il 92 what this migat be? I i 23 A YC3- J"rG01 Central has r. ado an aacessment 24 of the 394 ndllica dellar total carrent invast:;ont. Atcut 25 f461 million has been jcd:;ed to be non-rosalabla. ' chia j M 1 t
Rab0r-croso 1962 1 portica is mads up largely of indirect costa and nca-tangibis' O 2 items such as AFDC, architoct-engineering service, other 3 cessulting services, on site labor and so on. 4 Major oquipment itens L51t could be sold 5 if a buyer could be found total about 113 million. This 6 category facludes nuclear stoss supply equipment. 7 Q Eoes the 118 millica -- is most of that the 8 nucloar steam supply aystsa? 9 A Yes, I think so. Thors sre other items of i i 10 equipment, a large numbar of tham, that make up ths remainder 5 11 of the 2ntast=ent which is acmothing liko 013 nillica, and 12 that includos about 7300 items which can be disposed of in ([).~ 13 can manner, shape or form or 2ncthar.
! 14 Q To acho aura I taderstand, ara you saying about i .
d 15 l 193 million is the nuclear steam supply and tha romaining i I i 16 13 millien 2ro thcao largo numbers of other parts? 17 A 113 millien, I think I said, 118 millien for 18 ths nuelcar stoss supply system. 19 Q Now, tell mo cemething mora about tha nuclear 20 stsam supply ayatom. . 21 Ohat has a market for comocne who wants 22 to use it in another ncelear plant? 23 A In a very specific other nuclsar plant, 24 , specifically, in 1130 magawatt class nuclear plants dasigned l () l 25 l by oca particular vendor, ysc. I i i i
Rabcr-croco 1862 1 portica is made up largely of indirect costs and non-tangible () 2 itsms such as AFCC, architect-engineering servica, other 3 consulting services, on site labor and so ca. 4 Major equipment itena that could be sold 5 if a buyer could be found total about 118 million. This 6 categorydacludes nucloar stsam supply' equipment. 7 Q Does the 110 millica -- is most of that the 8 nuclear steam supply systaa? 9 A Yes, I think so. Chars are other items of 10 cquip=cnt, a large numbar of them, that ma%o up the remaindert
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! 11 ! of ths investment which is somothing liko 013 million, and i
12 that includos about 7500 items which can bn diaposed of in
$ 13 cau 22nner, shapo or form er another.
Ius') *
! 14 Q To anko cura I undsratand, ara you saying about i
d 15 103 millicn is the nucloar atsam supply and the remaining
! 16 13 millics are those largs numbers of other parts?
17 A 113 millica, I think I caid, 118 million for 18 tha nuclear atoas supply system, 19 Q Now, tell mo co=ething = ors about the nuclear 20 stsam supply system. 21 That has a market for someone who wants 22 to use it in asether nuclear plant? 23 A In a very specific other nucinar plant, 24 specifically, in 1130 magawatt clans nuclaar plants dasigned () 25 l by one particular vendor, yes. 4 il : i,l
r I Raber-croco 1863 I I 1 O what vendor is that? , i () 2 A Combustion Engineering. 3 Q Ucw did you reach the value of 118 millien? I 4 A May we go off the record for a noment, please? 5 JUDGE MARS!!ALL: All right. 6 (A discussion was held off the record.) ! 7 JUDGE EuSHALL: Back on the record. ; 8 MR. KIR3 TEN: I might say for the record i 9, that this particular exhibit is not really an l l 10 l exhibit that can be supporte,d by Mr. Raber, 11 It was_ prepared through Mr. Preis ' 12 area, nr.d there really -- we brought it along 8 because wo expected questions along this lino ()$l " 13 14 no that I would like to mark it for identifica-i , d ! tion as JC-111, and if there's any problem 3 15 l' E 16 about it, I'd like to point out that Mr.
, 17 Preis would be the one that was supplying the 18 details of the exhibit.
19 It is responsive to the question just 20 posed by Mr. Hardelli in respect to whure i 21 did Mr. Raber derive these numbers from. 22 ' JUDGE MARSHALL: If there's no objec-- 23 tien, this exhibit will be marked Exhibit i 24 JC-lll. () 25 (Fourteen-page document with first l
's
E r Rabor-cross 1864 , I page ' entitled " Forked River Investmsnt", 2 referred to above b-j lir. Kirsten, is received ; 3 for identification and marked Exhibit JC-lll.) 4
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, 11 1 12 -
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; $ 15
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I m _ 20 ! s 3' ' A - 21 N. 4 i e 3
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1865. 3 Rcher-c:oco I, y Mr. Zaber, on the second page of this exhibit, 2 there's an ite:s of 32.2 nillion for AFDC. You ces that? 3 A Yes, I do. 4 Q Do you know hou much of that 32 million was l 5 accrued after the point in April of 1979 that Jersey Centrat 6 cuspended constructica on Forked River? 7 A Ito, 1:a acrry, I don't. 8
% That uculd bc : ore in Mr. Preis' area?
9 j A I uculd think so. 10 Itow, the nent item of 70.1 eillion, that'c Q i j ll for the nuclear steta uupply system you and I have begun to 12 1 g dir.cucs ? 13 A Yes.
}
I 14 i Q. W e's the difference between the 70 million
$ 15 g and the 113 sillicn, cdditional parts?
16 A The 113 million described on the last tuo 17 pa;;cs of this enhibit. and that includes the 70.1 million 18 plus other ccarenonts. 19 Q 11cu does that 12 million for expenses for 20 other than material relato to the 70.1 million on the nuclear 21 ateos supply cysten? Is that the AFL'C7 no ,
~'
A l's sorry, I don't knou. Q Hote did you arrive at the figure of 70.1 24 p million? d 25 TdE WITNZSS: May wa go off the record l
~ -
Edber-cross 1865. 1 casin? (h t) ! 2 JJIGE LUC E L: Yea. 3 (Discussien van held off the rcecrd.) [ ( 4 JULG3 EtRSiiALL: 2ach :n the Iccord. i l 5 BY FR. NARDELLI: ! i 6 Q Mr. Rober, :ty que tion 13: 'ehat was the $70.1 l 7 million signify? Is it scscoac's estincte ac to .dut the 8 worth of the nucicar seca.2 supply syst.n is? l 9 A g; orth probably in a cas: acase. l'a not curo t 10 that that algnifica thac acnebody thinks they can scil it II f for that price.
~
1* Okay, that's a helpful casucr. g Q
] {
13 l Thace figures that vc have in chia c:6ibi:: 4 14 j are what it costs the Compacy. Ia it ccc:e aind af heck 15 cost of this equircent? 16 A Again, Mr. Freia is probably tha bact one to 17 address that questien'to. 18 ~ , Q Uc11, vould you.be the perscu to add:cco the 19 question of what is the relationchip botucen the 70.1 mil-20 lion and any possibic salvage value of the equip: ant?
*1
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IR. 1*1ESTEN: If ycu dcn't mind, per-99
~~
haps if I ach lir. Kaber a feu questions about 23-this c::hibit, that will colve ycur probica, i 24 p because I have a practf good idea of where 25 we're going. All right? I l
Eaber-direct 1867. I 1 PREU2 DEECT I2.VfEMTION
'O V 2 FI MR. IIPdTTM:
3 Q Mr. Raber, we have had an exhibit which has 4 beca rurhed ac .iC-111. Uss that the numbers which were 5 31ven to you by Mr. Preis upon ubich your study of feasibility 6 of varicus alternatives uas based? 7 A i orked River alternatives as opposed to TMI-2 8 alternatives that we Vere discussing. 9 Forhad River? Q 10 A Forhed River alternatives, yes. 11 Q Nou, the breakdcwn on the first page which 19 g chcus $394 million as a total inves ~, cnt, that indicates O I 13 V j that that is heck value, friestm-nt; right? IA h A Tes. i 15 Q And, therofera, the items that are the com-r 16 pootte of that are the Jersey Central book costs of those I7 various itesal 18 A Yes. 19 Q C* cay. 3o 3, you indicated that the $113 mil-20 lien are the itens uhich are salable. 91
~
A Yes, previded one can find a buyer. Q Chay. Do you have any infor=stion as to, in 23 fact, uhat the carket is for these itess?
~>4 A 1"no best information that I have indicates 25 there icn't a:rf sarh2t. ;
l i
Eeder-direct 136G. 1 Q All :1 3ht. Fev, for the purpose of ycur + O 2 .na1 7 12 or the re=*ed 2tve= cg=1cas. ,*>: salv1a= vat =2 3 was att:1*cuted, if any, Oc thia 3M r.1111:n-dollar f r.vc:t-4 c.ent? 5 A For the purposa ci our study, vc casur.ed ze:o, 6 that the salvage valus that .27 he acc: red appears to ba 7 small in cocrparlacn with ocher as=:pticus thte uc azie had 8 to malta concerning the pcasi~aility of cen: ructing ecal 9 plants in Ncv Jeracy. 10
. 11 12 a
3 4, 13 t
- i. 14 O
$ 15 R
~
16 17 18 19 f 20 i 21 1 22 23 24 25 l
-- - ., - -- 0--- - , - , --- .---w----s
.211 Taber-direct 1869. l 1 A (Ccucinuing.) For the purpose of that study, O 2 us simply asst =:ed a cost that was equal to the construction 3 coat of a plant in Pennsylvania and did not add into that 4 allowance for nnjar differences in costs that might arise 5
for a plant built in Ucw Jercey due to the scrubber system, 6 due to coal transportation facilities, rehabilitation, due 7 to other things, nd in view of these other uncertainties, 8 tha salvana value scened very small. 9 Q Now, can any of thin invest:sent which is re-10 ferred to in J';-111 be applied to a coal plant constructed II h at Forked River or alsot/cero in New Jersey? 12 i A The cocpenenta that take up the list that OiI 14 1 cede to the 313 m1111on may or mey not be ap,11 cab 1.. i Th.rf would have to be judged on an individual component d 15 i j j basis. 16 Picane rcccaber that if we were to build a 17 ccal plant or cecnic to building a coal plant in New Jersey 18 in the not-too-distant future, we would probably wish to 19 build a replica of Seward 7. 20 , The ccu::enents for Forked River may not be 21 readily adoptable to that plant. This would have to be 22 looked at en a case-by-case basis. 23 Q Thank you. 24 ] 25 FLT.TEL CROSG-l%'J11NATICU 3Y 12. H.UU)ELLI:
! I l
y Raher-crees 1.370. 1 Q lir. 2cher, ytr= anc icra to Mr. 7.irstm' : { V 2 questions were $aned upon what acet=ptians ycu s:1.c when j 3 you were doing ycur ce= pari:en of eccpic:ing I'orhed River i 4 as a nucicar plant at that site and either buildis; e c:ci ! 1 5 plant at Forked River or at another sita. Is that correct? ! i 6 A That's co-rect. ' 7 Q .And I cay get back te thct, but tho questions 8 I'm going to be aching ycu nc: cre going t.: tha issue of 9 how much of For?ted River, if any, cheuld be alloJed to be 10 a:nortized and charged to ratc7cycrn, ,qiven that of the i i 11 $394 million, there cuct Sc amething that can ba :civaged 12 so that no one has to boar the cccc of it. 13 gg, gip 3 7;g 7; y3 c ;q 33 3 go
!- 14 li into that, if ycu'rc going en tha acou:rotica i !
15
, thero c:uct be cone, I think l h re to object 16 beenune therc't nothing in the re:Ord to 17 indicate there tmst be scua.
- 18 Mr. Raber's tecti =cny una that there 19 may be so c anatil salva3s value, but in re-90 intionship to the way he's made his ce=pariace ,
91 he has assu=ed nonc, and if you're going to 2 probe in ter:ss of the engineering status of
'3 that judgnent, Mr. 2.aber is not the witness.
94 He haa raade an ccencaic n?.alysia 'cased
\ 25 upon an assumption that thoro t.rc no si;g ificent
r Raber-crocs 1071. { I calvage values in that 394 million dollars. V) 2I bhether that's right or not, l'c not 3 disputing. I'm jisst saying fx the purpose r
'I of his kuculedge, he's makity that asste:ption..
5 ME. W2JJEI: All right. Who in the 6 witness for thic linc of questicnia;;? 7 F2.. F.lPEmi: Mr. Newton is our en;;in- ! 8 erring expert and could explain uhy that 12 1 9l ao. Ho uculd be the witness.
- 10 3.j;gt, ggg3Lg7 i
4 11 j Q Mr. Raber, are yriu mrare of any plans by .10y l'
~
j i other utilities to build coal plaats in thic 3eneral ceca 7 13 1 2
, 3y that, I neen New Jersey, Pcunsylvcnia, New Yerh.
4 i 14 i A I c:2 cuare that Atlantic Electric has propoacd
! $ 15 to build a =211-sized cost unit here in No; Jersey. I'm g
- 16 not specifically avarc of any unit under constructica er j 17 incediately planned in either of the other tso states that i 18 -
y7.: centioned. 19 . In Pennsylv:nia, at least within cortsin 20 areas, the PJA data would allou ::e to 1cok that up if you 21 - uish ria to do that. I can get back to ycu whether any of I 22 the PJA Ceepanies are planning to build ccal planta over ! 23 the nc::t ten years within Pennsylvania.
- 24 Q Well, forgetting just Pannsylvania, we'd be i
interestad in kncuing of any projected ceal plants by the i 4 1
.-,.=-,e --- y
Enber-crata 1372.
^T Il '
PlM Ccmpaniec. I believe : hut LxiuCes ik:r7 and 1 and per:s (V 2 cue -- 3
.* I underccand that Dalcarva ?cuer & Light is 4
clso building or planning to build sanc cost picnts. Th::sc 5 ara the ones that ' recollect for cure. 6 L did not brin:t that cats with oc but I'd be 7 happy to v-2rify whetter any other ca paniac 3 ave these 8 chings in their plans for tha next decade or so. 9 i l 10
- i
. 11 l,
, 12 8
C'T j 13 , v o. I i: 14 3 15 ! I 16 I i i 17 18
. 19 20 21 l 1
22 l, l 23 24 g
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b y i P.aber-cross 1873 1 Q Yes, we would like ycu to verify that. 7 t %) 2 Yes, I will do that. A 3 sn, 3:RSTE;it Just so that you're not 4 nialead, Mr. Hardelli, I think you'll find 5 when Mr. :lewton testifics he will testify 6 that the kind of equipme'nt we have at Forked 7 River is not =uitable for coal plants. 8 IIe can give you the technical reasona 9 why, and the prcblen isn't not being coal 10 plants there, but no 1100 megawatt nuclear
- 11 plants being planned.
s 12 Q Mr. Raber, are there, to your kncwledge, any f () i 13 1100 nagawatt nuclear plan'da being planned? - I, i s 14 A Thsre ara four sistor units to the Forked Rive- I f 15 unit undor constructica in the Unitsd States, i: 16 Q Could you toll ne what they are? . I 17 A Two of ther. are under construction by Southern l l 18 California 2dison. 19 They are the San Onofre cnita 2 and 3. [ l 20 The third eno is under construction by 21 Louisiana Pcwsr and Light. This is the Watorford-3 unit, I 4 22 and thu fourth one is either under construction or planned l. 23 by Dosto.i 5dison Company. This is Pilgrim 2. N fS 24 Q And nron't thece fcur unita -- aren' t those
%.)
25 conpanies that aro constructing them a possible narhet for the
2ator-Orcss 1874 I the naterinis and equip = sat at rorhad River? fs 1 lv 2 A I would doubt it. The first thrsa of those 3 units are in a pr: tty advanced stage of ccnstritchion, and 4 the major equipsont itsma hava icng sinc 3 baon procured. 5 I'ra lesa r. tare of the stat 1.a of the 6 Doston Edison plant, but I rocall that it was ordered back 7 in the early 1370's and my guess is, and this is subject to verification, of courisa, ny gusac is thay havo also isada 9 commitronts for t'ta najor conpononta. 10 !ow do you spell thst Southorn California Q
- i
- II '
Edison? to~ A 3an Onofre, two words, S-n-n 0-n-o-f-r-o. I i y () a I3 0 : Icv, I read in the papers occasionally of
!- I4 I varioua foraign countrie:s _ saying -thay'ra going to conatruct 1
l 15 nuclesr plants. l 16 l' Co you have any knowledgs about that, t 17 whether there's a possible markot' oversea 37 18 A I don't hava any specific first-hand knowledga l I9 ' but lot me nota that most countrias do not have electric
'O utility systems enat are large enough to comfortably absorb 21 units in the 1100 magawatt. sian range. 'Ohat's a very larga '
22 unit for rest foreign countries. 23 0 When you any cbcorb certain equip = ant, you're l 24 talking about the nucicer supply? o- 3
- A Mo. I'm talking _ about a plant -- what I'n l
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i I I n I
a 2aber-cross 1875 1 trying to say 13 that the 1100 magavatts is a large percentage ' i e (~/ \_ 2 of their total cysten and that commiting any one single plant i t j-a~ ' 3 of that sima could producs/ reliability prchina for them. 4 Q Dut my questien, though, is, I gather that there 5 are sons piacos of equipnent at Forhed River that could only N 6 bc used at 1100 cogawatt plants. That's what you're saying? I r 7 A Thst's true, yes. 8 Dut the next question is: Isn't there equipment h Q 9 that can be used as sonsthing at a plant uhich is.smallar ' 10 than 1100 megawatta? j 11 A I accume thoro sro such pieces of equipmont. 12 2 And i:n't it possible that in addition to the
/
(v ; a 13 aquipnant that can today be used at a plant that's smaller l 14l than 1100 megawatts, there's also equipment that with tedifica-1 f j 15 l tions could be used at planto that are cnalls than 1100 i l 16 nogawatts? 17 A That nay be right, but pleSco lock at this 18 frcm the standpcint of tha person who io purchasing thcao 19 compononts and he has to ach hinnalf the question whnthor 20 he wishes to do that or whether he wishes to or would profar 21 to purchaso a apocifically designad compenent for tho system 22 that he's buying. 23 30 nay weil wish to do thn latter. 24 0 Hould Mr. N3wton ba abla to gat into nora detali O 25 about this type of thing, about what c.tn be nodified and what I
n naber-croan 1976 I can ba used at a different si::ed nuclear plant?
~ A !!cpsfully, yes, i 3
4 5 6 7 8 9 10 !
$ 11 I e
12 i , O; 13 s i 14 I r E 15 i
=
i 16 > l i 17 , j l l 18 l i 19 l , I 20 ' 21 22 23 o
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25 l . l . I i o l l
. . _ _ ____m _. __ ___
q R20r-cross 1877 l 1 0 nell, the reason I asknd about Mr. Newton -- 0 2 I mean, I have some mara questions in this area. 3 Nould you prefer me to defer them to 4 his or are you in a position to got specific about the various 5 places of equipment we're talking about? 6 A I'm not in a position to get specific about 7 the various pieces of equignant that you're talking about. 8 I'm just not -- I don't know whether Mr. Newton is the 9 right ititness or not, and I am reluctant to con: nit Mr. New-1 10 ton.
$ 11 0 Fino.
12 A Sut somebcdy can ansuor your questions.
! l M3. KIR370'J: I might say that you
(}) a 13 l i
; 14 have stopped short of a few questions that Mr.
d 15 I Raber is prepared to sncver, and that's why I 5 I think he hesitates. 16 f i 17 l I think the next question you were about 18 to sah, wera you not, is if you could quantify the nu21er, 19 I the dollars involved in tho equipment that may be more 20 readily salable than the large components. 21 Hr. Raber is involved in terms of 22 quantifytag the varioua categorias, although he couldn't 23 justify how you gat into thcoe categories, if you under-24 stand what I'= trying to say. O 25 ?!R. NADDELLI: Yes, I do understand, k
Raber-cross 1878 1 and, fir. Raber, I'ra happy to adopt fir. Kirstena 2 question. 3 Q Are you able to give us acne of that information 4 A Tnat's the $15 million shown on the first pa@t 5 of Exhibit JC-lll. y 6 0 Ncw, exactly what dess that itett represent? 7 I see it saya " Direct flinor Material Itena. 3 A 7500 itens. 9 0 7500 itens? 10 A Tnat's what I undcratand the list contain3.
! I j 11 I J And they're not contained in this~ oxhibit, e
12 though?
?
(g-m ) 13 A do. 14 0 Ia thero any breakdoan of that 15 millica in d 15 i this exhibit? i r I 16 l A Not to my knowledge. It must be included in 17 the first bunch of pages, 31:aply because the firsn subtotal 18 in there is 394 million. 19 The last iton is miscellaneous 15 nillion, 20 go tem sorry, I don't think the detaila of that 15 nillion 21 are centained in hare in an identifiable) way. 22 Q Eut explain for the record again what type of 23 equiprent wa are talking about in this category of Direct 24 Minor i4aterial Itama in terms of whether they're completely L/ 25 . fundable with another plant or what. h l i .
!, l
Raber-cross 1979 I ,_ A I'm not sura I know how to charactarl=e - I 2 assur.e they would include pumps and valvos and piping and 3 wiring and1 ricks and other structural materials which could 4 be adopted to a variety of uses, perhaps in othar plants, 5 perhaps salable for non-powered plant use. 6 Q Would I be able to define these items of equip-7 i raent as salvagachia, that sorothing can be done with thom 8 in one form or anothar? A I think that we are calling that potentially 10 ' salvageable, yes. E
. 11 Q Are you the witness to discu:s what of tho I 12 y i tillo cd.11 ton la potentially salvageable?
l O; ' A uot ree117 . I ' [ 14 l Q Are ycu in a position to discuss what of the ,
- i l 15 i S261 million is potentially salvageable?
16 3 g,, I7 O Please turn to page 4 of JC-500. I8 In that first full paragraph you'ra 19 talking about possible economic benefits to custcasra in
'O
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the completion of the Forked Rivsr project, are you not? j 91 A That's correct. 22 And isn't the underlying assumption that thoro Q 93 is a need for additional permanont generating capacity? 24 A 'Ihat's what our studies indicats, yos. q , V o.5 Q now, earlior today you discussed with us a I 1
I rater-crcss 1880 l I reduction in your load fc*rscast. What nort of things can ' happen that would r1 duce ..a noed for additional perzanent
- 3 generating capacity?
i 4 A Impicmentation of various load managezent and ; I 5 conservation mecJares, some of which ths Company will propose, 6 others of which the custo.wra r.ay choose to do with no further 7 encouragement by the Company. 4 8 0 Woll, ara you familiar with what's been marked 9 as JC-3197 l It is the executive su:ra.ary of the GPU conserva-10 tion and load m:nagement master plan. j 11 ' A I have scen it, yes. 12 Q Are th433 the sort of things that you're talking Oii li incuer referring j I4 A Choco are the kinds of things I'.7/to, that's i j 15 corrcet. : i 16 17 18 i 19 l 20 21 4 23 7 24 25 I' - d ! a K l
A Eaber-cross 1i331, 1 Q And, la fact, isn't thia a l'es :: Plcn of GPU i 2 that has been recposed and is being advecated by the Corapany? l 3 A ' Quat's corrcet. 4 Q And there's no question thac Jersey Central
- 5 also supports this plan; correct?
6 A That's correct. 7 Q Ihca referrin;; to J0-304, Mr. Caber, which 8 you carked today, there's a line on tha: c2hi'ait for load 9 candger. ant goal. Fnat do you :::can try that? 10 A ;.:nt is intended to portray an anscarment en cur part of Jeracy Central'a capacity obligation, assmain; 11
; {
12 t.hnt the Master Ylun that you referred to a de; cctcenta ap 33
) vera to N imple .cnted and proved to be successful.
14 ; y Decc the line for lead ecna'arment goal ca } . E 15 JC-5C4 cc:ranpcad exactly wi::h the represents:1ona =ade in 1
- 16 J C-31')!
I7 A 1 auspect there are miner differenc2s. We 18 racx.puted thia line basad on conc updated PJ.I data and 19 acce other thint;3.
'>0 Q Are ycu caying that JC-304 is core curr:nt 21 than JO-3192
~ 2 A It is -- well, it's =cre current in the sense 23 that it una acro recently derived, but this is --
24 O V Q That's that I mcant. 25 l A -- still higtly preli:.tinary in nature. l l l
. -- . . -. . _ .. . - . - - . . -- .. - - . .- . ~ .
i Jtact-cross 1032. i i 1 Q \C.at' c "this"l ; i 2 .h Tha lias. i 3 y 411 rig!st. ' 4 5. .II.?I2'E;; Could we go off the 5 record ju.2t for a eccent? l
. i 6 )l l JyIq3 ;'lC31LEL: Sure. i i
7 (A discussica saa held off the record.) ! 8 J U S C O 2 1: 5 LI.: 3ae:c on the record. 9 gy g , g.gggy , 10 q. I have ny bearin.ga again, sir. Rohr. I kncu [ i: II I had seen 504 befara. na I carrect in thinking tiut tants a 1~9 g a revicien of JC .501? , I3 1 A Yea, it is. - e .
- 14 1 g 4 hid thcre does acen to be a difference bet::cca ,
3 15 j =
- th.c iced c.aaa;p.cnt gonia -- tha lino for the ic:d -mage-i .
t 16 l tcat goal on 501. and the line that'3 celled "c'a ligui:1 a n". 17 4 i baGad cn Jorsey Ccarral's load managcucnt goal that arpearad - t 1 18 ou JC-501. ' i 19 * ) Cen you reconcile those lines' . 4
-20 1 A The differences I think coce abcut because t
21 s uc used updated PJti data for computing reserve wir:3 ia ob11-22 tations. - 23 ' i A larga n nber.of things changed to a cmall 1 24 ! c : tent en a year-by year bacia cith this cet of daca. 3 25 , Q Is it fair to esy that the load cacagement I
, . _ _ _ __ _ -. , . . ~ _
i o s- l itaber-cross 1833. I goal on 304, that line, as n rule is lot.er -- deca it reveal : i C i f 2 a lover capacity obligation than the line thn: cppeared en
'3 50 0 l
4 A I think tic.t's co m et. 5 a ::mi, you've r.ncuored "n the affi:. native my 6 questitm aho.tt that the capacity obli:;ntion under the load 7 zu.nugt:ent sconcrio ;as lowar under 504 than it is in 501. 8 My noy.t quentica, ':har.&h,1:1 that there secna 9 to be a m.11er 1: pact of che lead utnagemer.t on 504 thr.n i 10 en 301 und, specifically, u 2rc N a millar difference be-l 11 l. taecn the ic:d nanas cent line and i.ha espacity alicactica i
)
12 i 4 line en 504 than thera is on 501. ! e - j j 13 to you have any enlaaation for that? i 4 14 j t
.\
L* - m 'laracecri::o the load annagccent goal, 1 8 15 ,
- ' not in terus of a nyecific :n:rnearical targe : but a 3eneral '
16 objective of th.3 Ccapany :s do -iaatrv r turna cut to be cost ' II offective, end if load 222.a3 =en: ac tiv1':l a : grov.3 to be 18
- r. ore ccat eff?ctiva San ecc.3'racties capacity, the C o.pany 19 vould adopt thet and would not atop a: any lia.e dr.twn en a i
20 . i sacat of paper.
*1 30 that the 11 e that y n zee here J0ea not 2~'
1 ply a ter32:: in t'.): sense of we'r+2 ;oing to ?,0 just that 23 f ar and na fur th0r. 24 l 25
,, ,.,.-e. , - - ,,,--
)
Esbor-cro43 1884 I (Continuing) Tha original caster plan was A
) 2
, developed based cn a relative to a specific forecast.
3 The forecast has teen updated. 4 Tho v. aster plan is still somewhat in its 5 There are ongoing evaluations going on formativo stageo. 6 today. These will go on for soun tico into the future, and 7 both the ferocaat line and uhat we thing night be achievablo 8 will bs adjusted en an cngoing basic based on our boat 9 i porcaptions of the succesa of these actions. 10 So that please don't read too much into i j II l the specific lccations of that lina today. 19*' 3 , MR. !!ARDULLI: I'll address this qusstion O! s 14 ' I sat =ttr +^ :m aseer era a= a2==t==- =ot
,!' j kncvi:,9 sho would be the best to answer it. ; outstanding l 15l, There la an/infora.ation requant r2garding
- 16 theloadnanegocentprogramandthecoatsavingls 17 that would result fron it.
I8 Arc you faciliar with that information request,; Q I9 tir. Rabor?
"O Are you the one who's in the process of
*1 ce= plying with it?
22 3 ne, y.= not. I am not aware of the specific 23 form of the request of fhand. 24 Q 0%ay, tir. Kirstan was the one to answer. 7_s \-) o5 x2. xIasTzni The status of that 1. i 1 il
" i
y Rahor-cross 1835 i I that wa vera going to determine whsther we ('-) - 2 could respond to your specific request by t 3 so:a sort of a stater. ant or exhibit, whathave-4 you. 4 5 If that was not sufficient or adequate, 6 we would have sonsons from Mr. Snerry's depart-7 ment availabls who had the specific responsibility 8 of developing the load management progran. 9' MR. NARDELLI: Chay, as long as it's I 10 ' understocd, Mr. .Mirsten, that our rsquest i i# 11 includos an exhibit that bzcaks down the
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12 l savings resulting from tha -- by year, ths 13 l' navings that r3sult by year from the lead {" } . 14 l managament program. l*
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{ 15 l MR. KIl3 TEN: t!e undarstand that that's I ; 16 j what the roquast ia. 17 Tha quantion is that whether what 18 we'rs able to give you will bo adequate or 19 whether vo'11 also have to give you scme 20 additional quastions by way of a witnoes. 21 I might say I thought we agreed we 22 would hold the 3rd of Novocoor open availabla 23 so if we did need a witnoss he would be 24 available en that day. G 25 HR. NARDELLI: Would the response i
Rabor-creas 1986 i 1 include the megawatt savings result from the A V 2 various -- 3 HR. KI2 STEN: I understand that's how 1 4 we figured a savings. r 5 !!R. NARCELLI: All right. , l 6 O Still on page 4 of JC-500, in the paragraph t 7 nunbered two, you speak of avoiding transmission system 8 reliability concerns associated with importing anergy from i f 9 generating stations far from load centers.. 10 i Could you elaborata a little on what
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, 11 l P.ind of reliability concarna there are mattociated with this?
,, 12 l A ifall, the PJM tystem is currently not able to ,
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13 adequataly tranafar the energy rsquired from wantsrn generating 14 I sources to the castern load contars whilo maintaining mrtimu:nl l
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$ 15 . system operating econeny.
I 16 l As lcng transmission linos become heavily. 17 loaded, the voltage. drop at the load or receiving and of the ; 18 transmissian lines boccmo covere. ; 19 The current solution to this voltage 20 drop problem is to operate high cost eastern oil-fired 21 ccchuntion turbina capacity here in New Jersey rather than 22 being abla to import energy from, say, western Pennsylvania. , 23 i
" 24 O 25 I i
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10a Rab.:r-cro sc 1807. I \ (Continuing.) 1:: is af onderstaadi:ig : hat s 2 f.hla eff-course ganara c.'.cn can 'is a s h!.3h a3 710 nillion per a 3 onth. Tha si:uation can 'se 311mitate:1 by reindsreing die 4 c::c.:nia:. ion ayatan or alternativn17 by addLng 1rz-coat -- i. 5 lo.,.op.::ating ca.s0 baae load cc.pacity itera uithin the encarn j 6 l 727 og 33a yyn gy3te:3, 37ectgtent;7 les Jersey. i t 7 j Q In your a!.nd, la there any cut-off point in 8 terms f nila: beyond WI.ch va n:n lata cna reliability cen-
-[
9 cerna 7:u' ec referred to ca Page 4? 10 a I d :n' t t'2i d : it's a s.bple function of just ;
- e 11 til e ' .a . We've imported energ.t Zrra fairiv s in ;c distances i 12 '
i g .L-to the ?II aystera and into acu Jersey. It's a quescion 1 13 2 cf at 9201:v21s of pouer enu csn use. ! 6 J
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i U3. C TC: If I may say senething l 3
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briefly, :h,. rcr.rtumsa, whether it's ic: any c i : 16 reason, cuch as craildbility of poacr, depends ! 17 tpcn not only a discence but available cources j of tran ninaion. 19 i 4 The ccm thing -- I night have c remota j It's :=ote not becau::e pl.7ce in Nr.e.i Jeracy. t 21 it'a distant but because cecting there er j transtaitting to it nir.,he be difficult. ! 23 l 4 ' dell, are thera any specific transaccicna yeu > 24
- g umtid hepa to avoid by tui.iding a traclear plant or, for that r 25 :
nEctcr, any ki:ad of plant at Forked River? Do you have ' I
- i. _ _ _ _ _ _ . _ -- ___ - . . - - . -- - - - - - -
___ .- . - _ _ = _ - . = _ - _ . _ _ _ _ _ _ - ~ _ - _ _ _ _ - - . . - i L 2aber cross 18M. ! L 1 anything specific in nind? O i i V 2 a ~he kind of thin ~, ua ro :1d hay to avoid, 3 :nm3 other things, in avoidance of thic aff-ctrarse genera-l 4 tion using oil-fired capacity harc in licw Jeracy. 5 Yea, but hou does that -- da 73u acan tra.nc-Q 6 nitting 70.ier froa nut of stato that'a genernted by oil ta
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here, you know, n purcha,:cd powoc agrec:nant? [ 8 & l'a teihing about- f.E the trcncaissica lines A s 9 i that cc=c into Mew Jeracy are no*. adequate to handle Wu j 10
- Jersey's full load uador cor.c ivrticular cet of conditions, !
j 11 and particularly into the futura, aa loc 'n ;rrar you need to e 12 ja one c,r tva thin 33; nra cit >cr need to reinJorcs the trans* l 3 l 13 i J e; r2icsion :yotau, pravtdo additianal tranruissian lines to 14 ,. bcIn3 in the energy, or you need to 3cuerate that energy I 15 1x. a.3., . t 16 ! If ycu :pnerata t'n energy 1: call /, the capacity 1 17 that b mallabic to da that in to a larga entant oil-fired P 18 ; and other type of capacity, alther coal or n1:claar would 19 en'.:e up that clack. t' 90
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i Q Do you at'll stand by your st2terent on ? ge 4 ; 21 that a nucicar plant at Forked River can be completed au - , 22 > carly ca 19367 ~ 23 A Motice tha': 1 penfacdd that uith an "opti-
. ~94 i aistically."- It's juat getting coro and cure opti:niatic, !
25 ur. ucraalu. , i i l ey- ,7- ._- ,c+-
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1 Raher-cross 1809 I In fact, it's -- oh, what restart date on the 2 /
') 9 Forkeel River ccastruction were you assuming when you made this 3
admittsdly optimistic projection of 193G7 A If you'll notice further into the testimony 5 that we did the study param2 trio in startup date and I think 6 the earliest one tro ssaamed was 19CG, and we did it in each year between 1936 and 1990. 8 Q Well, the question I was getting at, if con-9j structica did not rssuma on Forked River for another year, 10 lat's say a year from now, in 1931, would you have any hops i i II ! at all of having it in service by 19367 I g A I would doubt it. If you recall, just prior to a 2 the cessation of constructicn activities in March of 1979, f) us , l i 14 j j the targat in-scrvice date was Dacember of 1933. 15 ! I assure that a two year or a high 16 I construction hiatus of any duration would move the in-sarvics I7 dato by tha a= cunt of tnat hiatus. I8 If we had a two year suspension of 19 activity at tha nits, the plant would be two yoars later in "O coming into servics. 91 Q In Paragraph 4 en your pass 4, you make 22 rafarence to a comparisen of the cost of energy frem a 93 Forked River nuclear plant with that from the Ontario Hydro 24 transaction.
'5 Do you see these two projects as being
Rabar-cross 1830 1 mutually.sclusivs? f'i
\ '/ 2 A In other than a financial sense?
3 Well, let's begin within en other than financial 0
'l sense.
5 In other words, yea, for the purposes 6 l of this particular questien, let's put the financial considera-7 tiens saide. 8 A Oksy. If ene were to proceed withthe Ontario 9 Uydro tio, it vould probably not bs necessary to install 10 l Forked River for the duration of the major energy purchased.
! I 11 l Alternatively, if one were to proceed g 12 l with Forked River, ons might not need the Ontario Hydro,
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; 13 l but they are roughly tho as=a crdar of magnituds in terms O)
!" I'I l o" cr.pacity.
l { 15 !' O Aro you tho witness on ths Ontario Hydro tie, r i 16 in terms of the status and so forth? 17 A .7 0, I'm not. 18 33, murigit r : Is that Mr. Newton again?i 19 11R. KIRSTEN Yes, sir. 20 (A discussicn was held off the record.) 21 JUDGE EMSUALL Back onths rscord. 22 Mr. Nardelli has indicated that concluden l 23 his questions. l 21 Mr. Kirsten, do you have any redirect l h_ 25 i for this witness?. , l l l q - 1 ll l
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1991 1 Mn. K IST0!!: Kot at this tin.o. (") (> 2 - JL'DCr 1GR311ALL: I!isa tello, do you have 3 any questions? 4 MS. DELLO: No, Judge. 5 11R. 11ARDLLLI: Judge, I. should take cicar 6' that I was just deferring cy additional ques-7 tiens for tir. Rabar until Thursday rorning. 8 JUDC3 MARSHALL Ch, yes. 9 j I'm sorry, I wasn't cloar en that. i 10 IIR. XIRSTEU I think averybody under-j 11 stood that. 12
- JUDG3 MARSEALL: Chay, in that caso, !
13
,-) q ve'11 cenclude today's hearing and r. eat back j
14 here at 9:00 o' clock on Thursday morning. \ f 15 ! Thank you for attending. ir I 16 (5IARING ADJOU3NED TO T3URSDAY, 17 CCTOBER 23, 1330, NEWAR4, N3W JERSEY, 9:00 r 18 A.!!.) 19 20 21 22 23 - 24 s, 75 y.< - e
1892., I > g x }{ I 3 1 y s_ ( 2 NO. DESCR1FTION __ PAGE 3 JC-300 Prepared testimony of Marvin Raber 1755 4 JC-504 One-page. docincnc entitled " Jersey Central Installed Capacity and 5 Obligrtion," 1763 6 JC-505 One-page doct: ment entitled "JCF&L Energy Sources" 1754 8 JC-111 Fourteen-page 'dect::acnt with first
, page entitled " Forked River Investraant' 9 1864 10 -------------------------------
. 11 I U D ". X I
12 WITNESS DIRECT CROSS j 4 13 gianyI3 ga3gg hh ! 34 By Mr. Kirsten 1754, 1357
}- By Mr. Nardelli 1773, 1351 15
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16 DIRIE L. FtEY 1702 17 By Mr. Kirsten 1791 18 VALER13 WALS11 1803 I9 KATilERINE SLOFF 1811 20 ANN BLANCHARD 1813 21 By Mr. Kirsten 1815 22
'ZABET11 KIEBY 1317 23 By Mr. Kirsten 1322 24 By Mr. Hardelli 1830 1
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