ML19289F392
| ML19289F392 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 03/28/1979 |
| From: | Sampels M, Worsham J WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | |
| References | |
| NUDOCS 7906070317 | |
| Download: ML19289F392 (16) | |
Text
TESA C4 clh s
o$l$
%= - *% II 9ts7 4 30 S@g-h5M [
6 UNITED STATES OF AMERICA c
NUCLEAR REGULATORY COMMISSION
.g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
/
in the Matter of HOUSTON LIGHTING & POWER NRC Docket Nos. 50-498A COMPANY, PUBLIC SERVICE 50-499A BOARD OF SAN ANTONIO, CITY OF AUSTIN, CENTRAL POWER AND LIGHT COMPANY (South Texas Project, Unit Nos.
I and 2)
TEXAS UTILITIES GENERATING COMPANY, et al.
NRC Docket Nos. 50-445A (Comanche Peak Steam Electric 50-446A Station, Units I and 2)
ANSWER OF TEXAS UTILITIES COMPANY AND ITS SUBSIDIARIES TO CENTRAL POWER AND LIGHT COMPANY'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO TEXAS UTILITIES GENERATING COMPANY. ET AL COME NOW TEXAS UTILITIES COMPANY ("TU"), TEXAS UTILITIES GENERATING COMPANY ("TUGCO"), DALLAS POWER & LIGHT COMPANY
("DPL"), TEXAS ELECTRIC SERVICE COMPANY ("TESCO"), and TEXAS POWER
& LIGHT COMPANY ("TPL"), all collectively referred to as "TU Companies," in complicnce with Section 2.740b and 2.741 of the Rules of Practice of the Nuclear Regulatory Commission ("NRC"), and make the following answers to Central Power and Light Company's First Set of Interrogatories and Request for Production of Documents Addressed to Texas Utilities Generating Company, et al.
Reference is made to the Objections and Motion for Protective Order filed contemporaneously herewith.
INTERROGATORY NO.1. " Identify every change to the existing or planned transmission or distribution systems of e y of the TU Companies which would be necessary to permit each of them to provide cpproximately the same level of reliability of service as they currently provide in the event the Central and South West ('CSW') operating subsidiaries engage in Mode 4 operation."
ANSWER:
1.
It is impossible to answer this question until the exact nature of the interconnected system has been determined. See our Objections and Motion for Protective Order.
2?31 059 79060703n
INTERROGATORY NO. 2.
"(a) State the approximate cost of the changes identified in your Answer to Interrogatory Number I, (b) state the method by which the cost was computed, and (c) identify the individual (s) who computed the cost."
ANSWER:
2.
The costs cannot now be determined. See our Objections and Motion for Protective Order.
INTERROGATORY NO. 3.
" State separately the present attitude of the management of TESCO, TPL and DPL on the issue of interstate versus intrastate operation and identify every factor which was considered by each management in forming that attitude."
ANSWER:
3.
It is the attitude of each TU Company that it is now pursuing and will in the future pursue the mode of operation, intrastate or interstate, which is best for its customers cnd its stockholders. See the depositions and testimony of Messrs.
Austin, Hulsey, Marqucrdt, Farrington, Skelton and Scarth in the trial of West Texas Utilities Comoany, et al v. Texas Electric Service Company, et al, before the United States District Court, Northern District of Texas, Dallas, Division, CA 76-0633-F, and discovery documents therein and the exhibits thereto (" Federal Court Case"); the testimony of Mr. Secrth in the Texas Public Utility Commission Docket 14 (" Docket 14"); and the answer to Department of Justice Interrogatory No.
4 and NRC Staff Interrogatory No. 2; for further explanation of the TU Companies' attitude and the factors considered in forming that attitude, see also the answer to Interrogatory No.18 below.
INTERROGATORY NO. 4. "Have any of the TU Companies contrected with any other electric utility to purchase or sell electricity in any yect between 1979 and 2000?"
ANSWER:
4.
Yes.
INTERROGATORY NO. S. "If the Answer to Interrogatory Number 4 is in the affirmative, (a) identify each electric utility with which OPL, TPL or TESCO has so contracted, (b) describe the terms of each such contract by stating whether the TU Company will purchase or sell, or both; the qucntities 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 eleci "ity, and (c) produce a copy of each such contract."
7731 060 ANSWER:
S.Y hkbr 'tSe incmes of the parties cnd the terms thereof, see the 11 2
agreements %r economy or interruptible energy sales which are attcched. There are numerous other contreets between a TU Company and other electric uti'ities, such as contracts with various REA's, which have been previously produced for inspection and copying. See also answers to interrogntories Nos. 9 cnd 13 to the Information Requested by the Attorney General for Antitrust Review Submitted in Connection with the Application of TUGCO for a Construction Permit with respect to Comanche Peck for information as to wholesale sales agreements.
INTERROGATORY NO. 6.
"Are cny of the TU Compcnies currently negotiating, or considering, the possible purchase from or sale to othar electric utilities of electricity in any year between 1979 and 2000?"
ANSWER:
6.
No.
INTERROGATORY NO. 7. "If the Answer to Interrogatory Number 6 is in the offirmative, (c) identify ecch electric utility (i) with which DPL, TPL or TESCO is currently negotiating for such purchase or sale or (ii) which DPL, TPL or TESCO is considering for such purchase or scle, and (b) state the terms of each such purchase or sale which is being negotiated or considered."
ANSWER:
7.
Not cppliccble.
INTERROGATORY NO. 8. "Have any of the TU Companies entered into cny agreement or understanding with cny other electric utility for the provision of
" wheeling" or other transmission services?"
ANSWER:
8.
Yes.
INTERROGATORY NO. 9.
"If the answer to interrogatory Number 8 is in the offirmative, with respect to ecch such agreement or understanding (i) identify the other electric utility with which DPL, TPL or TESCO has the cgreement or understanding, and (ii) describe the terms of ecch 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 provided, cnd the chcrge for such " wheeling" or other transmission service. (b) Produce all documents which reflect cny agreement or understencing between DPL, TPL or TESCO cnd cny other electric utility for the provision of " wheeling" or other trcnsmission services."
ANSWER:
9.
By en agreement between BEPC cnd SPA, SPA will provide BEPC up to S0,000 t w of hydro power from Denison Dcm during the times when power in k
qlgWhitney'Ocm is not availcble in sufficient cmounts to encbie SPA to fulfill its l
2231 061 3
contractual crrcngements with BEPC.
Under this crrangement, all such power from Denison Dam is wheeled through the TPL system to BEPC. As a consideration for this wheeling, TPL gets I kwh of energy for every 6 kwh of energy delivered to BEPC. TPL gets I kw capacity for each 6 kw ccpccity in excess of 5,000 kw provided to BEPC. The Transmission Facilities Agreement with Texcs Municipal Power Agency, dated Janucry 2.1979, provides for delivery of their generation entitlement at Comanche Peck and Gibbons Creek through the TV Compcnies' transmission system. A similar agreement is being negotiated with BEPC. Copies of these cgreements hcve beer previously provided to your counsel.
INTERROCATORY NO.10. "(a) State separately the policy or position of each of the TU Companies with respect to the provision by them of " wheeling" or other trcnsmission services for other electric utilities and (b) produce all documents relating to such policy or position."
ANSWER:
10.
The TU Companies' only policy in this respect is to do what is best for, and to protect the interest of, their customers and security holders. Each factual situation must be examined on its own merits. The TU Companies will study the coordination of ERCOT, including wheeling, with anyone at any time so long as the aim of the study is directed towarcs determining the most efficient cnd reliable method of serving the customers of the respective electric systems in ERCOT. See the answers to Interrogatories Nos. 3, 9 cnd 18 and the cpplicable conditions in the Comanche Peck Construction Permit. See also documents produced in connection with the Federal Court Case.
INTERROGATORY NO. II. " Identify every benefit which TUGCO or any of the TU Compcnies believe any of them might co:ain in the event the TU Compcnies engage in Mode 4 operation with the CSW operating subsidiaries."
ANSWER:
11.
None.
INTERROGATORY NO.12.
" Describe every cdverse consequence which TUGCO or any of the TU Compcnies believe might result from (c) disconnection of (i) DPL (ii) TPL cnd (iii) TESCO from the other TU Companies; (b) disconnection of the TU Companies from the CSW subsidiaries; (c) disconnection of the TU Companies from Houston Lighting & Power Company ("HLP"); (d) disconnection of the TU Companies from the CSW subsidiarios and HLP; cnd (e) disconnection of (i)
DPL (ii) TPL and (iii) TESCO from all other electric utilities."
ANSWER:
12.
It is impossible to answer this inquiry without knowing the alternative circumstances which exist at the time.
2231 062 ISU 4
INTERROGATORY NO.13. "(a) Describe the manner in which TUGCO or any of the TU Companies believes each adverse consequence described in the Answer to
~
Interrogatory number 12 could be mitigated or eliminated; and (b) state the cpproximate cost which such mitigation or elimination would entail."
ANSWER:
13.
It is impossible to answer this inquiry without knowing the alternative circumstances which exist at the time.
INTERROGATORY NO.14. " Produce all documents relating to each inquiry received by the TU Companies or any of them since March I,1977 from any person, firm or corporation which at the time of the inquiry was not a customer of the Company receiving the inquiry, concerning the cost or price at which any of the TU Companies would sell electricity."
ANSWER:
14.
Such documents, which are filed ciphabetically by the name of the company which inquires and not chronologically, will be produced for your inspection at a mutually convenient time.
INTERROGATORY NO.15. " Produce all documents relating to each inquiry received by the TU Companies or any of them since March I,1977 from any person, firm or corporation which at the time of the inquiry was a customer of any of them, cancerning the cost or price at which any of the TU Companies would be cble to sell electricity in the future."
ANSWER:
15.
On occasion, customers make inquiries of future electric power costs, so that such information can be used in their intet not budgeting or for other purposes.
Most such inquiries are oral cnd no records are kept by the TU Companies with respect thereto. See the answer to Interrogatory No.14 with respect to such inquiries relating to possible new plant locations and expansions.
INTERROGATORY NO.16. " Identify all industrial or commercial customers whose peak load has ever exceeded 2,000 kw cnd who hcve terminated receiving electricity from any of the TU Companies 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."
ANSWER:
16.
For the most part, it is impossible to cnswer this question, since records relating to the subject of this inquiry are not maintained. However, a reasonable inquiry was made of knowledgecble persons at the TU Compcnies and the following informatiot) was obtained:
2231 063 5
~
f:
'^
^
t Name and Location of Reason for 2000 Kw User Termination DPL Ford Motor Co. Assembly Plcnt
-l 1970
- t. j Closed picnt Rio Grande Life insurance 1970 Building torn down for
?
new building Peavy Flour Mill 1974 Went out of business Mobil Building - 1976 Relocated of fices Neuhoff Packing Company 1978 Closed picnt TESCO Swift & Co., Ft. Worth 19 71 Meat packing - closed plant Elcor Chemical, Culbertson County Sulphur processing -
1974 Went out of business Seven Secs, Arlington 1976 Amusement park -
Went out of business Webb Air Force Bcse, Big Spring 1978 Base closed TPL Perrin Field, Sherman Military base ceased operation Fort Walters, Mineral Wells Military base cecsed operation Woodcrd Iron Co., Tyler Ceased operation Morton Prahl Plant, Farmers Brcnch Cecsed operation Round Rock Lime Co.
Ceased operation Ni Pck Fertilizer Plant, Trinidad Ceased operation Conwa
' ? '( y Oil Co., Denison Cecsed operation 3' (-)
i
~~
2231 064 k
~~
__a
e INTERROGATORY NO.17. " Produce all documents prepared since Jcnuary I, 1974 analyzing or relating to (a) the cost or price at which any of the TU Compcnies will be cble to sell electricity in the future cnd/or (b) the impact of the cost or price of electricity on cny of the TU Companies' ability to retain existing customers or attract new customers."
ANSWER:
17.
(a)
Electric utility system picnning is a conf.,uing process. System expansion plans analyze various citernative proposals for iuture system expcnsion based on the latest available information cnd projections and are revised at least annually. Only certain costs, such cs projected ccpital costs for new facilities, cre included in such studies. Such studies cs are maintained will be mcde available for inspection at a mutually cgreed time and place. In addition, ecch of the TU Companies' projects future budgets for internal use only, cnd to the extent information contained therein has not been disclosed publicly, we c!cim privilege since such informaton is highly confidential and contains proprietary information.
Except as to matters for which privilege is claimed, which will only be revealed to counsel and not to principals under a suitable protective order and confidenticlity agreement, such budgets will also be furnished for inspection at a mutually agreed time cnd place.
(b)
None.
INTERROGATORY NO.18. " Produce all documents prepared since August 1, 1976 relating to the effect, if cny, on the DPL, TPL or TESCO transmission or distribution system or on DPL's, TPL's or TESCO's cbility to provide service to its customers, of any of the proposals advcnced by CSW for the more complete coordination of its subsidiary companies in either Mode 2 or Mode 4."
ANSWER:
18.
Based upon the facts, circumstances and availcble citernatives, the TU Companies believe that an intrastate mode of operation has been cnd continues to be in the best interests of their customers. This conclusion has been fortified by repeated analysis over the years of what mode of operation is in the best interest of their customers, including, without limitation, cnolyses of the various proposcls advanced from time to time since 1974 by CSW.
In ecch instance, the TU Companies have concluded that operating in cn intrastate mode produces for their customers the most relicble and economical electric service. In particulcr, the TU Companies have concluded that the various CSW proposed interconnection plcns were intentionally biased, were based upon extremely remote and highly speculative assumptions cnd were conducted to save its holding company cnd not with the view toward determining what was in the best interest of its customers or the customers of other affected utilities. No proposal has been advanced which persucdes the TU Companies that their historical intrastate mode of operation should be altered.
Except for privileged documents, all have been made availcble for inspection and copying. See also the depositions cnd testimony of Messrs. Austin, Hulsey, Marqvar.dt, 9rrington, Skelton cnd Secrth in the Federal Court Case end of Mr. Scarth in;Ddck t~l4.,
2231 065
INTERROGATORY NO.19. " Produce a copy of each cdvertisement placed since March 1,
1977 which attempted to encourage potentici industrial or commercial customers to locate a plant or facility in the service crec of DPL, TPL or TESCO, and identify the newspcper, journal, mcgazine or periodi.cl in which, and state the time period during which, each such cdvertisement was rut.."
ANSWER:
19.
None.
INTERROGATORY NO. 20. " State the amount which DPL, TPL cnd TESCO have spent on advertising in each year since 1970."
ANSWER:
20.
Year Advertising Expense DPL I970
$933,484 197I 967,980 1972 959,670 1973 873,84l 1974 637,023 1975 491,966 1976 549,590 1977 540,541 1978 57i,734 TESCO 1970
$1,052,993 1971 995,428 1972 I,081,503 1973 1,06i,424 I974 907,302 1975 838,456 1976 763,E62 1977 79I,357 1978 813,328 2231 066 2n0
!?L 8
TPL 1970
$866,648
~
l971 843,057 1972 863,557 1973 882,297 1974 905,419 1975 975,433 1976 877,455 1977 95I,526 1978 987,212 INTERROGATORY NO. 21. " State (c) the amount of the fuel cost cdjustment to the industrial customers of TPL, DPL and TESCO for ecch month since January, 1978 and (b) whether the fuel cost adjustment to industrial customers for ecch such month differed from the fuel cost adjustment cpplied to other customer classes."
ANSWER:
21.
(c)
Month Cents /Kwh DPL January 1978 0.3420 February 0.5250 March
.6360 April
.4980 May
.3150 June
.4440 July
.7590 August
!.5609*
September 1.2712 October
.9145 November
.9881 December 1.2014 January 1979 1.3807 February I.1672 March 1.8479 TESCO January 1978
.8617 February 1.0514 March 1.0699 April
.7432 2231 067 May
.9388 s
June
.9737 July
.9675 August i.0465 September 0.9066 See Footnote + on next page.
October
.6609 November
.8010 December
.9066 January 1979
.9066 -
February
.9066 March
.9066 TPL January 1978 1.2588 February 0.9357 March
!.3356 April 1.3648 May 1.5194 June 1.4138 July I.3057 August i.2272 September
!.2275 October i.0672 November 0.8354 December
!.281I January 1979 1.1261 February 0.9255 March
- .3709 Prior to August 1978, the fuel cost adjustme.,! was based on the amount by which fuel costs in the second preceding month exceeded 76 cents /million Stu.
(L' Fuel cost adjustment to industrial customers is the same as applied to other customer classes.
INTERROGATORY NO. 22. " Describe (a) the efforts which each of the TU Companies have made since January 1, i974 to attract or induce potential or existing industrial customers to locate or expand plar.t or other fccilities in the service crea of DPL, TPL or TESCO and (b) which of those efforts are still being made at present."
ANSWER:
22.
Each TU Company assists the Chamber of Commerce cnd similar civic organizations in tha improvement of the communities within their respective service territories by providing information to persons who inquire.
See the depositions, testimony, exhibits of Messrs. Heath, Raburn, Castillon cnd the docurner}ts produced in connection therewith in the Federal Court Case.
idu s
INTERROGATORY NO. 23. " Describe specifically every respe:t in which TUGCO or any of the TU Compcnies believe that coordination within he Electric Reliability Council of Texas ('ERCOT') could be maximized in the period Ic79 2231 068 10
through 2000 and state the benefits which the ERCOT companies couM achieve through such maximum coordination and (b) Produce all documents relating to any analysis of maximizing coordination within ERCOT and/or the benefits achievcble through such coordination."
ANSWER:
23.
See the answer to Interrcgatory No.10 above.
INTERROGATORY NO. 24. " State the name, business address, residence address and position in or affiliation with TUGCO, DPL, TPL or TESCO of each person who provided information in connection with the answers to any or all of these Interrogatories, and indicate by number those Int-rrogatories with respect to which ach such person provided information."
ANSWER:
24.
Mr. E. D. Scarth, Vice President of TESCO, Box 970, Fort Worth, Texas, provided information with respect to all the Interrogatories.
Mr. Roy Parks, Director, System Planning, Texas Utilities Service Company, 2001 Bryan Tower, Dallas, Texas, provided assistance in answering all the Interrogatories.
IN_TERROG ATORY NO. 25. "(a) Identify each person whom TUGCO, DPL, TPL or TESCO 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 25(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 25(a) is expected to testify and (ii) a summary of the grounds for each such opinion."
ANSWER:
25.
(a)
Mr. E. D. Scarth, Vice President of TESCO, P. O. Box 970, Fort Worth, Texas (817/336-9411). If and when it is determined that the TU Companies will use any other experts as witnesses in the ccptioned proceeding, CPL will be notified.
(b)
The subject matters have not yet been identified.
(c)
See the depositions and testimony of Mr. Scarth in Docket 14 and the Federal Court Case.
INTERROGATORY NO. 26. " Identify each person whom TUCCO, DPL, TPL or TESCO 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."
ANSWER:
O:,
26.
None other than toe employees of the TU Companies.
INTERROGATORY NO. 27.
" Identify every non-expert witness whom TUGCO, DPL, TPL or TESCO expects to call as a witness at the hearing in this 2231 069 11
Case."
ANSWER:
27.
None has yet been identified.
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 Sevent' enth Street, N. W.
Washingtor., D. C. 20036
//
By /
(/
/j &
y u-V ATTORNEYS FOR TEXAS UTILITIES COMPANY, TEXAS UTILITIES GENERATING COMPANY, DALLAS POWER & LIGHT COMPANY, TEXAS ELECTRIC SERVICE COMPANY AND TEXAS POWER & LIGHT COMPANY 2231 070 060
- A. :,
12
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 Central Power & Light Company's First Set of Interrogatories and Request for Production of Documents propounded to Texas Utilities Generating Company, et al, on behalf of the TU Companies, has read the above and foregoing Answers of the CU Companies to said Interrogatories from Central Power &
Light Company, and the same are true and correct, to the best of his knowledge and belief.
E.
D.
SCARTH SUBSCRIEED AND SWORN TO before me this 28th day of March, 1979, to certify which witness my hand and seal of office.
d.htE~U
%QLih PAULA HEWATT, Notary Public Tarrant County, Texas My Commission Expires:
December 27, 1980 2231 071
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of HOUSTON LIGHTING & POWER NP,C Docket Nos. 50-498A COMPANY, PUBLIC SERVICE 50-499A BOARD OF SAN ANTONIO, CITY OF AUSTIN, CENTRAL POWER AND LIGHT COMPANY (South Texas Project, Unit Nos.
I and 2)
TEXAS UTILITIES GENERATING COMPANY, et al.
NRC Docket Nos. 50-445A (Comanche Peck Stecm Electric 50-446A Station, Units I cnd 2)
CERTIFIC ATE OF SERVICE I hereby certify that service of the foregoing ANSWER OF TEXAS UTILITIES COMPANY AND ITS SUBSIDIARIES TO CENTRAL POWER AND LIGHT COMPANY'S FIRST SET OF INTERROGATORIES AND REGUEST FOR PRODUCTION OF DOCUMENTS ADDRESSED TO TEXAS UTILITIES GENERATING COMPANY, ET AL has been made on the following pcrties listed hereto this 28th day of March
, !979, by depositing copies thereof in the United States mail, first class, postage prepaid:
Marshall E. Miller, Esq. (2 copies)
Richard S. Salzmcn, Esq.
U. S. Nuclear Regulatory Commission U. S. : Juclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Michael L. Glcser, Esq. (2 copies)
Jerome E. Sharfman, Esq.
115017th Street, N. W.
U. S. Nuclear Regulatory Commission Washington, D. C. 20036 Washington, D. C. 20555 Sheldon J. Wolfe, Esq. (2 copies)
Chase R. Stephens, Secretary (20 copies)
U. S. Nuclear Regulatory Commission Docketing and Service Branch Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 jgp s
Samuel J. Chilk, Secretary Jerome Saltzman Office of the Secretary of the Commission Chief, Antitrust and Indemnity Group U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety & Licensing Appeal Raff Hardy Board Pcnel Chairman a d Chief Executive Officer U. S. Nuclect Regulatory Commission Centrol Power & Light Compcny Wcshington, D. C. 20555 P. O. Box 2121 Corpus Christi, Texas 78403 2231 072
Michael I. Miller, Esq.
G. K. Spruce, Richard E. Powell, Esq.
General Manager David M. Stahl, Esq.
City Public Service Board Thomas G. Ryan, Esq.
P. O. Box 1771 Isham, Lincoln & Beale San Antonio, Texas 78203 One First National Plaza Chicago, Illinois 60603 Roy P. Lessey, Esq.
Jerry L. Harris, Esq.
Michael Blume, Esq.
City Attomey, U. S. Nuclear Regulatory Commission Richard C. Balough, Esq.
Washington, D. C. 20555 Assistant City Attorney City of Austin R. L. Hancock, Directoc P. O. Box '088 City of Austin Electric Utility Department Austin, Teacs 78767 P. O. Box 1088 Austin, Texas 78767 Robert C. McDiarmid, Esq.
G. W. Oprea, Jr.
Spiegel and McDiarmid Executive Vice President 2600 Virginic Avenue, N. W.
Houston Lighting & Power Company Washington, D. C. 20036 P. O. Box 1700 Houston, Texas 77001 Dan H. Davidson Jon C. Wood, Esq.
City Manager W. Roger Wilson, Esq.
City of Austin Matthews, Nowlin, Macfarlane & Scrrett P. O. Box 1088 1500 Alamo National Building Austin, Texas 78767 San Antonio, Texas 78205 Joseph Gallo, Esq.
Judith Harris, Esq.
Richard D. Cudahy, Esq.
Energy Section Robert H. Loeffler, Esq.
Antitrust Division Ishcm, Lincoln & Beale U. S. Department of Justice Suite 701,105017th Street, N. W.
Washington, D. C. 20530 Washington, D. C. 20036 Douglas F. John, Esq.
R. Gordon Gooch, Esq.
Akin, Gump, Hauer & Feld John P. Mathis, Esq.
1100 Madison Office Building Baker & Botts
!!5515th Street, N. W.
1701 Pennsylvania Avenue, N. W.
Washington, D. C. 20024 Washin +cn, D. C. 20006 Mcrgan Hunter, Esq.
Robert Lowenstein, Esq.
McGinnis, Lochridge & Kilgore J. A. Bouknight, Esq.
5th Floor William Franklin, Esq.
Texas State Bank Building Lowenstein, Newman, Reis & Axelrad 900 Congress A. venue 1025 Connecticut Avenue, N. W.
Austin, Texas 78701 Washington, D. C. 20036 2231 073
Jay M. Galt, Esq.
E. W. Barnett, Esq.
Looney, Nichols, Johnson & Hayes Charles G. Thrash, Jr., Esq.
219 Couch Drive J. Gregory Copeland, Esq.
Oklahoma City, Oklahoma 73l01 T heodore 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.
SS41 East Skelly Drive Kevin B. Pratt, Esq.
Tulsa, Oklahoma 7413S Assistant Attorney General P. O. Box 12S48 John W. Davidson, Esq.
Capitol Station Sawtelle, Goode, Davidson & Tioilo Austin, Texas 787!!
1100 San Antonio Savings Building San A. tonio, fexas 78205 Frederick H. Ritts, Esq.
Northcutt Ely W. S. Robson Watergate 600 Building General Manager Washington, D. C. 20037 South Texas Electric Cooperative, Inc.
Route 6, Building 102 Don R. Butler, Esq.
Victoria Regional Airport 1225 Southwest Tower Victoria, Texas 77901 Austin, Texas 78701 Joseph B. Knotts, Jr., Esq.
Nicholas S. Reynolds, Esq.
Debevoise & Liberman 1200 Seventeenth ~2treet, N. W.
Washington, D. C. 20036
/
0
/
)
,i pJ W
7731 074 M0'.
..