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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied 1999-06-18
[Table view] Category:TRANSCRIPTS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
[Table view] Category:DEPOSITIONS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
[Table view] |
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DOCKET NO. 1517 f PREPARED TESTDiONY OF ROBERT M. GROSS, JR.
1 1Q PLEASE STATE YOUR.NAME AND ADDRESS.
I 2 A My name is Robert M. Gross, Jr. My business address is 1000 Crescent i
3 Avenue, N.E., Atlanta, Georgia 30309.
{ 4Q WAT IS YOUR EDUCATIONAL BACKGROUND?
- 5A I graduated from Georgia Institute of Technology in 1965, receiving i
6 the degree of Bachelor of Industrial Engineering. I also attended 7 Georgia State University and in 1971 received the degree of Master 8 of Business Administration, majoring in finance.
9Q PLEASE STATE YOUR PROFESSIONAL EXPERIENCE.
10 A I have been employed by Southern Engineering Company of Georgia for l 11 aPproximately ten years. During this time I have been involved in
! 12 the preparation of cost of service studies of Class A and B investor-t
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13 owned utilities, rural electric cooperatives and municipal electric 14 systems and have participated in wholesale and retail electric rrce i
15 consulting assignments in 23 states. I am a registered professional j
16 engineer in the State of Georgia.
f I 17 Q HAVE YOU EVER TESTIFIED IN OTHER COMMISSION PROCEEDING.S?
I I 18 A Yes, I have testified as a rate expert and cost of service witness h 19 before the State Commissions of Kentucky, Indiana, Michigan, Vermont
] 20 Virginia, and Arizona. I have also testified before the Federal Power 21 Commission (now Federal Energy Regulatory Cotmnission) in proceedings l 22 involving Mississippi Power Company, Appalachi'an Power Company, Duke I
- 23 P wer Company, Gulf States Utilities Company, Gulf Power Company, J
24 Virginia Electric & Power Company, Arizona Public Service Company,
' 25 Public Service Company of Indiana, Inc. , Carolina Power and Light,
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1 Southern California Edison Company.
2 Q WHAT WAS YOUR ASSIGNMENT IN THIS PROCEEDING?
3 A My assignment was in two areas. I was to determine if the 4 methods employed by Texas Power & Light Company to establish 5 the proposed wholesale rate design for the REA class of service 6 were just, reasonahic and consistant with sound rate making 7 procedures.
8 Secondly, I was to review the Company's adjustments to its 9 test year ending September 30, 1977, particularly the adjustments 10 for annualizing the anticipated costs of Martin Lake Unit #2 and 11 Monticello Unit #3 and for attrition, in order to determine the 12 overall validity of Texas Power and Light's system revenue require-13 ment. .
14 Q WITII RESPECT TO Tile FIRST ASPECT OF YOUR TESTIMONY WOULD YOU PLEASE 15 SUMMARIZE TEX-LA'S POSITION WITH REGARD TO TIIE PROPOSED REA -
16 Wil0LESALE RATE STRUCTURE FILED BY TP&L IN TilIS PROCEEDING?
17 A The rate design proposed by the Company in this proceeding with 18 respect to its service to REA wholesale customers appears reasonable 19 except for the Transmission Service Credit of 30 cents per kilowat,t 20 of demand. I find that the credit of 30 cents per kilowatt of 21 demand does not properly recognize the cost difference between 22 transmission service and service at distribution voltages for REA 23 Wholest.le Customers. The appropriate credit for transmission 24 service applicable to the REA class should be 70 cents per 25 kilowatt instead of the company's credit of 30 cents per kilowatt.
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, 1 Q WOULD YOU PLEASE EXPLAIN WiiY IT IS NECESSARY '10 INCLUDE A TRANSMISSION 2 CREDIT IN A WHOLESALE RATE STRUCTURE.
3 A Typically some whoicsale customers take service at transmission 4 voltages and others take service at distribution levels.
A 5 wholesale rate which is uniform for the wholesale classification 6 should recognize the cost differential between service off the 7 Power supply transmission system versus service at lower voltages 8 within the distribution system. Without an appropriately designed 9 transmission service credit, one group of wholes'lea customers, 10 taking service at a transmission voltage, would have to support part 11 of the distribution costs incurred in serving wholesale deliveries 12 at distribution voltages, s
13 Furthermore, in situations where wholesale customers can 14 upgrade their own distribution systems by building transmission 15 facilities and substations, a transmission credit in the wholesa16-16 rate provides an economic incentive for the, wholesale customer 17 to make an orderly transition from taking service at distribution 18 voltages by accommodating its system to the wholesale supplier's 19 transmission network. This of course, is beneficial to the ,
20 wholesale supplier since it would be relieved of the responsibility 21 of providing distribution service to its wholesale customers. The 22 wholesale supplier would thereby have additional distribution 23 capacity, or possibly capital, to apply to the cupplier's retail 24 customers requirements.
\ 25 Q DO TP&L'S REA WHOLESALE CUSTOMERS TAKE SERVICE AT PREDOMINANTLY l
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1 DISTRIBUTION OR TRANS>ESSION VOLTAGES?
2 A REA customers presently take service from the Company at predominantly 3 distribution voltages. In recent years several of the Company's 4 REA cooperative customers have begun to construct the necessary
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5 facilities to take service from the Company at transmission i
6 voltages. I believe presently the Company provides transmission
[ 7 service at approximately 8 REA delivery points. Also, I have been 8 advised that many of TP&L's REA whoicsale customers are planning to i
9 convert their systems to higher distribution, sub-trancmission, I 10 or even transmission voltages. During this transition the REA 11 Cooperatives plan to accommodate their systems to take service from s 12 the Company at negotiated transmission points of delivery and 13 gradually phase out the necessity of the Company having to provide la service to these customers at distribution voltages. I believe 15 this would be in the interest of both Texas Power & Light and the-16 wholesale customers. Of course, the Transmission Service Credit l
j 17 contained in the REA rate should be established at a icvel that -
18 properly reflects the difference in the cost of service to REA 19 delivery points at a transmission voltage versus service to REA .
20 points of delivery at a distribution voltage.
21 Q WOULD YOU PLEASE EXPLAIN HOW YOU DERIVED THE REA TRANSMISSION i
22 SERVICE CREDIT OF 70 CENTS ' PER KILOWATT AS COMPARED TO THE l
, 23 COMPANY'S FILED CREDIT OF 30 CENTS PER KILOWATT?
- I l 24 A Volume IV of the Company's filing contains Texas Power & Light Company's t
25 calculated Cost of Service applicable'by class of customer. .This Cose t
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1 of Service Study shows TP&L's estimate of the cost of providing ,
2 service to the REA wholesale classification. A close review of 3 this Cost of Service Study shows that the Company presently 4 experiences a significant amount of distribution costs in 5 providing service to the REA classification since most REA
- 6 delivery points are at a distribution voltage and must support 7
an allocation of distribution costs. The Cost of Service Study f
8 reveals that the 30 ceat per kilowatt REA Transmission Service 9 Credit proposed by the Company does not reflect the level of the 10 distribution cost incurred by TP&L in serving the typical REA 11 distribution voltage delivery point. The Company has derived 12 the 30 cent per kilowatt Transmission Service Credit based upon 13 typical transformer investments for certain LP-10,000 customers 14 (See response to TEX-LA date of request #J-3). This method is i
15 incorrect because the LP-10,000 customers do not have the same -
! 16 service or cost characteristics as the REA class. LP-10,000 l 17 customers are required to take service at transmission (60,000 18 volts or higher) whereas REA customers take service at voltage 19 levels requiring a wide spectrum of distribution facilities. ,
. 1 20 Q llAVE YOU PREPARED AN EXHIB7T WHICH SHOWS THE CALCULATION OF THE 21 70 CENT TRANStRSSION CREDIT THAT YOU PROPOSE? !
22 A Yes, Exhibit No.__(RMG-1) shows the derivation of the 70 cent per
! 23 kilowatt credit. Line 1 shows a figure of $7,818,269 representing 24 the amount of distribution plant related rate base (less meter k- 25 inves tment) that TP&L has allocated to REA service through its 3
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l 1 Cost of Service Study contained in Volume IV of the filing. This 2 amount represents an average investment in distribution plant 3 required to serve the REA class amounting to $3.22 per kilowatt _
4 of billing demand. Applying the Company's derived fixed charge i
5 rate of 25.6% (which includes a component for return, taxes, 6 and other fixed charges) producce a potential credit o'f 82.5 i 7 cents per kilowatt of billing demand. I have reduced that figure 8 to 70 cents per kilowatt in order to establish a Transmission 9 Service Credit consistent with the over-all revenue requirement 10 established by TP&L for the REA class.
11 Q IS YOUR PROPOSED TRANSMISSION SERVICE CREDIT CALCULATED IN A MANNER s 12 COMPARABLE TO Tile DEVELOPMENT OF TIIE PROPOSED REA DEMAND CIIARGE?
l 13 A Yes, both the Demand Charge and tl}c Transmission Service Credit 1
14 are based on the Company Cost of Service Study and are products l 15 of average cost pricing.
16 Q MR. GROSS, IF TIIE TRANSMISSION CREDIT IS INCPEASED FROM 30 CENTS 17 PER KILOWATI TO 70 CENTS PER KILOWATT AS YOU llAVE PROPOSED, WOULD 18 TllERE BE A CORRESPONDING UPWARD ADJUSTMENT IN Tile DEMAND CIIARGE 19 REQUIRED IN ORDER TO SATISFY TIIE OVERALL REVENUE REQUIREMENT OF ,
20 Tile CLASS?
21 A Yes. The overall demand charge, as approved by the Commi'ssion 22 for the REA class, would have to be increased 7 cents per kilowatt 23 in order to off-set the revenue impact of an increase in the 24 -credit from 30 cents per kilowatt to 70 cents per kilowatt. This
' 25 calculation is shown on footnote 4 of E::hibit No._(RMG-1) page- 1.
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i 1Q WITil RESPECT TO Tile SECOND FIIASE OF YOUR TESTIMONY MR. GROSS, 2 W0lILD YOU PLEASE DESCRIBE YOUR ANALYSIS OF Tile COMPANY'S TEST 3 YEAR INCLUDING YOUR EVALUATION OF Tile ADJUSTMENTS MADE BY TP&L 4 TO ESTABLIS11 TilEIR OVERALL SYSTEM REVEIRJE REQUIREMENT?
5 A From Company's testimony it appears that TP&L is attempting to 6 set rates which will recover its cost of operations and produce
- 7 an allowed return on capital based on future operations. The 8 test year of 12 months ending September 30, 1977 has been adjusted 9 in numerous ways to accomplish this end. The Company has made t
10 adjustments to all of its expenses for year-end conditions and l 11 has annualized its labor expenses for the impact caused by labor g 12 contracts in effect subsequent to the end of the test year. The 13 largest adjustment, however, made by the Company concerns the 14 increase in test year investment and expenses caused by the 15 annualization of the Martin Lake Unit #2 and Monticello Unit #3 j' 16 which are estimated to be cqmmercial by the Spring of 1978. Even 17 with this substantial adjustment to the test year for units which j 18 will not be commercial until 6 to 8 months after the end of the i <
1 19 test year, the Company also inserts an attrition factor in its cost 20 of capital which it states is needed in order to prevent a decline l 21 in earnings that will likely occur in the immediate future due 22 to a whole myriad of different cost factors.
23 In reviewing the Company's testimony and exhibits concerning 24 the justification for the attrition factor, I can find no actual N 25 data showing that this Company is now experiencing attrition.
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1 Certainly if an attrition adjustment is necessary, then the l
2 burden of proof should be on the Company to show that it is 3 indeed experiencing attrition under the rates approved by the F
4 Comission last year. TP&L, as of June 1977, was allowed rates l
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5 to be placed in effect producing, on,a test year basis, 58.2 l 6 million dollars in increased revenues. Since actual evidence is 7 not availabic from TP&L's filing, I have prepared Exhibit _(pJiG-2) i 8 to determine if TP&L is suffering any decline in the level of its i
f 9 carnings under present rates.
l 10 Q WOULD YOU PLEASE DESCRIBE EXHIBIT "(RMG- 2) ?
I 11 A Using the Company's monthly operating statements for the period 1 ,
! ( 12 December 1976 through november 1977, I have calculated by month i
13 the 12 month net income amounts earned by TP&L adjusted fer the 14 rate increase effective July 1977. Line 3 of Exhibit _(Rl'a-2) 15 shows that the Company has experienced an increase in annualized -
16 earnings of a substantial amount during this period c E time. More I
l 17 importantly, the twelve month adjusted income carnin!;s when divided l
I 18 by the monthly capitalization balances of TP&L, show that the 19 carnings per dollar of invested capital increases during this ,
20 period from 8.77. in December 1976 to 9.27 by Novembri 1977.
21 This shows that under the present rates, TP&L's operations 22 produce a trend of increased earnings, both in magt.itude and in 23 percent of invested capital, rather than an carning decline.
24 Historically speaking then TP&L's recent operations show no l 25 evidence of attrition under the present rate structure.
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1 Q DO YOU 11 AVE AN OPINION AS TO WIIY TliE CO:fPANY 11AS NOT EXPERIENCED 2 ATTRITION DURING Tile PERIOD THAT YOU AN/sLYZED?
3 A Yes. I think first of all the Company's rate structure is so 4 designed that as system kWh sales increase, revenues are produced 5 which tend to offset the increase in the cost of providing service.
6 AlthoughduringthisperiodoftimeTP&Lbroughtonlikesubstantial 7 generating capacity, experienced increases in cost of operations, 8 and went to the capital market, the carnings of the Company continue 9 to increase because of increased monthly kWh sales.
10 Q UOULD THE COMPANY'S ARGUEMENTS CO:!CER\'ING UEATHER ABNORMALITIES 11 DURING TIIE SUMMER OF 1977 ilAVE AN IMPACT ON TIIE RESULT OF THE
( 12 ANALYSIS OF EARNINGS S110WN ON EXHIBIT (RMG-2)?
13 A As covered in the testimony of other TEX-LA witnesses, the weather 14 adjustment made by the Company is incorrect for a number of 15 different reasons. IIowever, even if we take the weather adjustment 16 at TP&L's computed value and appropriately adjust the earnings 17 shown on Exhibit NO (R'40-2) for the period studied, I find that 18 the resulting earnings per dollar of capitalization atill do not 19 decline. Attrition therefore is not evidenced during this period 20 even under the extreme assumption that the weather adjustment is 21 necessary and properly computed.
22 Q MR. GROSS, LOOI;ING INTO TIIE FLTURE DO YOU SEE ANY SIGNIFICANT CHANCES 23 IN THE COMPANY'S OPERATIONS THAT WOULD WARRANT THE IMPLEMENTATION 24 0F AN ATTRITION FACTOR?
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25 A The most substancial change in the Campany's operations in the 26 immediate future will occur with the co==creialization of the Martin 9
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l 1 Lake #2 and Monticello #3 units which the Company estimates to be 2 commercial prior to the 1978 stmmier peak. These units will indeed 1
j 3 change the operations of the Company by raising the cost of providing
! 4 service to the Company's customers. TP&L, however, in adjusting its 5 test year, includes most of the cost which will be experienced i .
- r 6 once these units become commercial. Although I disagtce with the
! 7 manner in which the Company has made the Martin Lake and Monticello i
I 8 adjustment to the test year, I do believe that when the test l 9 year is properly adjusted for the addition of these units, TP&L 10 will have a most comprehensive hedge against future dilution in 11 the return carned on their invested capital. Other witnesses :
( 12 for TEX-LA have additional comments concerning the appropriateness I 13 of this attrition adjustment given other factors of TP&L's operations.
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l 14 Q IN TIIIS SAME RECARD IIAVE YOU REVIbWED Tile RESULT OF TP&L WITNESS i
! 15 SWIGER'S STUDY S110WN IN EX!!IBIT SSS-17 " COMPUTATION OF EXPECTED -
) 16 ATTRITION "
17 A Yes.
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18 Q DO YOU UELIEVE TIIAT TilIS IS A VALID STUDY?
f 19 A No I do not. ,
20 Q WOULD YOU PLEASE EXPLAIN WIIY?
l 21 A Mr. Swiger's study -in based entirely upon a forecast of the i
l 22 relationship between incremental revt.nues per customer and I incremental costs per customer as such are projected to increase 23 24 over the next two years. The study relies upon projections of
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l L 25 number of customers, customer sales, plant in service, invested f
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1 capital, operating expenses, depreciation expenses, other tax l
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2 expense, and finally capital cost including appropriate income 3 taxes. Mr. Swiger, in an attempt to justify an attrition factor, 4 has tried to project operations of TP&L through 1979. Of course, 5 these projections are not based upon known and measurable events 6 to the extent that such would satisfy the Commission's rules 7 and regulations.
8 Other than the fact that the whole study is pre'dicated 9 upon estimates, the one item that appears most questionabic in 10 Mr. Swiger's study is the projected Icvel of kWh sales per 11 customer for 1978 and 1979. In trying to come up with the 12 increase in the level of revenues per customer, Mr. Swiger uses 13 a compound annual growth factor of 1.987. to estimate kilowatt
[ 14 hour sales per customer in 1979. A quick review of TP&L ,
13 Exhibit SSS-13, page 2, shows that TP&L has been experiencing a -
16 considerably higher compound growth rate in this category covering 17 any period since 1971. The projection of kilowatt hour sales 18 per customer has a substantial impact on the results of the " Attrition 19 Study." I have prepared Exhibit No. (RMO-3) which shows both the 20 actual annual growth in kilowatt hour sales per customer from year 21 to year since 1971 (page 1) and the compound rate of growth in 22 kilowatt sales per customer for the period 1971 through 1977 (page 2). l 1
23 This exhibit shows that TP&L has experienced an average annual 24 rate of growth of 4.607, per year even with 1977 adjusted for TP&L's 25 weather adjustment. On a compound annual growth basis. TP&L's 26 kWh sales per customer have increased 4.567 from 1971 through
( 27 1977 also based upon the adjusted 1977 consumption per 28 customer. This points out that TP&L's use of
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1 of 1.987, as the growth factor in kilowatt hour sales per customer 2
is absurd. Furthennore a quick application of any growth percentage 3 in this category above approximately 3.757, to Mr. Swiger's attrition cafculation shcus that TP&L's attrition adjustment is reduced to 5 a negative value because the resulting incremental increase in 6 revenues per customer, as a result of the higher growth rate, 7 taore than execeds incremental cost including TP&L's claimed return 8 on invested capital.
9 MR. GROSS, YOU INDICATE Tl!AT YOU API IN DISAGPIEMENT WITil Tile Q
10 1W;NER IN WilICl! ' Tile COMPANY llAS ADJUSTED ' DIE TEST YEAR FOR Tile 11 boULD ADDITION OF TilESE TWO NEW UNITS TO BE CO:0!ERCI AL NEXT YEAR.
\ 12 YOU PLEASE EXPLAIN IN MORE DETAIL?
13 A Yes. If Texas Power and Light Company were essentially a static 1/' company uith the little expected growth in sales, I would be in 15 agreement with the manner in which the company has adjusted its 16 test year Plant in Service and expenses for the addition of these 17 two units. I find however, that TP&L is not in a static situation.
18 It will be experiencing, as evidenced by its own load projections, 19 considerable k!(n sales growth. With sales growth, TP&L under ,
20 properly designed rates, will be generating additional base revenues 21 substantially in excess of the icyc1 reflected in the test year.
22 The increase in base revenues will act to absorb much of the 23 additional expenses and return on investment that will be
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incurred when these two new units become cc:maercial.
25 TP&L !!AINTAINS TilAT MOST OF Tile CAPACITY TilAT TIIEY WILL BE ADDING Q
$ d f
s 1 IS FOR CONVERSION PURPOSES AND TilEREFORE IS NON-REVENUE PRODUCING.
2 DO YOU llAVE A RESPONSE TO TIIIS POSITION?
3 A Yes. I find that TP&L has and will be adding generating plant 4 capability for both load growth and conversion purposes. It 5
- seems, however, that for the next three to four years, TP&L 6 will be experiencing load growth equal to the amount of' capacity 7 that it adds to its system. I have prepared Exhibit,__(RMG-4) which B shows TP&L expects its System peak load to grow by approximately 9 800 megawatts during the three year period 1978 through 1980. If 10 a 20% reserve criteria is assigned to each kilowatt of load growth, .
11 then approximately 1000 megawatts of additional generating capacity g 12 is necessary to match load growth. TP&L is adding 924 (net) 13 megawatts of generating capability or slightly less than the amount 14 required for load grouth. TP&L Exhibit (RKC-8) shows reserves 15 of the Company to decrease from 1978 through 1980 from 50% down -
I 16 to 37.4%.
17 All of this indicates that TP&L seems to be reversing the trend 18 that it has experienced in the past which has been to add more U
3 19 generating capability than load growth. The present rates approved 20 by f he Commission in the last TP&L rate filing are based upon a i
j 21 test year including system reserves of approximately 45%. TP&L's
, 22 projections show that its reserves will decline signficantly to l 23 a level in the lower to mid 30's in the early 1980's. l l
24 I believe that ,for rate making purposes if an adjustment can s 25 be made to the current test year for the higher unit cost that will .
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I be attendant with the new generating unit additions coming on line 2 in the immediate future, then growth in TP&L's sales coupled with 3 the proper rate design should offset TP&L's cost of operations 4 ~
during the next several years. I have approached the Martin Lake 5 and Monticello adjustments to the test year on this basis.
0 WOOLD YOU PLEASE EXPLAIN 110W YOU IIAVE ADJUSTED TIIE TEST YEAR FOR Q
7 Tile MARTIN LEE AND MONTICELID ADDITIONS?
8 A Exhibit No._(RMG-5) Schedule 1, su=narizes the adjustments that 9 I have made to the test year for Martin Lake Unit #2, Monticello 10 Unit #3 and also Martin Lake Unit 43, in those areas where I 11 differed with the Company's approach. I have included Martin
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12 Lake #3 in r calculation so as to be sure to include, as fully 13 as possibic, the impact that all new generating unit additions will 14 have on the average unit cost of Texas Power and Light during the 15 immediately forseeabic future. These are the only generating 16 additions that TP&L projects to be coemercial during the next 17 three years.
18 As shown on Exhibit _(RMG-5) Schedule 1, I have changed the 19 adjustment for Electric Plant in Service, depreciation expense and ,
20 production operations and maintenance expense less fuel from the 21 amount derived by TP&L. The method I have used to calculate the 22 adjustment is comparabic for all three cost ;'tegories. I have 23 first detemined the unit cost per kilowatt of procaction capability 1
( 24 experienced during the test year and then compared that value with
! 25 the unit cost resulting af ter the addition of the Martin Lake #2, l
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1 Martin Lake #3, and Monticello #3 units. For instance, on 2 Schedule 2 of Exhibit : o.__(IUC-4), I show that presently TP&L's 3 cabedded investment cost per kilowatt of production capability 4 is -$98.14 per kilowatt. With the addition of Martin Lake #2 & 3 5 and Monticello #3 the average investment cost per hilowatt will 6 increase to $125.87. I have taken the difference betwebn these 7 two unit cost figures and multiplied that times the generating 8 capability of the Company during the test year in order to 9 derive a Plant in Service adjustment of $169,358,607. Once this 10 amount is added to Production Plant in Service, the test year is 11 then adjusted for the higher unit investment cost that TP&L f
( 12 will be experiencing through 1980. With this component built 13 into the test year rate base, the additional growth in sales 14 coupled with an appropriate rate design will produce revenues _
15 for the Company that should match its cost of providing service -
16 since the unit cost that goes into the base rates will be at Icasc 17 equal to the unit cost experienced by the Company over this 18 period of time.
19 The adjustment to depreciation expense and production operation 20 and maintenance expense is made on the same basis.
21 I should add that the mechanics of this series of adjustments 22 are canparable to TP&L's Plant in Service adjustment for Martin 23 Lake Unit #1 allowed by the Commission in the last rate case.
/ 24 Q DOES TilAT CO !CLUDE YOUll TESTIMO::Y?
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25 A Yes.