ML19276E690
| ML19276E690 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/27/1979 |
| From: | Stahl D ISHAM, LINCOLN & BEALE |
| To: | |
| References | |
| NUDOCS 7903200269 | |
| Download: ML19276E690 (10) | |
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UNITED STATEF OF AMERICA
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NUCLEAR REGULA20RY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD'.x.__,.:j h '
In the Matter of
)
)
HOUSTON LIGHTING & POWER
)
NRC Docket Nos. 50-498A COMPANY, et al.
)
50-499A
)
(South Texas Project, Unit
)
Nos. 1 and 2)
)
)
)
In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak Steam
)
Electric Station, Units 1
)
and 2)
)
(Consolidated for Discovery)
CENTRAL POWER AND LIGHT COMPANY'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO HOUSTON LIGHTING & POWER COMPANY Central Pcwer and Light Company
(" CPL"), through its attorneys and pursuant to Rules 2.740b and 2.741 of this Commission's Rules of Practice, propounds the following Interrogatories and Requests for Production of Documents to Houston Lighting & Power Company ("HLP").
CPL requests that the Interrogatories be answered according to the Rules within 14 days of service and that the documents requested herein be produced for inspection and copying 30 days after service.
to the directive of the Board (Transcript Pursuant at 105), issued at the prehearing conference on June 21, 1978, these interrogatories and requests for production of documents are continuing in nature and, accordingly, require 7903200 2 69
supplemental answers or production should HLP generate or obtain further pertinent information or documents after the time for compliance with these discovery requests.
Definitions:
" Documents" means, without limiting the generality of its meaning, all original (or copies where originals are unavailable) and non-identical copies (whether different from originals by reason of notation made on such copies or otherwise) of all written, recorded or graphic matter, however produced or reproduced, whether or not now in existence, including but not limited to correspondence, telegrams, notes or sound recordings of any type of conver-sation, meeting, or conference, minutes of directors' or committee meetings, memoranda, inter-office communications, studies, analyses, notes, books, records, reports, summaries and results of investigations and tests, reviews, contracts, agreements, pamphlets, diaries, calendar or ciary entries, maps, graphs, charts, statistical records, computer data or papers similar to any of the foregoing, however denominated, including preliminary versions, drafts or revisions of any of the foregoing and any supporting, underlying or pre-paratory material.
" Identify" when used in reference to a natural person means to state the person's full name, business
- affiliation and last known address.
" Relating to" means consist of, refer to, reflect or be in any way legally, logically or factually connected with the matter discussed.
Interrogatories and Requests for Documents:
1.
Identify every change to its existing or planned transmission or distribution system which HLP believes would be necessary to permit it to provide approximately the same level of reliability of service as it currently provides in the event the Central and South West ("CSW")
operating subsidiaries engage in Mode 4 operation.
2.
(a)
State the approximate cost of the changes identified in your Answer to Interrogatory Number 1, (b) state the method by which the cost was computed, and (c) identify the individual (s) who computed the cost.
3.
State the present attitude of HLP's management on the issue of interstate versus intrastate operation and identify every factor which was considered by HLP's management in forming that attitude.
4.
Has HLP contracted with any other electric utility to purchase or sell electricity in any year between 1979 and 2000?
5.
If the Answer to Interrogatory Number 4 is in the affirmative, (a) identify each electric utility with which HLP has so contracted, (b) describe the terms of each such contract by stating whether HLP will purchase or sell, or both; the quantities of electricity to be purchased or sold; the period during which such purchases and sales will occur and
the price to be paid or received for such electricity, and (c) produce a copy of each such contract.
6.
Is HLP currently negotiating, or considering, the possible purchase from or sale to other electric utilities of electricity in any year between 1979 and 2000?
7.
If the Answer to Interrogatory Number 6 is in the affirmative, (a) identify each electric utility (i) with which HLP is currently negotiating for such purchase or sale or (ii) which HLP is considering for such purchase or sale, and (b) state the terms of each such purchase or sale which is being negotiated or considered.
8.
Has HLP entered into any agreement or understanding with any other electric utility for the provision of " wheeling" or other transmission services?
9.
(a)
If the answer to Interrogatory Number 8 is in the affirmative, with respect to each such agreement or understanding (i) identify the other electric utility with which HLP has the agreement or understanding, and (ii) describe the terms of each such agreement or understanding by stating the utility which will provide the " wheeling" or other transmission service, the amount of
_ electricity to be " wheeled", the period of time during which such " wheeling" or other transmission service will be pro-vided, and the charge for such " wheeling" or other trans-mission service.
(b)
Produce all documents which reflect any agreement or understanding between HLP and any other electric utility for the provision of " wheeling" or other transmission services.
10.
With respect to HLP's proposed purchase of capacity from the City of Austin Electric Department
(" Austin"),
- state, (a) the amount of electricity which will flow over the transmission Jines of other electric utilities once HLP begins receiving electricity from Austin as a result of such purchase and (b)
(i) whether HLP has entered into, or intends to enter into, any agreement with other electric utilities over whose transmission lines such electricity will flow to compensate those other electric utilities for the use of their lines, and (ii) if so, the terms of any such agreement.
11.
(a)
State HLP's policy or position with respect to the provision by it of " wheeling" or other transmission services for other electric utilities and (b) produce all documents relating to such policy or position.
12.
Identify every benefit which HLP believes it might obtain in the event HLP engages in Mode 4 operation with the CSN operating subsidiaries.
13.
Describe every adverse consequence which HLP believes might result from (a) disconnection of the HLP system from the subsidiaries of the Texas Utilities Company ("TU");
(b) disconnection of the HLP system from the CEW subsidiaries; (c) disconnection of tne HLP system from the TU and CSW subsidiaries; and (d) disconnection of the HLP system from all other electric utilities.
14.
(a)
Describe the manner in which HLP believes it could mitigate or eliminate each adverse consequence described in your Answer to Interrogatory Number 13; and (b).
state the approximate cost which such mitigation or elimination would entail.
15.
Is HLP aware of any analysis of the manner by which all participants in the South Texas Project could con-tinue to receive their respective entitlements of electric but less energy from the Project in the event one or more, than all, of the Participants commence synchronous operation with the South West Power Pool during the life of the Project?
16.
(a)
If the Answer to Interrogatory Number 15 is in the affirmative, (i) state the results or conclusions of each such analysis; and (ii) state when and by whom each such analysis was prepared.
(b)
Produce each such analysis and all other documents relating thereto, including but not limited to those " studies" referred to by Mr. Jordan on page 2805 of the trial transcript in West Texas Utilities v.
Texas Electric Service.
17.
Produce all documents relating to each inquiry received by HLP since March 1, 1977 from any person, firm or corporation which at the time of the inquiry was not a customer of HLP, concerning the cost or price at which HLP would sell electricity.
18.
Produce all documents relating to each inquiry received by HLP since March 1, 1977 from any person, firm or corporation which at the time of the inquiry was a customer concerning the cost or price at which HLP would be able to sell electricity in the future.
19.
Identify all industrial or commercial customers whose peak load has ever exceeded 2,000 kw and who have terminated receiving electricity from HLP since January 1, 1970.
With respect to each such customer state the month of termination, whether the customer moved to another location (and, if so, where) and the reason for such termination.
20.
Produce all documents prepared since January 1, 1974 analyzing or relating to (a) the cost or price at which HLP will be able to sell electricity in the future and/or (b) the impact of the cost or price of electricity on HLP's ability to retain existing customers or attract new customers.
21.
Produce all documents prepared since August 1, 1976 relating to the effect, if any, on the HLP transmission or distribution system or on HLP's ability to provide service to its customers of any of the proposals advanced
. by CSW for the more complete coordination of its subsidiary companies in either Mode 2 or Mode 4.
22.
(a)
What effect, if any, does HLP believe that the portion of the Order in Texas Public Utility Commission Docket 2001 (" Docket 2 001") which sets HLP's interruptible rate to Dow Chemical Company ("Dow") at 80% of the firm rates charged by HLP, will or may have on Dow's willingness to continue to receive electricity from HLP either at all or in amounts comparable to those received before the Order in Docket 2001.
(b)
Produce all documents relating to the analysis of the effect of Docket 2001 on (i) HLP's ability to continue to provide electricity to Dow or (ii) Dow's willingness to continue to purchase electricity from HLP.
23.
(a)
Has HLP undertaken, or caused to be undertaken, the " comprehensive studies" required by Finding of Fact 35 in the Order in Docket 200l?
(b) if so, (i) identify who is performing each such study and the individual involved, (ii) state the conclusions reached to date by each such study and (iii) produce all documents relating to such studies.
24.
(a)
Produce all documents relating to Plaintiffs' Exhibit 814 in West Texas Utilities v.
Texas Electric Service including but not limited to the originals of the documents
_ which comprise said Exhibit and all computer printouts which contain information or data from or upon which said Exhibit was prepared; and
. (b) identify all persons who (i) participated in the preparation of said Exhibit 814 and all documents related thereto and (ii) had knowledge of such documents at or about the time of their preparation or prior to May 4, 1976 and state the circumstances under which each such person obtained that knowledge.
25.
(a)
With respect to the testimony of Mr.
D.
E. Simmons on pages 3144-45 of the transcript of West Texas Utilities v. Texas Electric Service and HLP's Exhibit 206 in that case, (i) describe specifically every respect in which HLP believes that coordination within the Electric Reliability Council of Texas ("ERCOT") could be maximized in the period 1979 through 2000 and (ii) state the benefits which HLP believes ERCOT companies could achieve through such maximum coordination and (b)
Produce all documents relating to any analysis of maximizing coordination within ERCOT and/or the benefits achievable through such coordination.
26.
State the name, business address, residence address and position in or affiliation with HLP of each person who provided information in connection with HLP's answers to any or all of these Interrogatories, and indicate by number those Interrogatories with respect to which each such person provided information.
27.
(a)
Identify each person whom HLP expects to call as an expert witness at the hearing in this case by stating each such person's name, occupation and business address.
. (b)
State the subject matter on which each person identified in your answer to Interrogatory Number 27(a) is expected to testify.
(c)
State (i) the substance of the facts and opinions to which each person identified in your answer to Interrogatory Number 27 (a) is expected to testify and (ii) a summary of the grounds for each such opinion.
28.
Identify each person whom HLP has employed in anticipation of or in connection with the preparation for the hearing in this case and who is not expected to be called as an expert witness.
29.
Identify every non-expert witness whom HLP expects to call as a witness at the hearing in this case.
30.
Provide Answers to Interrogatories Number 8, 14 (a), 16(a) and 18(ii) from CPL's First Set of Interrogatories to HLP, which HLP stated it was unable to answers at that time.
Respectfully submitted, ISHAF,,INCOLN & BEAL l
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l By rY Attorneys fop / Central Power and LYght Co.
ISHAM, LINCOLN & BEALE One First National Plaza
- Suite 4200 Chicago, Illinois 60603 312/786-7500