ML19269D903

Forwards Public Utils Boards of City of Brownsville,Tx Response to Houston Lighting & Power Co First Set of Interrogatories & First Request for Production of Documents. Affidavit & Certificate of Svc Encl

ML19269D903
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	05/02/1979
From:	White S SPIEGEL & MCDIARMID
To:	Stephens C NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML19269D904	List: ML19269D903 ML19269D919
References
NUDOCS 7906200299
Download: ML19269D903 (6)

Text

4. W law orriCES Qg SPIEGEL & McDIAR31ID 2600 VIRGINIA AVENUE N.W.

WASHINGTON. D.C. 20037 TELEPHONE (202) 333 4500 ROBERT C. MCDIARMIO TELECOPIE R (202) 333-2974 ROBERT HARLEY BEAR SANDRA J. STREBEL THOM AS C. TRAUGER ROBERT A. JABLON JOHN MICHAEL ADRAGNA JAMES N. HORWOOD CYNTHIA S. BOGORAD ALAN J. ROTH FRANCES E. FRANCIS h (M ASSACHUSETTS S AR ONLY)

GARY J. NEWELL DANIEL i DAVIDSON MARC R. PolRIER THOMAS N McHUGH,JR.

DANIEL J. GUTTM AN g 4@D 4g7 ,3 PETER K. M ATT w oAvio R. STRAUS 2

May 2, 1979 Mr. Chase Stephens, Chief  % ,A Docketing & Service Section N ,

U. S. Nuclear Regulatory Commission Washing ton , D. C. 20555 RE: Houston Lighting & Power Company, et al. (South Texas Project, Unit Nos. 1 and 2), Docke t Nos .

50-498A and 50-499A; Texas Utilities Generating Company, et al. (tomanche Peak Steam Electric Station, Unit Nos. 1 and 2), Docke t Nos. 50-445A and 50-446A

Dear Mr. Stephens:

Enclosed for filing in the above-captioned proceedings on behalf of the Public Utilities Board of the City of Brownsville, Texas are two originals and forty copies of the following:

" Response of the Public Utilities Board of the City of Brownsville, " was to Houston Lighting and Power Company's F .t Request for Production of Documents and to Houst: . Lighting & Power Company's First Set of Written Interrogatories" Please have the two extra copies enclosed date stamped and returned to this office in the envelope provided.

Respectfully submitted,

-[ A ,

[L Susa G. White k 2251 245 7 9 0 6 2 00W

1 ,

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

)

HOUSTON LIGHTING & POWER COMPANY, ) Docke t Nos. 50-498A et al. ) and 50-499A

)

(South Texas Project, Unit Nos. )

1 and 2) )

)

)

)

In the Matter of )

)

TEXAS UTILITIES GENERATING COMPANY,) Docket Nos. 50-445A et al. ) and 50-446A

)

(Comanche Peak Steam Electric )

Station, Unit Nos.1 and 2) )

RESPONSE OF THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE, TEXAS TO HOUSTON LIGHTING AND POWER COMPANY'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND TO HOUSTON LIGHTING & POWER COMPANY'S FIRST SET OF WRITTEN INTERROGATORIES The Public Utilities Board of the City of Brownsville, Texas, (" PUB") hereby responds to:

(1) Houston Lighting & Power Company's First Request for Production of Documents to the Public Utilities Board of the City of Brownsville, Texas; and (2) Houston Lighting & Power Company's First Set of Written Interrogatories to the Public Utilities Board of the City of Brownsville, Texas.

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s , Document Production Houston Lighting & Fower Company requests that the following documents be produced for inspection and copying:

1. All documents identified in response to Houston Lighting & Power Company's First Set of Written Interrogatories to the Public Utilities Board of the City of Brownsville, Texas.

2. All documents referring or relating to or set-ting forth testimony given by PUB or any other entity before the Public Utility Commission of Texas in Docket No. 1776 (Generic Rate Hearings) .

3. All documents referring or relating to or setting forth PUB's membership in ERCOT and requests for mem-bership in TIS.

4. All documents referring or relating to par-ticipation by PUB in the South Texas Project.

5. All documents referring to relating to or setting forth any solicitations and/or offers made to PUB regarding participation in the South Texas Projecr.

6. All documents referring or relating to or setting forth any consideration, analysis or study of PUB's operation or contemplated operation in synchronous intercon-nection with any utility operating in interstate commerce or any utility otherwise synchronously interconnected with a utility operating in interstate commerce (including any uti-lity located in Mexico).

7. All documents referring or relating to or setting forth contemplated transmission changes, additions and related connections by PUB necessary for PUB to take power from the South Texas Project, including any changes or additions required to the underlying lower voltage network.

8. Since 1965, all of PUB's annual reports, prospectuses, and FPC (now FERC) Form l's or comparable reports to other Federal or State agencies.

Response

Copies of documents requested herein are being supplied to HL&P under separate cover.

In addition to the documents supplied , certain of the minutes of meetings of the Public Utilities Board are 2251 247

- responsive to these interrogatories. The minutes are volumi-nous and will be made available to HL&P for inspection and copying in Brownsville, if HL&P so desires, at a mutually convenient time.

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Interrogatory No. 1

1. Separately state for PUB the total megawatts of generating capacity in each year since January 1, 1968, and define the basis upon which such capacity was measured, i.e.,

nameplate, maximum dependable capacity, etc.

Response

For each year since January 1, 1968, PUB has had installed nameplate generating capacity as follows:

53 1968 68.0 1969 68.0 1970 68.0 1971 68.0 1972 68.0 1973 113.0 1974 113.0 1975 119.6 1976 119.6 1977 119_.6 1978 113.0 1979 113.0 Interrogatory No. 2

2. Separately state for PUB in each year since January 1, 1968 the total megawatt-hours of electricity generated; the average cost of generation per megawatt-hour; the average cost of generation per megawatt-hour for operating costs excluding fuel, maintenance costs and fuel costs; the average cost of fuel per million BTU; and the average BTU per kilowatt hour. .

Response

Table 1, which is attached, provides the requested data for 1968 through 1978.

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Interrogatory No. 3

3. Separately describe for PUB each rate schedule under which PUB has extended or offered electric service to industrial customers since' January 1, 1968, and provide the criteria that each company used to define an industrial customer.

Response

Attached are copies of City of Brownsville Ordinances establishing and describing rate schedules under which PUB has extended electric service to its customers since January 1, 1968. Those rate schedules include the cri-teria an industrial customer must meet to be eligible for service under the specific rates.

PUB will shortly establish new rate schedules.

Copies of such schedules will be provided when they become available.

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