ML19211D146

Response to Tx Pirg Sixth Set of Interrogatories.Demand Projection for 1985-87 Revised After Fes Publication. Includes Info Re Limestone Lignite Plant & Peak Load Forecast for Next Ten Yrs.Certificate of Svc Encl

ML19211D146
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	12/21/1979
From:	Biddle C, Mcgurie W, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	TEXAS PUBLIC INTEREST RESEARCH GROUP
References
NUDOCS 8001160565
Download: ML19211D146 (6)

Text

s December 21, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S APPLICANT'S RESPONSE TO TEX PIRG'S SIXTH SET OF INTERROGATORIES TO HOUSTON LIGHTING & POWER COMPANY In response to the interrogatories propounded by TexPirg, Houston Lighting & Power Company (" Applicant")

answers as follows:

INTERROGATORY NO. 1(a) : In earlier responses, HL&P stated that the Dow power plant was the predecessor of the Limestone Lignite Plant. What was the MWe rating of the proposed Dow venture? Was power from the proposed Dow venture included in the installed capacity projections on either Table Sl.1-3 of ER Supp., App. SH, p. SH-100 of the Environmental Report, or Tables S.8.13 and S.8.14 of the FS-Final Environ-mental Statement?

ANSWER:

1.a. The MWe rating of each unit of the proposed 2-unit plant was 750 MW. Under the proposed venture, HL&P was to receive 50% of each unit. HL&P's share of each of the two units was included in all three of the tables referenced in the request.

INTERROGATORY NO. l(b) : Has HL&P revised demand projections for the time period in which ACNGS is expected to come on-line since the publication of the FS-Final Environmental Statement?

If so, what is the new peak demand projection for the relevant years? Is that an upward or downward revision?

175$'i63 G 8 0 0116 0 IId".Si

ANSWER:

1.b. HL&P has revised demand projection since the publication of the FS-Final Environmental Statement. The new peak demand projection for the relevant years is as follows:

Year Demand Projection (.MW) 1985 12425 1986 12900 1987 13325 The revision was downward.

INTERROGATORY NO. l(c): Is the Limestone Lignite Plant a response, in any way, to revised peak demand projections?

To what extent have any revised demand projections affected the Limestone facility?

ANSWER:

1.c. The decision to construct the Limestone Lignite Plant was not in any way a response to revised peak demand projections and to no extent did revised demand projections affect the facility.

INTERROGATORY NO. 1(d): Would HL&P build ooth ACNGS and the Limestone facility within the presently similar time frames if the company decided to maintain its present reserve margin level each year rather than increase the reserve margin? Is the Limestone Power Plant decision a result of the determination by HL&P management that the reserve margin be increased above 20% in the next decade?

ANSWER:

1.d. HL&P's current plans contemplate the construction of the Limestone Plant for commercial operation of Units 1 and 2 in 1985 and 1986, respectively, and the commercial operation of ACNGS in 1987. The consideration of increasing the reserve margin to a level greater than the present 15%

criterion is not impacted by nor does it impact the decision to construct the Limestone facility. There has been no determination that the reserve margin should be increased above 20% in the next decade; hence, the Limestone decision was not related to such considerations.

175%fi 64 INTERROGATORY NO. 2: With regard to HL&P's peak load forecast for the next ten years, provide the following for the linear analysis involved with each rate class:

(a) R 2 for each independent variable.

(b) t-statistic (or other measure of significance level) .

(c) Percent unexplained variance.

(d) Durbin-Watson statistic.

Please give the number of degrees of freedom where applicable for each statistic.

ANSWER:

2. Pages SH-72 through SH-82 of the ER Supplement contain the model and assumptions used to forecast the demand projections shown in Chapter 1 of the ER Supplement.

INTERROGATORY NO. 3: With regard to HL&P's load forecast, what differences in price elasticity are assumed for each rate class (residential, commercial, and industrial) ?

ANSWER:

3. See answer to Interrogatory No. 2.

Respectfully submitted, OF COUNSEL: J. Gregory Copeland C. Thomas Biddle, Jr.

BAKER & BOTTS Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY I756? 165 STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared W. F. McGuire, who upon his oath stated that he has answered the foregoing Houston Lighting & Power Company's Response to TexPirg's Sixth Set of Interrogatories in his capacity as Principal Engineer of the Environmental Protection Department for Houston Lighting & Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

1

4. r.'McGuire SUBSCRIBED AND SWORN TO BEFORE ME by the said W. F. McGuire, on this 2/;24 day of 21s cW , 1979.

N6tary Public in and for Harris County, Texas 175(166

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

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to TexPirg's Sixth Set of Interroga-tories to Houston Lighting & Power Company in the above-captioned proceeding were served on the following by deposit in the United States mail, pstage prepaid, or by hand-delivery this Aln day of U4 cz*t h ev - , 1979.

Sheldon J. Wolfe, Esq., Chairman Richard Lowerre, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel for the State of Texas U.S. Nuclear Regulatory Commission P. O. Box 12548 Washington, D. C. 20555 Capitol Station Austin, Texas 78711 Dr. E. Leonard Cheatum Route 3, Box 350A Hon. Charles J. Dusek Watkinsville, Georgia 30677 Mayor, City of Wallis P. O. Box 312 Mr. Gustave A. Linenberger Wallis, Texas 77485 Atomic Safety and Licensing Board Panel Hon. Leroy H. Grebe U.S. Nuclear Regulatory Commission County Judge, Austin County Washington, D. C. 20555 P. O. Box 99 Bellville, Texas 77418 Chase R. Stephens Docketing and Service Section Atomic Safety and Licensing Office of the Secretary of the Appeal Board Commission U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C. 20555 Washington, D. C. 20555 R. Gordon Gooch, Esq. Atomic Safety and Licensing Baker & Botts Board Panel 1701 Pennsylvania Avenue, N. W. U.S. Nuclear Regulatory Washington, D. C. 20006 Commission Washington, D. C. 20555 1758I 167

Steve Schinki, Esq. Dorothy F. Carrick Staff Counsel Box 409, Wagon Rd. Rfd. #1 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Carolina Conn John F. Doherty 1414 Scenic Ridge 4327 Alconbury Street Houston, Texas 77043 Houston, Texas 77021 Elinore P. Cumings Robert S. Framson Route 1, Box 138V Madeline Bass Framson Rosenberg, Texas 77471 4822 Waynesboro Houston, Texas 77035 Stephen A. Doggett, Esq.

P. O. Box 592 Carro Hinderstein Rosenberg, Texas 77471 8739 Link Terrace Houston, Texas 77025 Robin Griffith 1034 Sally Ann D. Marrack Rosenberg, Texas 77471 420 Mulberry Lane Bellaire, Texas 77401 Leotis Johnston 1407 Scenic Ridge Brenda McCorkle Houston, Texas 77043 6140 Darnell Houston, Texas 77074 Rosemary N. Lemmer 11423 Oak Spring F. H. Potthoff, III Houston, Texas 77043 7200 Shady Villa, #110 Houston, Texas 77055 Kathryn Otto Route 2, Box 61L Wayne E. Rentfro Richmond, Texas 77469 P. O. Box 1335 Rosenberg, Texas 77471 Frances Pavlovic 111 Datonia James M. Scott Bellaire, Texas 77401 8302 Albacore Houston, Texas 77074 Charles Perez 1014 Montrose Bryan L. Baker Houston, Texas 77019 1118 Montrose Houston, Texas 77019 William Schuessler 5810 Darnell J. Morgan Bishop Houston, Texas 77074 11418 Oak Spring Houston, Texas 77043 Patricia L. Strelein Route 2, Box 395C Richmond, Texas 175$ 168