ML19273B257

Answer of Tx Utils Generating Co & Subsidiaries to NRC Interrogatories & Requests for Production of Documents. Provides Detailed Responses to Interrogatories 1-35 & 37-39. Certificate of Svc Encl

ML19273B257
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	03/05/1979
From:	Worsham J WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:
References
NUDOCS 7904060033
Download: ML19273B257 (15)

Text

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' UNITED STATES OF Ahr u A ,

NUCLEAR REGULATORY COMMISSION N # .C /

3EFORE THE ATOMIC SA~TY AND LICENSING 30ARD \.

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In the Matter of 5 5

HOUSTON LIGHTING & POWER 5 NRC Docket Nos. 50-498A COMPANY, PUBLIC SERVICE 5 50-499A BOARD OF SAN ANTONIO, CITY OF 5 AUSTIN, CENTRAL POWER AND 5 LIGHT COMPANY 5 (South Texas Project, Unic Nos. 5 1 and 2) 5 5 i TE'GS UTILITIES GENERATING S NRC Docket Nos.}50-445A COMPAN", et al. 5 50-44 '

(Comanche'7ead Steam Electric 5 Station, Units 1 and 2) 5 ANSWER OF TEXAS UTILI"IES COMPANY AND ITS SUBSIDL1 RIES TO THE liRC STAFF'S INITIA INTERROGATORIES AND REn,UESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDED TO HOUSTON LIGHTING

& POWER COMPANY AND TE:GS UTILITIES GENERATIliG COB 9A Ti COME NOW TEXAS UTILITIES CO'9ANY ("TU") , TEXAS UTILITIES GENERATING COMPANY ("TUGC0"), DALLAS POWER & LIGHT COMPAliY ("DPL"),

TEXAS ELECTRIC SERVICE COMPAIPf ("TESC0") , AND TE'GS POWER & LIGHT COMPANY ("T?L"), all collectively referred to as "TU Cocoanies," in comoliance with Section 2.740b and 2.741 of the Rules of Practice of 'the Nuclear Regulatory Cocsission ("NRC") , and cake the folicwing answers to the NRC Staff's Initial Inter-ogatories and Recuests for Production of Documents Propounded to Houston Lighting & Power Coccany and Texas Utilities Generating Comoany.

Most of the interrogatories request information with respect to both the TU Companies and Hous ton Lighting & Power Company ("HLP") .

The answers filed herewith are for and on behalf of the TU Coenanies only. The TU Companies informally agreed to cooperate with the NRC Staff by providing a response to Interrogatories 1-35 and 37-39 on March 1, 1979. The response to Interrogatory No. 38 is amended herein. Reference is cade to the Objections and Motion for Protec-tive Order filed contemporaneously herewith.

Interrocatorv 36. Provide data with respect to each interconnection at 110 kv or above that ' L&P/TU F has or plans to have with another coccany or with each other by 1987, as follows:

79040600 8

a. nace of the interconnected electric utility;

b. length of the portion of the interconnection owned by

. EL&P/TU and length of the porrion of the interconnection owned by the other electric utility;

c. date that the interconnection was first cocsitted;

d. date that the interconnection was or will be energited;

e. kv rating and MVA or accere normal and emergency ratings as used by the EL&P/TU operators ;

f. relay loadability in a= peres;

g. method of determining the value specified in (f);

h. cost of the right-of-way;

i. cost of the transmission line;

j. cost of the terminal facilities at each end of the line;

k. any documents suggesting that the interconnection has had or may have an adverse i= pact on any other electric utility other than those directly interconnected by the intercon-nection line;

1. compensation paid or to be paid to any electric utility other than those directly interconnected by the line , because of the impact of the interconnection on the other electric systems;

m. identify by title, date, etc. each load flow case, each transient stability case, each cost or economic feasibility study, and each engineering report conducted or prepared in connection with the planning of the interconnection;

n. designate each electric utility that contributed monetarily to the planning studies nade in connection with the inter-connection; 2

o. for existing interconnections, dates of each instance since 1965 when the interconnection was manually or automatically opened because of an overload condition; and

p. for existing interconnections, dates of each instance since 1965 when the interconnection was manually opened or auto-matically opened for more than 60 seconds for reasons other than overload, and discussion of the reasons.

Answer.

a. The TU companies are interconnected directly or indirectly with the member systems of ERCOT.

b. See answer to Interrogatory 37.

c-d. No such records are kept.

e-g. See answer to Interrogatory 37.

h-k. No such records are kept.

1. None.

2-p. No such records are kept.

Int 2rrocatorv 38. Provide dates for each instance since 1965 that load has been manually or automatically shed by TU/HL&P, and dis-cuss the approximate amount of load shed, the length of time, the method used, and the cause.

Amended Answer. The TU Companies are not aware of any such inscances ,

except that the underfrecuency relays on the TU System have malfunc-tiened on a small number of occasions and that on a few occasions the load to Alcoa Aluminns has been interrupted by agreement of the parries. No records are kept with respect thereto.

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Interrogatorv 40. Provide a listing of each load flow case and each transient stability case used in the analysis of the transmission recuirements for the South Texas and Comanche Peak units , including:

a. the case nu=ber;

b. the date when the case was run;

c. the case title;

d. description of the condition studied if not indicated by the case title;

e. any su=rnary discussions of the case that were prepared; and

f. for the stability studies, designation of any unstable cases.

Answer. The cost recent study of the Comanche Peak area is attached. No prior studies are kept.

Interrozatorv 41. Describe the organicational and administrative structure used for conductiIng the load flow and transient s tability studies for the transmission planning for the South Texas Units or Comanche Peak Units including, but not necessarily limited to:

a. listing of each electric utility involved in the studies, and description of how each was represented, including na=es and titles of those senior professional and manage-rial persons who actively participated in the studies;

b. methods and formulae used in allocating costs of the studies among the electric utility participants;

c. methods and for=ulae used in allocating the decision caking rights among the electric uti3ity carticipants- ,

d. description of any cocmittees or similar study groups with oversight resnonsibilities with resnect to the areparation or analysis.of the studies; 4

description of the cocouter facilities used and the nethod e.

of interfacing with the srudy group;

f. names acd affiliations of those senior personnel responsible for collecting, coordinating and checking or otherwise pre-paring the input dara;

g. names and affiliations of those senior personnel responsible for the final determination of the system configurations and conditions that were studied; and

h. names and affiliations of those responsible for the analysis of the results.

Answer.-

a. The electric utilities involved are the TU Co=panies and TMPA. Each senior planning engineer therefrom, who changes from tine to cine, is the person responsible therefor. At present the chief engineers for DPL, TESCO and TFL are Messrs. R. K. Payne, Willie Keel and T. L. Hatcher, respec-tively.

b. Third party studies are paid for on a pro rata basis. Each company pays its own costs on work it performs.

c-d. See the Cemanche Peak operating agreement.

e. Various computer facilities are used from time to time, f-h. See a. and d. above.

Interrocatorv 42.

a. Provide a conputer printout, including input data and area interchange sucmaries, of the latest normal peak load system condition load flows for the time that the South Te:cas Units or Comanche Peak Units will first be in ecm-5

cercial operation.

If the actual system configurations have not been determined as vet, and several system configurations are being considered, orovide the co= outer orintouts for each configuration and describe the considerations or f ac-tors which will determine the final configuration.

b. Provide a transmission man suitable for identifying the location of each bus used in the load flow analysis in terms If of X-Y coordinates, and so identify each bus location.

not clearly indicated by the cocputer printout, provide the following:

1. nominal bus voltages; su==ary of area interchanges; and

2. ~

3. the control area in which each bus is located.

Answer.

a. See printout attached,

b. See printout attached.

Interrocatorv 43.

a. Provide all documents discussing or describing the i=cacts of the transmission for the South Texas Units and/or Comanche Peak Units on the underlying voltage cransmission systems.

b.

Provide all documents recc= rending changes to the underlying transmission as recuired to integrate the South Texas and/or Comanche Peak Units into the overall and respective systems.

c. EL&P: provide all docu=ents discussing compensation to due to the non-participants in the South Texas Project inpact of the South Texas Project on non-particicant systecs.

Answer.

a-b. See answer to Interrogatory 42 above.

c. Not applicable.

Interrogatorv 44 P r c , s .' - all docunents perraining to cost estimates.

and cost allocations for the transmission additions and related con-nections chargeable to the South Texas and/or Comanche Peak Units ,

bacluding any changes or additions recuired to the underlying lower voltage networks.

Answer. Preliminary cost estimates for transmission by the TU Company which will connect Comanche Peak to load centers are as follows:

$ x 1,000 DeCordova Substation-Comanche Peak 138 kv line 625 DeCordova SES-Comanche Peak 345 kv line 2,689 Comanche Peak-Parker 345 kv line 9,318 Comanche Peak-Cleburne Junction 345 kv line 6,099 Cleburne Junction-Evernan 345 kv line 6,522 DeCordova-Benbrook 345 kv (307. of right-of-way and towers) 1,458 Comanche Peak-DeCordova-Benbrook (conductor only) 3,138 Evernan-Sherry Tap (conductor only) 636 Sherry Tap-Century (conductor for 1 circuit and associated tower and right-of-way) 463 Cleburne Junction-Line connections change 150 DeCordova Substation-DeCordova 138 kv line 807 DeCordova 138 kv C3 and 1-345 kv C3 873

~

Parker Switching S tation 345 kv 'CB 's 1,684 Sherry 345 kv-CB 414 Benbrook 345 kv CB 616

Interrocatorv 45. Provide the latest cost esti=ates for the trans-mission additions and related connections, including any additions required to the underlying icwer voltage networks, for the South Te.xas or Comanche Peak Units. Provide separate cost estimates for:

a. Right-of-way;

b. Extra High Voltage (EHV) transmission lines;

c. EVE terminal facilities;

d. Lower voltage (LV) additions and connections;

e. Allocation of costs to each participant; and

f. Compensation to non-participants due to the impact of South Texas transmission.

Answer,

a. $4,414,000

b. $26,147,000

c. $3,330,000

d. $1,601,000

e. See answer to Interrogatory 44 above.

f. Not applicable ,

J Interrocatorv 46. List er.d describe all instances that TU/HLP has paid or plans to pay compensation to another electric utility due to the i= pact that its transmission additions has had or will have on other electric systems.

Answer. None.

Interrogatory 47. List and describe all instr.ces of which TU/HL?

is aware in which any electric utility has paid compensation to S

ancther electric utility due to the i= pact that the transmission ad-ditions of the one utility had or may have had on the system of another Answer. The TU Cc=panies are not aware of a proposed forced intercon-nection which would have the severe impact on another utility that 4-"lecentation of Mode 4 would have on the TU System. The TU Companies are not aware of, and have not inquired as to, the details and specific arrangements made in other forced interconnection situations.

Interrozatorv 48. Identify and provide each operating guide, each written set of instructions, directions, tabulaticns or other means used by the system operators to conitor maximum transmission line loadings.

Answer. The TIS operating guide has been oreviously orovided.

Interrozatorv 49.

a. Does ELP/TU employ any different system design criteria for developing bulk transmission and generation than is required by TIS?

b. If so, please explain such different criteria.

Answer.

a-b. Criteria employed by each system are not different from TIS criteria, but are additional to TIS criteria where TIS cri-teria are not comorehensive or are silent.

Interrogatorv 50.

a. TU: Describe in detail the assign =ent of Chas. T. Main, Inc.

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relating to a review of the PTI Study.

b. List the date of the assign =ent(s) with a brief descrip-tien thereof.

c. List the professional and managerial personnel of TU and of Chas. T. Main, Inc. involved in the assignment (s).

d. Semmnrize the results and conclusions reached by Chas . T.

Main, Inc.

e. Provide all documents which relate to this interrogatory.

Answer.

a-b. Chas. T. Main, Inc. were employed from April,1976 -

July, 1977, to review the PTI Study.

c. From Chas. T. Main, Inc. Robert C. Ender Southeast Tower Caleb H. Didriksen, Jr.

Prudential Center Harry E. Smith Boston, Massachusetts 02199 Robert A. Mills Arthur E. Fitzgerald From Texas Utilities Services Perry G. Brittain Inc. Roy R. Parks 2001 Bryan Tower Edward L. Busby Dallas, Texas 75201 L. W. Hart, Jr.

From Texas Electric Service E. D. Scarth Co. . Lee Westbrook P. O. Box 970 Ft. Worth, Texas' 76101

d. The PTI report was biased and therefore its conclusions are not reliable. .

e. See answer to Interrogatory id-e.

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Respectfully submitted Jos. Irion Worsham, Esq.

M. D. Sampels, Esq.

Spencer C. Relyea, Esq.

WORSHAM, FORSYTHE & SAMPELS 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201

. Joseph B. Knotts, Jr., Esq.

Nicholas S. Reynolds, Esq.

DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.

Washington, D.C. 20036 B - - - - - .. -

ATTORNEYS FOR TEXAS UTILITIES COMPANY, TEXAS UTILITIES GENERATING COMPANY, DALLAS POWER & LIGHT COMPANY, TEXAS ELECTRIC SERVICE COMPANY AND TEXAS POWER & LIGHT COMPANY 11

THE STATE OF TEXAS )

COUNTY OF TARRANT )

BEFORE ME, the undersigned authority, a Notary Public in and for Tarrant County, Texas, on this day personally appeared E. D. SCARTH, well known to me to be a credible person, who after being by me first duly sworn, did depose and say that he is duly authorized to respond to the NRC Staff's Initial Interrogatories and Requests for Production of Documents Propounded to Houston Lighting & Power Company

.and Texas Utilities Generating Ccmpany on behalf of the TU Companies, has read the above and foregoing Answers of the TU Companies to Interrogatories 36 and 40-50 from the NRC Staff, and the same are true and correct, to the best of his kncwledge and belief.

J A

E. D. Scarth SUBSCRIBED AND SWORN TO before me this 5th day of March, 1979, to certify which witness my hand and seal of office.

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% 4J ad Paula newatt, Notary Public, Tarrant County, Texas My Commission Expires December 27, 1980 12

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

HOUSTON LIGHTING & POWER  : NRC Docket Ncs. 50-498A COMPANY, PUELIC SERVICE -

50-499A BOARD OF SAN ANTONIO, CITY CF  :

AUSTlN, CENTRAL POWER AND  :

LIGHT COMPANY  : ,

(South Texas Project, Unit Nos.  :

I cnd 2)  :

TEXAS UTILITIES GENERATING  :

COMPANY,le oj.  : NRC Occket Nos. 50-445A (Ccmenche Peck Stecm Electric  : 50-446A Station, Units I cnd 2)  :

CERTIFICATE OF SERVICE 1 hereby certify that service of the foregoing ANSWER OF TEXAS UTILITIES COMPANY AND ITS SUBSIDIARIES TO THE NRC STAFPS INITIAL INTERPOGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS PROPOUNDED TO HOUSTCN LIGHTING & POWER COMPANY AND TEXAS UTILITIES GENERATING COMPANY has been mcde on the following pcrties listed hereto this 5th dcy of March ,1979, by depositing copies thereof in the United States mail, first cicss, postcge prepcid:

Marshall E. Miller, Esq. (2 copies) Richard S. Scizmcn, Esq.

U. S. Nuclecr Regulctory Ccmmission U. S. Nuclecr Regulatory Commission Washington, D. C. 20555 Wcshington, D. C. 20555 Michcel L. Glaser, Esq. (2 copies) Jerome E. Shcrfmcn, Esq.

115017th Street, N. W. U. S. Nuclect Regulatory Commission Wcshington, D. C. 20036 Washington, D. C. 20555 Shelden J. Wolfe, Esq. (2 copies) Chase R. Stephens, Secretary (20 ccpies)

U. S. Nuclect Regulatory Ccmmission Decketing cnd Service Brcnch Wcshington, D. C. 20555 U. S. Nuclect Regulatory Commission Wcshingten, D. C. 20555 Scmuel J. Chilk, Secretcry Jerome Scitzmcn Office of the Secretary of the Commission Chief, Antitrust cnd Indemnity Group U. S. Nuclect Regulctory Commission U. S. Nuclecr Regulatory Commission Washington, D. C. 20555 Wcsnington, D. C. 20555 Atcmic Safety & Licensing Appect Roff Hcrdy Board Penel Chairmen cnd Chief Executive Officer U. S. Nuclear Reguictory Commission Central Power & Light Compcny Wcshingten, D. C. 20555 P. O. Box 2121 Corpus Christi, Texas 78403

Michcel I. Miller, Esq. G. K. Spruce, Richcrd E. Powell, Esq. Genercl Mcncger David M. Stchl, Esq. City Public Service Becrd Thomcs G. Rycn, Esq. P. O. Box 1771 Ishem, Lincoln & Becle Scn Antonio, Texcs 78203 One First National Plczc Chiccgo, Illinois 60603 Roy P. Lessey, Esq. Jerry L. Harris, Esq.

Michcel Blume, Esq. City Attorney, U. S. Nuclect Regulaterr Commission Richard C. Eclough, Esq.

Wcshington, D. C. 20555 Assistent City Attomey City of Austin R. L. Hcncock, Director P. O. Box 1088 City of Austin Electric Utility Depcrtment Austin, Texcs 78767 P. O. Box 1088 Austin, Texas 78767 Robert C. McDictmid, Esq. G. W. Oprec, Jr.

Spiegel and McDicrmid Executive Vice President 2600 Virginic Avenue, N. W. Houston Lighting & Power Compcny Washington, D. C. 20036 P. O. Box 1700 Houston,Texcs 77001 Ocn H. Ocvidson Jon C. Wood, Esq.

City Mancger W. Roger Wilson, Esq.

City of Austin Mctthews, Nowlin, Mccfcricne & Scrrett P. O. Box 1088 1500 Alcmo National Building Austin, Texas 78767 Scn Antonio, Texcs 78205 Joseph Gallo, Esq. Judith Hctris, Esq.

Richcrd D. Cudchy, Esq. Energy Section Robert H. Loeffler, Esq. Antitrust Division Isham, Lincoln & Becle U. S. Department of Justice Suite 701,105017th Street, N. W. Washington, D. C. 20530 Wcshington, D. C. 20036 Douglas F. John, Esq. R. Gordon Gcoch, Esq.

Akin, Gump, Hcuer & Feld John P. Mathis, Esq.

1100 Madison Office Building Bcker & Botts 115515th Street, N. W. 1701 Pennsylvanic Avenue, N. W.

Wcshington, D. C. 20024 Wcshington, D. C. 20006 Morgen Hunter, Esq. Rcbert Lowenstein, Esq.

McGinnis, Lochridge & Kilgore J. A. Bouknight, Esq.

5th Floor William Frcnklin, Esq.

Texcs State Scnk Building Lowenstein, Newmen, Reis & Axelred 900 Congress Avenue 1025 Connecticut Avenue, N. W.

Austin, Texas 78701 Wcshington, D. C. 20036

I Jay M. Galt, Esq. E. W. Bernett, Esq.

Looney, Nichols, Johnson & Hayes . Chcries G. Thresh, Jr., Esq.

219 Couch Drive J. Gregory Copeland, Esq.

Oklchoma City, Okichoma 73101 Theodore F. Weiss, Jr., Esq.

Baker & Botts Knoland J. Plucknett 3000 One Shell Plaza Executive Director Houston, Texas 77002 Committee on Power for the Southwest, Inc. Linda L. Acker, Esq.

S541 East Skelly Drive Kevin B. Pratt, Esq.

Tulso, Okichoma 7413S Assistant Attorney General P. O. Box 12S48 John W. Davidson, Esq. .

Capitol Station Sawtelle, Goode, Davidson & Ticilo Austin, Texcs 787ll 1100 San Antonio Savings Building San Antonio, Texas 7820S Frederick H. Ritts, Esq.

Northeurt Ely W. S. Robson Watergate 600 Building General Manager Wcshington, D. C. 20037 South Texas Electric Cooperative, Inc.

Route 6, Building 102 Don R. Butler, Esq.

Victoria Regional Airport 122S Southwest Tower Victoria, Texas 77901 Austin, Texas 78701 Joseph B. Knotts, Jr., Esq.

Nicholcs S. Reynolds, Esq.

Debevoise & Liberman 1200 Seventeenth Street, N. W.

Washington, D. C. 20036

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