ML19254F400
| ML19254F400 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 09/17/1979 |
| From: | Price W, Stahl D CENTRAL POWER & LIGHT CO., ISHAM, LINCOLN & BEALE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7911090192 | |
| Download: ML19254F400 (12) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
S S
HOUSTON LIGHTING & POWER S
NRC DOCKET NOS. 50-4984 COMPANY, THE CITY OF SAN S
50-499A ANTONIO, THE CITY OF AUSTIN, 5
and CENTRAL POWER AND LIGHT S
COMPANY S
(South Texas Project, Unit S
Nos. 1 and 7}
S ll TEXAS UTILITIES GENERATING 9
NRC DOCKET NOS. 50-445A COMPANY, ET AL.
S 50-446A (Comanche Peak Steam Electric S Station, Unit Nos. 1 and 2)
S CENTRAL POWER AND LIGHT COMPANY'S FIRST AMENDED AND SUPPLEMENTAL ANSWERS TO HOUSTON LIGHTING & POWER COMPANY'S FIRST SET OF INTERROCATORIES o
Central Power and Light Company
(" CPL") hereby files its First Amended and Supplemental Answers to Houston Lighting & Power Company's First Set of Interrogatories as follows:
Interrogatory No.
3.
The part of this Answer which refers to the " Industrial Power Rate" (page 3) should be supplemented by adding the following:
"Even though the Industrial Power Rate is designed for customers whose load exceeds 600 kw, if the customer operates at a sufficiently high load factor, it may be to the customer's advantage to 1309 356
/92 00 9
a; 7911 TVt
. be served under the Industrial Power Rate, even though usage is less than 600 kw".
The part of this Answer which refers to the "Small Irrigation Pumping Rate" (page 4) should be supplemented by stating that this rate was increased in 1977 as well as in 1973.
The part of this Answer which refers to the two " Petroleum Service Rates" (pages 4-5) should be supplemented to clarify that these rates were instituted in 1973.
The part of this Answer which refers to the "Muni-cipal Power Rates" (page 5) should be amended to clarify that these rates are applied to " municipal customers and other customers such as privately owned water supply systems serving the general public...".
Interrogatory No. 10.
The last sentence in the first full paragraph of this Answer (beginning "[m]oreover, between June and November, 1978...") should be deleted, and the following added:
"In January, 1979, MEC-STEC discon-tinued its purchases of firm power from CPL, and began purchasing firm power from the City Public Service Board of San Antonio because the City Public Service Board offered a lower rate.
CPL was willing and able to continue selling firm power to MEC-STEC".
Interrogatory No. 15.
CPL has had discussions with representative of other CSW subsidiary companies con-cerning the possibility of sharing future generating units 1309 337
.. ' with those companies.
CPL has, from time to time, purchased hydro power and energy from Falcon Dam and Guadaloupe Blanco River Authority.
CPL has also had seasonal power exchanges with CFE (Mexico) based upon diversity of load.
For many years, CPL has engaged in energy exchanges with LCRA primarily to reconcile border-line loads within each other's service territory. Documents relating to the matters referred to in this answer to interrogatory are located in the offices of M.
L.
Borchelt, W.
P.
- Smith, Jr., J. M.
Mabe, the CPL System Planning Department, the Victoria Dispatching Office, the Rates and Regulatory Affairs Department and the Administrative Services Department, and will be made available to HLP upon request.
Interrogatory No. 20.
The Answer to this Interrogatory should be supplemented by adding " Glen Chruchill" to the list of persons with knowledge on page 23.
Interrogatory No. 44.
The Answer to this Interrogatory should be supplemented by adding " Larry Gawlik, John Davidson, M.
I. Miller, T.
G.
Ryan, W. N. Woolsey, Ralph Weston, Durwood Chalker, Merle Borchelt and Chuck Orsak" to the list of per-sons with knowledge on page 44.
Interrogatory No. 49.
The Answer to this Interroga-tory should be supplemented by adding to the first full para-graph on page 52 the following:
"Likewise, in the event the FERC or the NRC ordered TU and/or HLP to engage in wheeling or provide other transmission services, not all of those I
i 1309 338
. transmission lines would necessarily have to be constructed.
For example, a wheeling order under Sections 211 and 212 of the Federal Power Act, as amended by PURPA, would probably remove the necessity for the so-called ' contract path' be-tween SWEPCO and CPL".
Interrogatory No. 56.
Persons who CPL expects to call or present expert testimony on its behalf, and the sub-stance of the facts and opinions to which each is expected to testify, include:
(a)
A. J. Wood, who is expected to testify about the studies performed under his supervision and direction concerning the economies and reliability of operating the
'CSW operating companies centrally-dispatched with and without interconnections with the non-CSW ERCOT companies.
Dr. Wood will also testify about the effect on CPL, in terms of cost and reliability, of CPL's loss of participation in the South Texas Project.
In general, Dr. Wood will testify that his studies demonstrate that the costs of operating the four CSW subsidiaries in synchronism are less than if the i
four CSW subsidiaries operate in their historical pattern (e.g.,
CPL and WTU within ERCOT, but effectively separate from PSO and SWEP) and that this is particularly true if the CSW Texas companies (CPL and WTU) can also retain their interconnections with the other ERCOT companies, and if CPL is permitted to retain its ownership share in the STP.
The 1309 339 specific basis for Dr. Wood's testimony are the various pro-duction costing studies performed by PTI and the multi-area loss of load probability study conducted by PTI in late 1976 and early 1977, as well as his general knowledge and ex-perience.
(b)
F. George Arey, who is expected to testify about the results of the various load-flow and stability studies which were performed under his supervision and direction in order to determine whether the four CSW com-panies can be synchronously operated - and ERCOT and the SWPP can be interconnected - without causing adverse effects to electric systems in ERCOT.
Generally, Mr. Arey will explain the method used to design e transmission system and testify that the system he has designed is capable of (1) providing acceptable and fully adequate service under normal conditions, and (2) withstanding one or more " contingencies" without interruption of service or other adverse effect.
(c)
J. A.
Bruggeman, who is expected to testify that the four CSW companies can operate at a lower cost by engaging in centralized dispatch among themselves than if they continue to operate in their historical mode, par-q ticularly if CPL and WTU can retain their interconnections i
with non-CSW ERCOT companies, and if CPL can retain its ownership share of the STP.
Mr. Bruggeman will further testify that synchronous operation of the four CSW companies 1309 340 with interconnections with non-CSW ERCOT companies will not have any adverse effect on any ERCOT company, and will not require any ERCOT company to construct any additional trans-mission line.
The basis for Mr. Bruggeman's testimony will be the various production costing, load flow and stability studies which he has performed and in which he has par-ticipated, as well as his general knowledge and experience.
With respect to Dr. Wood, Mr. Arey and Mr. Brug-geman, see also the Answer to Interrogatory No. 47.
(d)
John T. Wenders, who is expected to testify concerning the nature and extent of competition as it exists within the electric utility industry both in general and, more specifically, in Texas and the surrounding area.
It is also expected that Dr. Wenders will testify about the economic impact of restrictions on the purchase, sale and other exchanges of electricity and limitations on access to various transmission services.
Dr. Wenders will testify about the nature, extent and role of competition in various relevant markets within the electric utility industry as well as the general structure of the industry.
He will testify about market shares and market power in the relevant markets and the conduct of various electric utilities in those markets.
Also, Dr. Wenders may testify regarding the relief necessary to alleviate any actual or potential anti-competitive situation related to the licensing of the South 1309 34I Texas and/or Comanche Peak plants.
The opinions expected to be expressed by Dr. Wenders will be based, at least in part, on his review of the plead-ings, discovery materials and depositions in this proceeding as well as related cases and proceedings, inozuding his testi-mony in the federal district court antitrust case and the information and materials reviewed in connection with that case.
Dr. Wenders is also expected to rely upon his research and experience in economics, information and materials gathered in unrelated proceedings, the record in this con-troversy and conversations and other research into the opera-tion of electric utilities both within and outside of Texas.
CENTRA OWER AND LIG CO.
/// /
BY:
One of its A torneys ISHAM, LINCOLN & BEALE 1050 17th Street, N.W.
Suite 701 Washington, D.C.
20036 (202) 833-9730 j } }g
} /} }
September 17, 1979
STATE OF TEXAS
)
)
SS COUNTY OF NUECES
)
VERIFICATION I, W.
C.
Price, having been duly sworn, do depose and say that I am a Vice-President of Central Power and Light Company, that I have read the foregoing Amended and Supplemental Answers and that the facts stated therein are true and correct to the best of my knowledge.
hk $.
str 2 W.
C.
Price
-l, SUBSCRIBED AND SWORN to before,me this
/'/ r,6 day of i g/x,,,1,J, 1979.
'/
,W M LDA Y.PEREZ Notary Public 8 My comission expires 1-31-81.
j 3(')9 b k
~
r CERTIFICATE OF SERVICE I hereby certify that service of the foregoing CENTRAL POWER AND LIGHT COMPANY'S FIRST AMENDED AND SUPPLE-MENTAL ANSWERS TO HOUSTON LIGHTING & POWER COMPANY'S FIRST SET OF INTERROGATORIES were served upon the following persons by deposit in the United States mail, first-class postage prepaid, this 9th day of October, 1979.
/
/
/
1309 344
_1_
Marshall E. Miller, Esq.
Roy P.
Lessy, Jr., Esq.
U.S. Nuclear Regulatory Commission Michael B.
Blume, Esq.
Washington, D.C.
20555 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Michael L.
Glaser, Esq.
1150 17th Street, N. W.
Roff Hardy Washington, D. C.
20036 Chairman and Chief Executive Officer Shelden J. Wolfe, Esq.
Central Power & Light Co.
U.S. Nuclear Regulatory Commission P. O.
Box 2121 Washington, D.C.
20555 Corpus Christi, Texas 78403 Atomic Safety and Licensing G. K. Spruce, Gen. Manager Appeal Board Panel City Public Service Board U.S. Nuclear Regulatory Commission P.
O.
Box 1771 Washington, D.
C.
20555 San Antonio, Texas 78203 Chase R.
Stephens (20)
Mr. Perry G.
Brittain D7cketing and Service Section President L.S. Nuclear Regulatory Commission Texas Utilities Generating Co.
Washington, D.
C.
20555 2001 Bryan Tower Dallas, Texas 75201 Jerome D.
Saltzman Chief, Antitrust and Indemnity Group R.
L.
Hancock, Director U.S. Nuclear Regulatory Commission City of Austin Electric Utility Washington, D.C.
20555 P.
O.
Box 1088 Austin, Texas 78767 J.
Irion Worsham, Esq.
Merlyn D.
Sampels, Esq.
G. W.
Oprea, Jr.
Spencer C.
Relyea, Esq.
Executive Vice President Worsham, Forsythe & Sampels Houston Lighting & Power Co.
2001 Bryan Tower, Suite 2500 P. O. Box 1700 Dallas, Texas 75201 Houston, Texas 77001 Jon C. Wood, Esq.
Michael I.
Miller, Esq.
W.
Roger Wilson, Esq.
Isham, Lincoln & Beale Matthews, Nowlin, Macfarlane & Barrett One First National Plaza 1500 Alamo National Building Chicago, Illinois 60603 San Antonio, Texas 78205 Morgan Hunter, Esq.
J.
A.
Bouknight, Esq.
Bill D.
St. Clair, Esq.
Bill Franklin, Esq.
McGinnin, Lockridge & Kilgore Lowenstein, Newman, Reis, Axelrad Fifth Floor, Texas State
& Toll Bank Building 1025 Connecticut Avenue, N. W.
900 Congress Avenue Washington, D.
C.
20036 Austin, Texas 78701 R. Gordon Gooch, Esq.
Don R.
Butler, Esq.
Baker & Botts 1225 Southwest Tower 1701 Pennsylvania Avenue, N. W.
Austin, Texas 78701 Washington, D. C.
20006 1309 345
-27 Jerry L. Harris, Esq.
W.
S. Robson Richard C. Balough, Esq.
General Manager City of Austin South Texas Electric P. O.
Box 1088 Cooperative, Inc.
Austin, Texas 78767 Route 6, Building 102 Victoria Regional Airport Joseph B.
- Knotts, Jr.,
Esq.
Victoria, Texas 77901 Nicholas S.
Reynolds, Esq.
Debevoise & Liberman Robert C. McDiarmid, Esq.
1200 17th Street, N.
W.
Robert A. Jablon, Esq.
Washington, D. C.
20036 Marc R.
Poirier Speigel & McDiarmid Don H.
Davidson 2600 Virginia Avenue, N.W.
City Manager Washington, D.
C.
20036 City of Austin P.
O.
Box 1088 Kevin B.
Pratt Austin, Texas 78767 Texas Attorney General's Office P. O. Box 12548 Jay Galt, Esq.
Austin, Texas 78711 Looney, Nichols, Johnson & Hays 219 Couch Drive William H. Burchette, Esq.
Oklahoma City, Oklahoma 73102 Frederic H.
Ritts, Esq.
Law Offices of Northcutt Ely Knoland J.
Plucknett Watergate Building Executive Director Washington, D.
C.
20037 Committee on Power for the Southwest, Inc.
Wheatley & Miller 5541 East Skelly Drive 1112 Watergate Office Bldg.
Tulsa, Oklahoma 74135 2600 Virginia Avenue, N.W.
Washington, D.
C.
20037 John W.
Davidson, Esq.
Sawtelle, Goods, Davidson & Tiolo Joseph Rutberg, Esq.
1100 San Antonio Savings Building Antitrust Counsel San Antonio, Texas 78205 Counsel for NRC Staff U.S. NRC Washington, D.
C.
20555 Douglas F.
John, Esq.
Linda L. Aaker, Esq.
Akin, Gump, Haver & Feld Asst. Attorney General 1333 New Hampshire Avenue, N. W.
P.
O. Box 12548 Suite 400 Capitol Station Washington, D.
C.
N. Woolsey, Esq.
Robert M.
Rader Dyer and Redford Conner, Moore & Corber 1030 Petroleum Tower 1747 Pennsylvania Ave.,
N.W.
Corpus Christi, Texas 78474 washington, D.C.
20006 Donald Clements Melvin G. Berger, Esq.
Gulf States Utilities Company Ronald Clark, Esq.
P.
O.
Box 2951 Antitrust Division, Energy Beaumont, Texas 77704 Section Room 8308 414 lith Street, N.W.
Washington, L.C.
20530 1309 346
.- Charles G.
Thrash, Jr., Esq.
Joseph J.
Saunders, Esq.
E. W.
Barnett, Esq.
Chief, Public Counsel &
Theodore F. Weiss, Esq.
Legislative Section J.
Gregory Copeland, Esq.
Antitrust Section Baker & Botts U.S.
Department of Justice 3000 One Shell Plaza P.
O. Box 14141 Houston, Texas 77002 Washington, D.
C.
20044 Donald A.
Kaplan, Chief Robert E.
Bathen Robert Fabrikant, Asst. Chief R.
W.
Beck & Associates Energy Section P.
O. Box 6817 Antitrust Division Orlando, Florida 82853 U.S.
Department of Justice Washington, D.C.
20530 3 'n) 341
.