Corrected & Supplemental Answers by Public Utils Board of City of Brownsville,Tx in Response to Houston Lighting & Power First Set of Interrogatories & First Request for Production of Documents.Contains Info Re Sale of PowerML19256F520 |
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South Texas, Comanche Peak |
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11/07/1979 |
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TEXAS, STATE OF |
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Shared Package |
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ML19256F486 |
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NUDOCS 7912190319 |
Download: ML19256F520 (6) |
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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20155F7031988-06-10010 June 1988 Applicant Supplemental Responses to Case Discovery Requests.* Suppls Responses to Interrogatories 31 & 32 & Interrogatory 32 .W/Certificate of Svc. Related Correspondence ML20155F6751988-06-0808 June 1988 Applicant Supplementation to Answers to Case 850827 Interrogatories to Applicant (850827).* No Further Documents Will Be Provided in Response to Interrogatories H-3 & H-6. Certificate of Svc Encl.Related Correspondence ML20148D4911988-03-22022 March 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicant (870825).* Certificate of Svc Encl.Related Correspondence ML20148D0571988-01-22022 January 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicants (850827).* W/Certificate of Svc.Related Correspondence ML20236X3301987-12-0404 December 1987 Supplemental Response to Intervenors Document Production Request Dtd 870619.* Related Correspondence.Certificate of Svc Encl ML20236X3191987-12-0404 December 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant 850827.* Related Correspondence.Certificate of Svc Encl ML20236X2161987-12-0404 December 1987 Permittees Supplemental Response to Meddie Gregory Interrogatories & Request for Documents (Set 5).* Response to 870409 Interrogatories Re Seismic Design of Control Room Ceiling.Certificate of Svc Encl.Related Correspondence ML20235W1931987-10-0707 October 1987 Supplemental Response to Intervenors Document Production Requests.* Applicants Will Make Listed Matls Available to Intervenors Representatives for Exam & Copying in Dallas,Tx Ofcs.W/Certificate of Svc.Related Correspondence ML20235F2521987-09-22022 September 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Organization Charts Available for Review.Resumes Will Be Obtained Upon Request. W/Certificate of Svc.Related Correspondence ML20237L7181987-08-19019 August 1987 Supplemental Responses to Case Interrogatories Re Mac Rept & Issues Raised by Mac Rept ML20238A7531987-08-14014 August 1987 Responses to Consolidated Intervenors (870619) Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20237K1941987-08-10010 August 1987 Further Answers to Comanche Peak Review Team Interrogatories (Set 12) Re Reinsp Program for Random Errors.* Related Correspondence ML20236E8041987-07-22022 July 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20235G5011987-07-0606 July 1987 Case Supplementary Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc & Three Oversize Newspaper Articles Encl ML20215J8801987-06-19019 June 1987 Consolidated Intervnors Interrogatories & Reguest for Production of Documents to Applicant Texas Utilities Electric Co (870619).* Related Correspondence ML20215J7741987-06-19019 June 1987 Applicants Interrogatories to Intervenor (Set No. 1987-9).* Certificate of Svc Encl.Related Correspondence ML20215K2951987-06-15015 June 1987 M Gregory Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc Encl ML20214W5711987-06-0808 June 1987 Applicant Supplemental Responses to Case 860630 Interrogatories & Request for Documents.* Info Requested from Stone & Webster Submitted as Interrogatory 32.W/ Certificate of Svc.Related Correspondence ML20214W5601987-06-0606 June 1987 Case Response to Applicant Interrogatories to Consolidated Intervenors (Set 1987-1).* Case Would Object to & Moves for Protective Order Against Having to Go Into More Extensive Detail Pending Completion of Discovery ML20214P0861987-05-28028 May 1987 Further Answers to Interrogatories (Comanche Peak Response Team Sets 1-7).* Applicant Suppls Responses to Certain Interrogatories Propounded by Case,Per Board Orders Rendered on 861215.W/Certificate of Svc.Related Correspondence ML20214N1021987-05-21021 May 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Related Correspondence ML20206M4411987-04-15015 April 1987 Permittees Final Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0941987-04-13013 April 1987 Permittees Further Responses to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0201987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Responds to Interrogatories Re Housekeeping & Sys Cleanliness. Certificate of Svc Encl.Related Correspondence ML20206H0031987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205L8151987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205M2781987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Cables Must Be Separated from Conduits Inside Panels by Min Distance of 6 Inches.W/Certificate of Svc.Related Correspondence ML20205L8281987-03-28028 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-4) & Motion for Protective Order.* Applicant Discovery Conflicts W/Board Assurance That Case Will Have Sufficient Time to Analyze Data.W/Certificate of Svc ML20205R5201987-03-27027 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20204B7441987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-6) & Motion for Protective Order.* Identification of Experts Not Discoverable Due to Irrelevancy of Opinions Based on Work in Progress.Certificate of Svc Encl ML20205M1831987-03-20020 March 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Charts Available for Review. Resumes Obtained & Will Be Provided If Specifically Requested.W/Certificate of Svc.Related Correspondence ML20204B7211987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-5) & Motion for Protective Order.* Applicant Requests Premature & Unanswerable by Case Until Comanche Peak Response Team Discovery Complete.W/Certificate of Svc ML20204B6651987-03-18018 March 1987 Applicant Interrogatories to Consolidated Intervenors (Set 1987 -1).* All Instances of Alleged Applicant Intentional Conduct to Delay Const of Unit 1 Requested.Certificate of Svc Encl.Related Correspondence ML20212N5981987-03-0505 March 1987 Applicants Interrogatories to Intervenor (Set Number 1987-8).* Interrogatories Concern Application for Ol. Certificate of Svc Encl.Related Correspondence ML20212C8581987-02-26026 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-7).* Info Re Walsh/Doyle Issues &/Or Allegations Requested. W/Certificate of Svc.Related Correspondence ML20212D0511987-02-26026 February 1987 Applicant Interrogatories to Intervenor (Set 1987-6).* Set of Interrogatories Re Identifying Experts Consulted W/Or Retained by Intervenor W/Respect to Problems in Facility. Related Correspondence.Certificate of Svc Encl ML20212D1381987-02-24024 February 1987 Applicants Interrogatories to Intervenor (Set No. 1987-5).* Interrogatories Re Application for Ol.Certificate of Svc Encl.Related Correspondence ML20211F5681987-02-18018 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-4).* Certificate of Svc Encl.Related Correspondence ML20211C9641987-02-13013 February 1987 Permittees Supplemental Response (Motion for Protective Order) to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20211D0011987-02-10010 February 1987 Permittees Supplemental Responses to M Gregory Interrogatories (Set 5).* Suppls Responses to M Gregory Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20210E4481987-02-0303 February 1987 Permittees Initial Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20209B0791987-01-29029 January 1987 Applicant Interrogatories to Intervenor (Set 1987-3).* W/Certificate of Svc.Related Correspondence ML20209B0581987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20209B0321987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20212R6211987-01-27027 January 1987 Supplemental Staff Answers to Case Interrogatories.* Suppls 861205 Answers to Case 860922 Discovery Request & Interrogatories 2,4 & 8.Affidavit & Certificate of Svc Encl. Related Correspondence ML20212K6991987-01-21021 January 1987 Applicants Supplementation to Answer to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20207Q2721987-01-16016 January 1987 M Gregory Request for Production of Documents (Set 6).* Certificate of Svc Encl.Related Correspondence ML20212E7501986-12-30030 December 1986 Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20211M9031986-12-0808 December 1986 Responds to Case 860918 Ninth Set of Interrogatories Re Comanche Peak Response Team Program Plan.Certificate of Svc Encl.Related Correspondence ML20211M8901986-12-0808 December 1986 Answers to Case 860918 Tenth Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence 1988-06-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARTXX-9915, Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed1999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20195E1481998-10-0202 October 1998 Confirmatory Order Modifying Licenses NPF-76 & NPF-80 Effective Immediately.Order Confirms Licensee Commitment, as Stated in Ltrs & 0604,to Complete Implementation of Thermo-Lag 330-1 Fire Barriers ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20236V2421998-07-28028 July 1998 Confirmatory Order Modifying License for Plant,Unit 1. Orders That,Effective Immediately,Tu Electric Shall Complete Final Implementation of Thermo-Lag 330-1 Fire Barrier Corrective Actions at Plant ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20094Q4581995-08-31031 August 1995 Exemption from Certain Requirements of 10CFR50,App J to Allow Performance of Required Periodic Type C Tests During Power Operation TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20085N3561995-06-21021 June 1995 Exemption from Requirements of 10CFR50.55a(f)(4)(ii) Re IST During Successive 120-month Intervals ML20085L8531995-06-14014 June 1995 Exemption from Certain Requirements of 10CFR73.55 Re Issuance,Storage & Retrieval of Badges for Personnel Granted Unescorted Access to Protected Areas,Per Util 950327 Application to Implement Geometry Biometric Sys ML20085L5021995-06-0909 June 1995 Exemption Granting One Time Exemption to Permit Schedular Extension of One Cycle for Preformance of App J ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20083M8731995-05-16016 May 1995 Exemption Granted from Certain Requirements of 10CFR73.55,to Implement Hand Geometry Biometric Sys for Site Access Control at Plant Such That Photographic Identification Badges May Be Taken Offsite ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20083A9941994-12-21021 December 1994 Response to Demand for Info (Dfi),Motion for Retraction of DFI & Alternatively,Request for Hearing ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20065L3661994-04-14014 April 1994 Exemption from Requirements of 10CFR50.71(e) to Resubmit Original Pages of FSAR ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals ML20045B8351993-06-0404 June 1993 Directors Decision 93-12 Partially Granting & Partially Denying Petition Filed Under 10CFR2.206,alleging New Evidence of Restrictive Settlement Agreements Entered Into by Util Re Plant ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ST-HL-AE-4428, Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans1993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans 1999-06-18
[Table view] |
Text
.<.. h UNITED STATES OF AMERICA
' ' P,
~
'r BEFORE THE NUCLEAR REGULATOR ~l COMMI3SIO:1 ya
^ :"i.1 ) T '
BEFORE THE ATOMIC SAFETY A:1D LICE::SI::G BOARD.
M(;'
In the Matter of
)
N's,
, a'
)
HOUSTOti LIGHTING & POWER COMPANY,
)
Do cke t No s. 50-498a et al.
)
and 50-499A
)
(South Texas Project, Unit Nos.
)
1 and 2)
)
)
)
)
In the Matter of
)
)
TEXAS UTILITIES GENERATING COMPANY,)
Docke t No s. 50-445A e' al.
)
and 50-446A
)
(Comanche Peak Steam Electric
)
Station, Unit Nos. 1 and 2)
)
ATTACHMENT A Interrogatory No. 7 7.
Detail every alternative that PUB has con-sidered to meet its maximum load forecast of 163 mi for 1985, including separate identification of: (a) every person that PUB has contacted or contemplated contacting about the purchase of bulk power; (b) the date of each such contact; (c) the response given to PUB; and (d) the identity and loca-tion of every document referring or relating to or setting forth the matters inquired into in this Interrogatory.
Interrogatory No. 8 8.
Identify every electric utility with which PUB has discussed the sale of electric power by such electric utility to PUB since January 1, 1968, and with respect to each such utility separately state:
(a) the date(s) upon which such utility discussed selling electric power to PUB; (b) the terms, if any, upon which such utility offered to sell electric power to PUB on each such date; and (c) the identity and location of every document referring or relating to or setting forth the matter,s,yf h 2 h1' inquired into in this Interrogatory.
7 912190 3/7 Interrogatory :Jo. 9 9.
Identify every electric utility (including affiliated or predecessor companies) from whom PUB has purchased electric power in each year since January 1, 1968, and with respect to each such electric utility for each such year separately state:
(a) the identity of the seller; (b) the type of power purchased, such as firm power, contract power, economy power, emergency power, and wholesale power; (c) the megawatts and megawatt-hours of electri-city purchased; (d) for each type of power purchase identified in (b), the sales price (s) per megawatt-hours and the number of megawatt-hours purchased at each such price; and (e)-
the identity and location of every document referring or relating to or setting forth the matters inquired into in this Interrogatory.
Response
Interrogatory Nos.
7, 8,
9 A copy of Burns & McDonnell's October 1979-1984 Capital Improvements Program Study of Power Supply and Electric Transmission and Distribution Systems is enclosed.
In August 1979, PUB and Texas Power & Light Company exa-cuted an agreement for the sale to PUB of interruptible off-peak economy energy, as available in an amount not to exceed 45 mw per hour.
Documents relating to this agreement are attached.
Also attached are documents relating to recent PUB inquiries directed to~ other Texas electric utilities con-cerning the purchase of base load capacity in existing or planned coal' nu lear or lignite generating units.
./*,h 262 T6 In:errca a tory :.a.
10 10.
Identify every electric utility (including affiliated companies) to which PUB has sold electric power in each year since January 1, 1968, and with respect to each such utility for each such year separately state:
(a) the identity of the purchaser; (b) the type of power sold, such as firm power, contract power, economy power, emergency power, and wholesale power; (c) the total megawatts and megawatt-hours of electricity sold; (d) for each type of electric power identified in (b), the unit price (s) per megawatt-hour and the number of megawatt-hours sold at each such price; and (e) the identity and location of every document referring or relating to or setting forth the matters inauired into in this Interrogatory.
Response
During two weeks in July 1979 PUB sold 9 mw of electric power to Union Carbide Corporation under the terms of the April 16, 19.64, Electric Service Contract.between PUB and Union Carbide.
e e
s W
TE2B $4h
.:p s.
_4-Interr:3gtory No. 15 15.
Identify every electric utility from which PU3 hac requested transmission services since January 1, 1968, but which has refused or declined to provide any of the transmission services requested, and with respect to each such electric utility separately state:
(a) the type of transmission service requested; (b) the date of the request; (c) the reason (s), if any, given for not providing the transmission services requested; and (d) the identity and location of every document referring or relating to or setting forth the matters inquired into in this Interrogatory.
Resconse In addition to the requests for and discussions con-cerning transmission services by CP&L in 1973, 1976, 1977 and 1978-1979 described in PUB's Initial Response to Houston Lighting & Power Company's First Set of Written Interrogatories, on information and belief, PUB requested wheeling services from CP&L during 1969 when PUB was con-sidering obtaining an allocation of power from the Falcon hydroelectric project.
PUB has obtained an agreement from CP&L to provide interruptible off-peak transmission service for the interrup-tible off-peak economy energy from Texas Power & Light Company described in its supplemental response to Interrogatory Nos.
7, 8, and 9, above.
This agreement has been filed at FERC as Schedule T to CPL Rate Schedule No. 51,
~
Interruptible Of f-peak Transmission Service between Central Power & Light Cmpany and the City of Brownsville, and notic%
by the Commission on September 28, 1979 in Central Power &
Light Company, Docket No. ER79-666.
Copies of CP&L's filing and the Commission's notice are attached.
. Interroca tory :!o. 22 22.
Identify every existing industrial customer since January 1, 1968, which is or has been served under a rate or tariff schedule under which it is or has been the only such customer served, and state separately for each such customer:
(a) the identity of the customer; (b) the location of the customer; (c) the principal product of the customer at the location at which it is or was being served; (d) the annual megawatts and megawatt-hours sold to such customer in each year since January 1, 1968; (e) the reasons for establishing the rate or tariff in effect; (f) the identity of all persons having knowledge of any contacts, negotiations or other communications concerning the establishment of the -rate or tarif f under which the customer is or has been served; and (g) the identity and location of every document referring or relating to or setting forth the matters inquired into in this Interrogatory.
Response
A copy of the Electric Service Contract between PUB and Union Carbide Corporation dated April 16, 1964 is attached.
s 8
.f
.i62D M+
g t..
d Interrogator / Mo. 32 32.
For each year since January 1, 1968, separa-tely state:
(a) the total amount that PUB has spent on advertising; (b) the total amount that PUB has spent to influence actual or potential customers to locate or expand existing facilities within the service area of PUB; (c) the total amount that PUB has spent to influence actual or potential customers to conserve electric power; and (d) the identity and location of every document referring or relating to or setting forth the matters inquired into in this Interrogatory.
Response
Since January 1, 1968, PUB has annually contributed
$25,000 to the Brownsville Chamber of Commerce.
(c)
Since approximately 1974, PUB has annually spent
+
about $1,000 or less on efforts to encourage its customers to conserve energy.
4
.