ML19296C480
| ML19296C480 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 02/06/1980 |
| From: | Copeland J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | CENTRAL & SOUTH WEST CORP., CENTRAL & SOUTH WEST SERVICES, INC., CENTRAL POWER & LIGHT CO., PUBLIC SERVICE CO. OF OKLAHOMA, WEST TEXAS UTILITIES CO. |
| References | |
| NUDOCS 8002260263 | |
| Download: ML19296C480 (14) | |
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'4 UNITED STATES OF AMERICA g
NUCLEAR REGULATORY COMMISSION 4
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY, 5
Docket Nos. 50-498A et al.
S 50-499A S
(South Texas Project, Units S
Nos. 1 and 2)
S S
-TEXAS UTILITIES GENERATING S
Docket Nos. 50-445A COMPANY, et al.
S 50-446A S
(Comanche Peak Steam Electric S
Station, Units 1 and 2)
S SECOND SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM HOUSTON LIGHTING &
POWER COMPANY TO CENTRAL AND SOUTH WEST CORPORATION, PUBLIC SERVICE COMPANY OF OKLAHOMA, WEST TEXAS UTILITIES COMPANY, SOUTHWESTERN ELECTRIC POWER COMPANY, CENTRAL POWER AND LIGHT COMPANY, AND CENTRAL AND SOUTHWEST SERVICES, INC.
Pursuant to Sections 2.740,
- 2. 740 (b) and 2.741 of the Nuclear Regulatory Commission's Rules of Practice, Houston Lighting & Power Company ("HL&P") propounds the following interrogatories and requests for production of documents to Central and South West Corporation, Public Service Company of Oklahoma, West Texas Utilities Company, Southwestern Electric Power Company, Central Power and Light Company, and Central and Southwest Services, Inc., and its predecessor CSR Services, Inc.
Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person or persons i
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making it no later than 14 days, and each document requested should be produced no later than 30 days, after service of these interrogatories and requests for production of documents.
DEFINITIONS As used herein the terms listed below, unless other-wise specifically indicated, are intended to have the following meaning:
1.
The word " person" or " persons" include natural persons, firms, partnerhips, associations, joint ventures, unit operations and corporations, or any other legal entity.
2.
The terms " officers", " directors", " agents", " employees" and other designations mean any person serving at any time during the relevent period in any such capacity even though no longer serving in such capacity.
3.
The term "CSW" includes within its meaning all officers, directors, agents and employees of Central and South West Corpora-tion and/or any affiliated companies of CSW includes, within the relevant period even though no longer serving in such capacity.
The affiliate companies of CSW include, without limitation, any companies that are owned or controlled by CSW or that are commonly owned or controlled with CSW.
The defini-tion of the term "CSW" includes, but is not limited to, the Central and South West Corporation, the Public Service Company of Oklahoma, West Texas Utilities Company, Southwestern Electric Power Company, Central Power and Light Company, Central and Southwe Services, Inc., and its predecessor CSR Services, Inc.
4.
The words " identify", " identifying" or " identification" when used in reference to a natural person means to state his full name and present or last known address and telephone number, his 'present or last known position or business address and telephone number, his present employer and position with that employer, and each of his positions during the relevant period; when used in reference to a business entity, means to state the name, address and any account or computer number to which such entity is referred to in your records; when used in reference to a document, means to state the type of document (i.e.,
- letter, memorandum, chart, sound production, report, computer input or output, etc.), the location where it is maintained, all identi-fying marks and codes, the addressee, the document date, author, and persons to whom copies were sent or person initiating or reading or approving the document and the name of each of the present custodians of the document.
If any such document was, but is no longer in your possession, or subject to your control, or in existence, state whether it is (1) missing or lost, (2) has been destroyed, (3) has been transferred, voluntarily or involuntarily, to others, er (4) otherwise disposed of, and in each instance, explain the circumstances surrounding an authorization for such disposition thereof and state the date or approximate date thereof.
5.
The term " document" means and includes every writing or record of any type and description and all attachments thereto that is in the possession, control or custody of CSW or an attorney for CSW as of the date of filing your answer to these interrogatories, including, but not limited to, corres-pondence, memoranda, stenographic or handwritten notes, drafts, studies (including, but not limited to, engineering, market, and economic studies), publications, invoices, ledgers, comparisons, tabulations, charts, journals, books, records, accounts, pamphlets, voice recording, reports, surveys, statistical compilations, workpapers, data processing cards, computer tapes or printouts, or any other writing or recording of any kind.
The term " documents" also includes every copy of a writing or record where such copy contains any commentary or notation of any kind that does not appear on the original or on any other copy.
Without limitation of the term " control",
a document-is deemed to be within your control if you have ownership, possession, or custody of the document or a copy thereof, or the right to secure the document or copy thereof from any person or public or private entity having physical possession thereof.
6.
The term " electric utility" means any entity engaged in the generation, transmission or sale, at either wholesale or retail, of electric energy, whether such entity is a cor-poration, agency of a federal, state or local government or a membership cooperative.
7.
" Witness" refers to any person who may give testi-mony, whether direct or rebuttal in the above-captioned proceedings.
8.
" Relating to" means consist of, report to, reflect or be in any way legally, logically or factually connected with the matter discussed.
9.
" TIS" refers to the Texas Interconnected Systems and "SWPP" refers to the Southwest Power Pool.
GENERAL INSTRUCTIONS The following general instructions apply to each of the discovery requests contained herein.
1.
Documents produced shall be grouped and marked by interrogatory.
2.
If you claim privileges as to any document or as to any answer requested by these interrogatories, identify, in the case of documents, the date of the document, the sender (s), the recipient (s), those receiving copies, and the subject matter of the document, and as to both documents and answers, specify the privilege claimed and the basis on which you assert that claim.
s 3.
In the event any dccument requested in these inter-rogatories is unavailable, describe in detail the circumstances surrounding such unavailability.
4.
These interrogatories are continuing and require supplemental answers if you obtain further information with respect to the same between the time your answers are served and the time of the evidentiary hearing.
5.
Restate the interrogatory or document request as the first par: of each answer.
As to any interrogatory or document request, or section or subsection thereof, that you refuse, or are unable, to answer in full, provide the most complete partial response possible and include a statement noting and explaining the partial response.
6.
Documents in the possession of any other party to this proceeding or publicly available are not to be regarded as being in HL&P's possession.
7.
Each interrogatory and request for production of documents is directed to CSW and each of its affiliated companies whether or not named in the definition of CSW above, and is to be answered individually by including them except where the answers would be the same, where it will be sufficient to simply indicate such entity so answering.
Documents should be produced for each responding entity; exact duplicates may be listed (other means of avoiding duplication of actual produc-tion may of course be adopted by agreement).
All documents are requested to be produced at the law offices of Baker & Botts, 3000 One Shell Plaza, Houston, Texas 77002, or as may be other-wise mutually agreed upon by the parties.
8.
These interrogatories and requests for production of documents are not meant to duplicate answers already provided or documents already produced to HL&P earlier in this pro-ceeding or in the Dallas District Court proceeding.
If the appropriate answer to an interrogatory has been previously given or the required documents have been previously produced, a specific reference to the previous response or identification of specific responsive documents will be sufficient.
This reference should include the page (s) of any transcript of a deposition or trial on which the answer appears, and a complete reference to the previous interrogatory response or the previous document production.
INTERROGATORIES 1.
Provide a copy of the final CSW Transmission Services Guidelines.
The draft of these guidelines is marked as Exhibit 4 to the deposition of Frank J. Meyer, Jr.
taken in Tulsa, Oklahoma on January 22, 1980.
2.
Produce the minutes of the CSW Transmission Guide-lines Task Force.
3.
Produce any studies conducted by, or reviewed by, the CSW Transmission Guidelines Task Force.
4.
Produce all minutes of the CSW Cperating Committee which reflect discussion of the CSW Transmission Services Guidelines.
5.
Produce any documents prepared by the CSW Operating Committee, or any member thereof, commenting on the CSW Transmission Services Guidelines.
6.
Produce any studies prepared by, or reviewed by, the CSW Operating Committee in connection with the Committee's review of the draft CSW Transmission Services Guidelines.
7.
Describe the nature of all studies done by CSW to calculate the impact of transfers of electricity on electric utilities within TIS and SWPP, if CSW's proposed Mode 4 were to be implemented, and id?ntify the employees or consultants who have done those studies.
8.
Produce all studies and documents relating to the calculation of the compensation to be made by CSW to electric utilities in TIS and SWPP for transmission services for the transfers proposed under Mode 4.
Explain whether or not such studies, if any, were done on the basis of the CSW Transmission Services Guidelines.
9.
State whether CSW intends to call a witness or witnesses to testify as to the impact on electric utilities in TIS and SWPP resulting from the Mode 4 interconnections proposed by CSW, including both the scheduled transfers proposed by CSW under Mode 4 and emergency transfers..
Identify any such witnesses, describe the substance of their testimony and provide copies of all studies which they will rely on in giving their testimony.
~
10.
Provide the maximum amount of scheduled transfers which CSW proposes to make under its current Mode 4 plans and produce copies of any economic or production costing studies which have been done for this maximum transfer level.
Identify the person who prepared these studies.
11.
Produce copies of all studies and documents relating to the effects on the transmission lines within TIS due to the loss of governor response action within TIS when TIS is interconnected with the SWPP, and identify the person or persons who made such studies.
One such study was marked as Exhibit 5 to the deposition of Frank J. Meyer.
12.
Identify any witness or witnesses who will testify as to the effects on the transmission lines within TIS due to the loss of governor response action within ERCOT when TIS is interconnected with the SWPP, and identify the docu-ments upon which they will rely in giving their testimony.
13.
Produce all studies and documents regarding the economic and/or electrical feasibility of interconaecting TIS and SWPP with direct current transmission facilities.
14.
Produce all studies, and all documents related thereto, regarding the economic feasibility of interconnect-ing TIS and SWPP which have been done by CSW since the trial in the Federal District Court, and identify the person or persons who have done the studies.
Respectfully submitted,
' 4tL 4
Grego y 'opeland J[0 0 One S OF COUNSEL:
2 11 Plaze BAKER & BOTTS Fo ston, Texas 77002 3000 One Shell Plaza Houston, Texas 77002 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING EOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY, 5
Docket Nos. 50-498A et al.
S 50-499A S
(South Texas Project, Units S
Nos. 1 and 2)
S S
TEXAS UTILITIES GENERATING S
Docket Nos. 50-445A COMPANY, et al.
S 50-446A S
(Comanche Peak Steam Electric S
Station, Units 1 and 2)
S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Second Set of Interrogatories and Requests for Production of Documents from Houston Lighting & Power Company to Central and South West Corporation, Public Service Company of Oklahoma, West Texas Utilities Company, Southwestern Electric Power Company, Central Power and Light Company, and Central and Southwest Services, Inc. were served upon the following persons by deposit in the United States mail, first-class postage prepaid, this 6 64 day of 92b 1980.
G7 J
Gre" gor
'pelarfd
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Marshall E. Miller, Esq.
Roy P.
Lessy, Jr.,
Esq.
U.S. Nuclear Regulatory Commission Michael B.
Blume, Esq.
Washington, D.C.
20555 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Michae)
L.
Glaser, Esq.
1150 l'th Street, N.W.
William C.
Price Washington, D.
C.
20036 Central Power and Light Company P. O.
Box 2121 Sheldon J. Wolfe, Esq.
Corpus Christi, Texas 78403 U.S. Nuclear Regulatory Commission Washington, D.
C.
20555 G.K.
Spruce, General Manager City Public Service Board Atomic Safety and Licensing P.O.
Box 1771 Appeal Board Panel San Antonio, Texas 78203 U.S.
Nuclear Regulatory Commissicn Washington, D.C.
20555 Perry G.
Brittain Texas Utilities Generating Co.
Chase R.
Stephens 2001 Bryan Tower Docketing and Service Section Dallas, Texas 75201 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 R.L.
Hancock, Director City of Austin Jerome D.
Saltzman Electric Utility Department Chief, Antitrust and Indemnity Group P.O.
Box 1088 U.S.
Nuclear Regulatory Commission-Austin, Texas 78767 Washington, D.C.
20555 G.W. Oprea, Jr.
J.
Irion Worsham, Esq.
Executive Vice President Merlyn D.
Sampels, Esq.
Houston Lighting & Power Company Spencer C.
Relyea, Esq.
P.O.
Box 1700 Worhsam, Forsythe & Sampels Houston, Texas 77001 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 David M.
Stahl Isham, Lincoln & Beale Jon C.
Wood, Esq.
1050 17th Street, N.W.,
Suite 701 W.
Roger Wilson, Esq.
Washington, D.C.
20036 Matthews, Nowlin, Macfarlane & Barrett 1500 Alamo National Building Michael I. Miller, Esq.
San Antonio, Texas 78205 James A.
Carney, Esq.
Sarah N. Welling, Esq.
J.A.
Bouknight, Esq.
Isham, Lincoln & Beale Bill Franklin, Esq.
4200 One First National Plaza Lowenstein, Newman, Reis, Chicago, Illinois 60603 Axelrad & Toll 1025 Connecticut Avenue, N.W.
R.
Gordon Gooch, Esq.
Washington, D.C.
20036 Baker & Botts 1701 Pennsylvania Avenue, N.W.
Washington, D.C.
20036
Don R.
Butler, Esq.
Morgan Hunter, Esq.
1225 Southwest Tower Bill D.
St. Clair, Esq.
Austin, Texas 78701 McGinnis, Lockridge & Kilgore Fifth Floor, Texas State Bank Bldg.
900 Congress Avenue Jerry L. Harris, Esq.
Austin, Texas 78701 Richard C.
Balough, Esq.
City of Austin W.
S.
Robson P.
O.
Box 1088 General Manager Austin, Texas 78767 South Texas Electric Cooperative, Inc.
Joseph B.
Knotts, Jr.,
Esq.
Route 6, Building 102 Nicholas S.
Reynolds, Esq.
Victoria Regional Airport Debevoise & Liberman Victoria, Texas 77901 1200 17th Street, N.W.
Washington, D.
C.
20036 Robert C. McDiarmid, Esq.
Robert A.
Jablon, Esq.
Don H.
Davidson Marc R.
Poirier City Manager Speigel & McDiarmid City of Austin 2600 Virginia Avenue, N.W.
P.O.
Box 1088 Washington, D.
C.
20036 Austin, Texas 78767 Kevin B.
Pratt Jay Galt, Esq.
Texas Attorney General's Office Looney, Nichols, Johnson & Hays P.
O.
Box 12548 219 Couch Drive Austin, Texas 78711 Oklahoma City, Oklahoma 73102 William H.
Burchette, Esq.
Knoland J.
Plucknett Frederic H.
Ritts, Esq.
Executive Director Law Offices of Northcutt Ely Committee on Power for the Watergate Building Southwest, Inc.
Washington, D.
C.
20037 5541 East Skelly Drive Tulsa, Oklahoma 74135 Tom W.
Gregg, Esq.
P. O.
Drawer 1032 John W.
Davidson, Esq.
San Angelo, Texas 76902 Sawtelle, Goode, Davidson & Tiolo 1100 San Antonio Savings Building Leland F.
Leatherman, Esq.
San Antonio, Texas 78205 McMath, Leatherman.& Woods, P.
A.
711 West Third Street Douglas F.
John, Esq.
Little Rock, Arkansas 72201 Akin, Gump, Haver & Feld 1333 New Hampshire Avenue, N.
W.
Paul W. Eaton, Jr., Esq.
Suite 400 Hinkle, Cox, Eaton, Coffield &
Washington, D.
C.
20036
& Hencley 600.Hinale Building P.
O.
Box 10 Roswell, New Mexico 88201 W.
N. Woolsey, Esq.
Kleberg, Dyer, Redford & Weil 1030 Petroleum Tower Corpus Christi, Texas 78474 Robert M.
Rader Conner, Moore & Corber 1747 Pennsylvania Avenue, N.
W.
Washington, D.
C.
20006 Donald Clements Gulf States Utilities Company P.
O.
Box 2951 Beaumont, Texas 77704 Susan Cyphert U.
S.
Department of Justice Antitrust Division, Energy Section Room 8308 414 llth Street, N.
W.
Washington, D.
C.
20530 G.
Holman King West Texas Utilities Company P.O.
Box 841 Abilene, Texas 79604