ML19308B261

First Joint Request of Doj,Aec & Intervenors for Document Production by Applicant for Period Beginning on 600101

ML19308B261
Person / Time
Site:	Oconee, McGuire, Mcguire
Issue date:	09/05/1972
From:	Brand W, Clabault W, Leckie D JUSTICE, DEPT. OF, ATTORNEY GENERAL, OFFICE OF
To:	US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19308B260	List: ML19308B259 ML19308B261
References
NUDOCS 7912180841
Download: ML19308B261 (24)

Text

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'. 'I UNITED STATES OF AMERICA

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BEFORE THE t, - M ,f-

%'.(t y p ,/ ATOMIC ENERGY ColGIISSION In the Matter of DUlG P0h'ER C0!!PANY Docket Nos. 50-269A, 50-270A 50-287A (Oconce Units 1, 2 -& 3, 369A, 50-370A McGuire Units 1 & 2) )

FIRST JOINT REQUEST OF DEPART!1ENT OF JUSTICE, AEC REGUTATORY STAFF, AND INTERVENORS FOR PRODUCTION OF DOCULENTS BY APPLICAITf FOR PERIOD _SINCE J!.NUARY 1, 1960 Pursuant to agreement among the parties reached on 26 July 1972, the Department of Jus tice, the Atomic Energy Ccr:nission Regulnt.ory

. Staff, and the Intervenors (hereinafter " joint discoverers") heraby subai.t a joint request for the production of document.s from the filco and records of the Applicant.

Unless otheruise indicated, the documents for which product. ion is sought shall include all documants dated, prepared, sent or received during the period <.nuary 1,1960 to date. Pursuant to agreement, requests for d6cumentary production outside that period will be made by separate motions to the Board. It is further

, requested that production ccmmence as promptly as possible and the production be completed by November 6,1972, a's to those requests to which there is 'no objection made by Applicant. Furthermore, e

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it is requested that several categories of documents necessary for completio. of engineering / economic studies be supplied in advance of other production, as soon as possible, but in no event later than October 6, 1972. These are indicated by asterisk in the schedule. The joint discoverers request that objections to production be made to the Board by September 21, 1972. Further, as to those requests upheld by rulin-g of the Board, the joint discovercrs ask that production be ompleted by Applicant either by the dates specified above, or within 10 days from the date of the Ecard's ruling for documents requested by October 6 and 30 days fro.a the date of the ruling for documents requested by November 6.

It in requested that any documents within the categories in the cttached schedule withheld by Applicant by reason of any assertion of privilege be identified individually by listing the person (s) prcparing, sending or receiving the same, the subject and date thereof and a brief statement on the basis for asserting privilege as to each document. ,

It is understood that all parties contemplate a round of discovery additional to these requests. These requests should no t be construed as Itniting in any way the scope or method of that further discovery; and, specifically; further discovery may include a request to search certain categories of files.

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SCllEDULE A. De. finitions . ,

1. " Company" means Duke Power Company, its subsidiaries or affiliates , predecessor companies and any entitics providing electric service at wholesale or retail, the properties or assets of which have been acquired by Duke Power Company.

2. " Documents" means all writings and records of every type in the possession, control or custody of the company, its directors, officers, employees or agents, including but not limited to memoranda, correspondence, reports, surveys, tabulations, charts, books , pamphic ts , photographs , maps , bulletins , minutes , notes ,

diaries, log sheets, ledgers , transcripts , microfilm, computer l l

printouts, vouchers, accounting statements, engineering diagrams )

("one-line" diagra:ns), mechanical and electrical recordings, telc~

phonc and telegraphic communication, specchos, and all other records, l written, cicetrical, mechanical or otherwise.

" Documents" shall also mean copics of documents , sven though the originals thereof are not in the possession, custody or control of the Company, and every copy of a document which contains handwritten or other notations or. which otherwise does not dupliccte the original or any other copy.

3. " Electric utility" means a private corporation, rural clectric cooperative, municipality, or any political subdivision, agency or instrumantality of the Federal or any State or munic'ipal 9

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government uhich owns or controls, or proposes to own or control, facilitics for the generation, transmission or distribution of clectric power and energy.

4. " Coordination" and " coordinating" shall include , but are not limited to, reserve sharing, economic dispatch or economy interchanbe, and pooling of load growth for joint or staggered additions of generating or transmissi.on facilitics.

" Coordination" and " coordinating"'shall also mean joint venturcs or the sharing of participation in the ownership, operation or output of generating facilities and the sharing of ownership, construction or use of transmission facilitics.

11 . Docuuents No Longer in Company's Pnarg:: pion. Cuntedv or Control.

If any document described in this schedule was, on or after December 17,1970 (date of enactment of P.L.91-560) , but is no longer, in the Company's possession, or subject to the Company's control, or in existence, state whether (a) it is missing or lost, (b) has been destroyed, (c) has' been transferred, voluntarily or involuntarily, to others, or (d) has been otherwise disposed of.

'In cach instance, explain the circumstances surrounding such disposition and identh.fy the person (s) directing or authorizing -

same, and the date(s) thereof. Identify cuch such docuicent by listing its author and addressee, type (e.g. , letter, memorandum, telegram, chart, photograph, etc.), date, subject matter, present location (s) and custodian (s), if the document (or copies) are j

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still in existence.

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C. Documents Recuested.

1. Documents showing the Company's corporate organization since January 1,1960, including:

(a) names of departments, divisions and subunits and dates of their organi=ation and reorganization; (b) names of all directors , corporate officers , depart-ment or division managers and the dates of their service in each office held (Indicate date of election or appointment, if prior to January 1,1960, for each individual serving in such capacity as of that date);

(c) function and responsibilitics of each officer, manager and department or division listed in (a) and (b) above and the dates of any changes therein; (d) name or identification, period of existence, function of, and persons comprising each ccmmittee reporting to company officers or the Board of Directors on a regular or ad hoc basis.

(Charen, tabulationa or lists setting forth the above informa-tion and verified by a company officer may be furnished in

• lieu of the foregoing documents) .

2. All file indexes'and documents describing the filing system utilined by the Company, its departments, divisions and. subunits,

' pertaining to active, inactive or stored files and records.

3. Any narrative history (or histories) 'of the Company.

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4. Documents including minutes of meetings of the Board of Directors and the crecutive committee of the Company, documents prepared in advance of meetings (e.g. , agenda, memos in summary or critique of plans, costs, proposals or status of negotiations),

and letters and memoranda to or from Company officers, relating to:

(a) interconnection plans , proposals or agreements with other electric utilitics; (b) termination of the CARVA pooling agreement on October 20, 1970; (c) e:cpansion of or additions to generating capacity or trancaission system to be (1) owned and utiliced solely by the Company or (2) shared on any basis with one or more electric utilities; (d) competition at wholesale and retail; (c) acquisitions by Company of electric utility proper-tics and proposals for such acquisition or invitations to purchase electric utility properties; (f) Icgislation and constitutional revisien affecting the ability of electric utilities to own, finance , construct facilitics and to sell electricity; '

(g)* wholesale and retail clectric rates and proposals

- for rate changes; (h) clections in any municipality 7perating an electric distribution system; .

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(1) Piedmont Electric Cities Association (PECA); EPIC, Inc. ; ElectriCities of North Carolina; (j) purchase by Company of land on the Green River comprising a part of the proposed site of FFC Project No. 2700; (k) consideration of the request of intervenor to participate, through ownership of an entitlement share or otherwise, in the present units; (1) litigation, actual and considered, before courts '

or agencies in opposition to construction of competing generation or transmission facilitics, including but not limited to FPC Project No. 2700.

5. Minutes of meetings and reports of each committee i

established under pooling er coordination agreements to which Company is a party, those of each subcommittee or task force thereof, and documents relating thereto prepared or circulated within the Company. ,

6. Documents relating to the following:

(a) neu electrical loads, aren growth or development and locations available for sites for commercial or industrial development in areas in whs:h such electrical loads might be

- served by electric utilitics other than Company; (b) electric service franchises for service by Ccmpany at retail, and.any applications, renewals or terminations' I

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(c) action, or contemplated action, by Company in response to failure by any municipality to renew any electric service franchisc; (d) franchises held by any other supplier of electric service within the Company's general service arca; (c) policias or practices., understandings or arrange-ments with other electric utilitic ' '- to allocation of wholesale or retail service areas; (f) inquiries, invitations, negotiations, ovaluations and proposals for the acquisition of electric power facilities

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of municipalitics, electric cooperatives or other electric utilities including (1) offers to serve at wholesale; (2) communications to or about elected officials, councils, and boards; and (3) sponsorship, support or opposition by the Comp.any of activities of citicen or taxpayer committees ,

community advisory councils, or the like; (g) acquisition of Company facilities by purchase or condemnation; - -

(h) cost analyscs or estimates of other North Carolina and South Carolina electric.utilitics' (present or proposed) system operations; comparisons of costs, rates or services of the Company vis-a-vis other electric utilities serving ,

or able to serve in contiguous areas of North Carolina and South Carolina.at wholesale or retail; .

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(i) activities by the Company to obtain for itself subsidies, exemptions, waivers, loans or construction funds or other favorable action of any kind by any agency, political subdivision or instrumentality of Federal, State or local governments, benefiting the Company including but not limited -to actions relating to:

(i) Oconee nuclear generating project; (ii) McGuire nuclear project; (iii) Catawba nuclear project; (iv) trcnsmission line construction or relocation; .

l (v) construction, improvement or maintenance of water facilities such as docks, wharfc , river, j stream or estuary dredging; recreation facilities;

, (vi) air or water pollution control; (vii), tax rulings, state or federal; (viii) Federal or State tax legislation or regulations thereundcr;  !

(ix) Federal or State regulatory legislation pertaining to electric utilities, including but not' limited to amendments to the Federal Power Act, the At'omic Energy Act and North Carolina and South Carolina Public Utilitics and Municipal Corporations L'aws -- and including 4 g

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but not limited to bills restricting the availability for power development of any waterway in or adjacent to Company's service arca, authorizing, appropriating funds for, or otherwise affecting Federally-owned electric generating or transmission facilitics in or adjacent to Company's service area, affecting the jurisdiction cr organization of any governmental agency charged with licensing, supervising, or regulating Company's facilities ,

, rates or services, or affecting the ability of municipal or cooperativo systems to acquire or own facilitics or render electric service; (x) efforts in opposition to the authorization or construction of ccmpeting generation.or transmission; (j) studies of joint:cenership or other participation ~.

considered, proposed or agreed upon between the Company and othc[ clectric utilitics with respect to nuclear, fossil-fuel or hydroelectric generating facilitics and transmission facilitics ;

(k) Company's exchange of information on any facet of its system operations in. d cooperative endeavor with any f 1

wholesale customer; 10 ,

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(1) requests or indications of interests by third .

parties in power pooling arrangements with Company, the CARVA pool or participants in the VACAR arrangements; (m) present and future planned interconnections with other utilities, and their proposed capacity and status (tontative or assured);

(n) studies or analyses of 5.?ll generation and/or trans-mission integration or coordination between Company and any other c1cceric utility; (o) the Company's line extension policy, including any modifications or interpretations thereof;

.(p) FPC Project No. 2700 (Green River) and the site

. thereof; (q) activities of Ccapany to. affect the cost of fuel for electric power generation by other persons in north and South Carolina; (r) the outage time in 1971 por customer per year in -

cach of Company's districts and the number of outages per customar per year (In lieu of such documents, a verified summary of such information may,be supplied) .

7. Correspondence betueen the Company and Edison Electric

' Institute or any committee thereof; the National Association of Electric Companies; Bozell & Jacobs; Central Surveys of Shenandoah, Iowa; Hofer and Sons of Portland, Oregon; Cargill, Wilson & Acreo, Inc. of Charlotte , North Carclina (or R. L. Ward); any other 11 '

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consultant or independent contractor; and any clectric utilities; and documents referring to these entitics and persons relating to:

(a) system construction, financing, ownership, operation of electric generation, transmission or distribution facilitics by any municipal and clectric cooperative utility, including acquisitions of any suc.h utility by the Co:apany, or competition betucen any such utility and the Company; (b) wholesale power supply to municipal and cooperativo utilities; (c) coordination, interconnection or pooling arrangements with municipal and cooperative systems; (d) wholesale or retail territorial or customer allocctions.

8. Documents showing the names and addresses of all attorneys retained by the Company and describing the basis for such retainers.

(In lieu of the foregoing, a verified' list containing the information would be acceptable.)

9. Documents pertaining to the following subjects located

. in the files of those individuals who by job or title are now or have boon since January 1,1960, responsible for, prepare analysis of, or forecast the effects of those subjects:

- (a) long-term competitive aspects of the Company's relationship with other electric utilities serving or able to servd at uhoicsale or retail in areas overlapping or in close ' pro :imity to the company's servide arca; 6

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(b) interconnection arrangements with other electric utilitics; (c) coordinated system operation, generation and transmission facilities expansion, and pooling arrangements involving other electric utilitics.

10. Documents referring or relating to communications between the Company and Carolina Power & Light Company (CP&L), Virginia Electric and Power Company (VEFCO) and South Carolina Electric and Gas Company (SCE&G) and among Company personnel in connection with the CAnVA. Fool agreement; (a) its formulation and the evaluation of any advantages or disadvantages thereof; (b) participation by third parties and limitations

- 'therco f; (c) its dissolution, including but not limited to estimates of the cost impact of ' dissolution on the Company.

11. Documents re ferring or relating to communications betseen the Company, CP&L, VEFC0 and CCE&G and among Company personnel

. ' in connection with the "VACAR" agreements; (a) their formulation and the evaluation of any advantages or disadvantages th'ereof; (b) participation by third parties and limitations thereo f.

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12. Documents relating to the Southeastern Electric Reliability Council (SERC), its formation and activities and Company's participation therein, including, but not limited to, any documents portaining to the decisions setting qualifications for membership and full participation.  !

13. Documents comprising the Company's individual files pertaining to cach wholesale electric customer of the Company (excluding billing data) including but not limited to (a) files identified by specific customer name; (b) files relating to any elected or appointed official of any municipal wholesale customer; (c) retail or wholesale competition relating to such customers; (d) interconnections or coordination with and sale or purchase of electric power or facilities to or from each customer; (c) analysis or study of each customer's system operations , rates, finances , expansion proposals and programs; including but not limited to any maps and diagrams of customer's transmiss, ion system; (f) communications with officials or members of boards of directors of wholesale customers which are or were cooperatives or private corporations , and with.

managers.and persons in elective or appointiva office, t

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who are or were responsible for the operations of each .

municipal wholesale customer; (g) communications to or fiom, or internal documents concerning any taxpayers i ' committee or any similar group or newspaper, and any action taken or proposed to be taken

.by such committee or group or nouspaper with respect to matters affecting a wholesale customer. .

14. A set of all rate schedules (currently, offective or otherwise) filed i>y Company uith the FPC. (If schedules are identical, one such schedule and a list of the parties to which it applies (applied) may be furnished in lieu of all the individual schedules. If schedules are almost identical, one of them plus a-list indicating the differences in the others will suffice.)

15 . Documents reflecting changes in any rate schedule, tariff, l contract, agreement, or tenns and conditions of service., or the effect on Company revenues (in dollar or percentage terms) of any such change. -

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16. Docurcents (including records of expenditures) regarding any advertisements, public-relations campaigns, or other ,means

! employed by Company to elicit support for its views in or in 1

connection with any municipal or state election in North Carolina or South Carolina.

17. Documents comprising the Company's individual files portaining to Electricities of North Carolina (o.r its predecessor, I

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EPIC, Inc .; and Piedmont Electric Citics Association, including but not li,aited to copics of releases by Company's public relations office re;.arding those entitics, and lettars concerning them addressed to any reunicipality or electric cooperative.

18.* One small scale and one large scale copy of the most recent geographic one-line diagram or map of the Company's electric generation and bulk transmission system and points of interconnection virh other c1cetric utilities indicating transmission or sub-transmission facilities of 23 kv. and above, delivery points and '

supply voltanen for municipalitics and cooperatives; further, large scale maps of SERC, the CARVA pool, and the area covered.by the VACAR agreements.

19.* The cost recent electrical one-line diagrams showing the generation and transmission systems corresponding to the diagrams requested in paragraph 18.

20.* A copy of the maps or diagrams for each planning period or year through 1985 corresponding to those requested in paragraphs 18 and 19. .

21.* Yearly peak power flow diagrams through 1985 for Company's system, and for such larger bulk power supply system arcas as may be studied by any power planning or operating groups in which Ccmpany participates by furnishing personnel, data or otherwise. .

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22. The operating manuals or equivalent documents for the CARVA pool and for.the present VACAR arrangements.

23. Each press release or article containing data supplied by the Company, or any internal ' document describing the Company's bulk power supply control center, or the major features thereof, such as equipment for load-frecuency control, economic dispatch, security monitoring, systema diagram-board, remote riupervisory equipment, information brought in to the control center from remoto points, nnd the like.

24.* Documents relating to pooling agreements or interchange arrangements in uhich the Company is a participant, directly or indirectly, ubich show:

(a) the method (s) used to . interpret and determine any installed, spinning or operating reserve requirement (s)

.under the terms of such agreements; (b) the method (s) and bases whereby payments are made, receipts disbursed and the manner in which funds flow among the pa7 ;icipants in determining any settlement of balances-for such reserve obligations.

25.* Reports and analyses (excluding load flow diagrams not a part of any such report or analysis except as requested in (d) below)' pertalding fo:_

(a) joint transmission studies with VEPCO, CP&L and SCE&G, or any of them; i (b), joint transmission 9tudies with Georgia Power Co. f I

or the. Southern System; 17 l

. (c) joint transmission studies with Appalachian pouar Co. or the American Electric Power.Co.;

(d) Company transmission; in addition, all transmis-sion load flou studios (plotted on a system one-line diagram of 100 kv and above) for Company's completc _.- ~ ~ [~_

system relating to planned bulk power additions for the period 1970-1985; (e) comparative or alternative programs of generation and transmission expansion for Company, CARVA pool, or any other coordinating group, and letters or memoranda pertaining thereto. .

26.* Documents containing or pertaining to capital and operntion and maintenance cost estimating factors utilined by Cou,,any for:

(a) transmission facilities (by varying voltages and range of capacitics for each voltage) per mile or per hundred miles; (b) ancillary substation facilities (by major cost components) and right of way; (c) generation (by types) and ancillary facilitics (provide breakdoun k)y major components for both generation and ancillary facilities where available); .

(d) escalation factors relating to (a), (b) and (c) of this paragraph, and for fossil fuel, nuclear fuel and other expenses, including but not limited to labor and administrative and general. _

27. Documents indicating:

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(a) the most recent nucicar unit cost estimates, in .

accordance with the FPC Uniform System of Accounts, showing separately the rate of return used; (b) _ the tot'al demand and energy cost of the nuclear units an of December 31, 1978, shouing as a distinct factor the escalation percentages adopted for cost projection purposes. .

28. Documents concerning any legal definition of or restriction on the Company's authority to:

(a) construct system facili: :s within a municipality; (b) render wholesale service to a municipality thich is already purchaning power from anotlier power supplier; (c) construct 'oulk power supply transmission lines id areas where other electric ' systems have installed bulk power supply transmission lines; (d) render service within a municipality which has its own electric system; - ..

(c) share the ownership of electric facilities with any dt.hcr ut:ility or entity; (f) interconnect with any other utility or entity; (g) coordinate or integrate in any other way with any other utility or entity; (h) wheel power from other electric systems to the Company's wholesale customers. ..

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29. Documents concerning the authority or lack thereof of the North Carolina Utilitics Commission or South Carolina Public Service Commission to regulate the construction of generating facilitics , transmission lines or distribution lines by any other supplier of clectric service within Company's service area.

30. Documents in which the-Company has asserted that any of its activitics are, or are not, subject to the Federal Power Act or North Carolina or South Carolina Public Utilitics Law.

31. Duplicate tax returns filed by Company.

32. Copy of the Company's Accounting Manual.

33. Monthly accounting sumularies , reconciliations , or billing statements in use for interconnection settlements betwocn Company and CP&L, SCE&G and VEPCO, betucen Company and Georgia

-Poua Co. , and between Company and Appalachian Power Co. , which indicate the manner in uhich power, energy, or transmission service is exchant,cd or otherwise accounted for, and hcw compencation is determined as between the parties. Copies for 1970 and 197.1 are requested, along with coreparable summaries, reconciliations or billing statements used under the CARVA pool in 1969 and 1970.

Furnish all statistic'al summaries and. documents necessary to apprise joint discoverers of the accounting methods by which entrics on log shocts containing power and energy data are ultimately converted into monetary settlements. rurnish also each of all other bulk power supply energy, or power, or transmission service accounting 9

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forms for the peak day of the peak month of 1972, including weekly or monthly summaries including amounts for such day --

and all such forms for the peak day of the peak month of 1970 under the CARVA pool.

34. Any contract for the sale or exchange of electric power between Co:::pany and any other electric utility, and a copy of any power pooling arrangement under consideration but not yet entered into. -

35. Documents regarding: .

(a) cost studies of nuclear vs. fossil- fueled generation; (b) planning studies made in the period 1960 to a'

date, alone or jointly with other utilitics; (c) transmission load flou studies tcado in the period 1960 to date which have been used in planning; (d) discussions with other utilities regarding the

. allocation of responsibility for, the location of, and 1

the timing of trans, mission construction. ,

36. Documants, including internal memoranda, regarding the ability of municipal and cooperative . Systems to purchase bulk l

power at Company's wholesale rates and resell to retail customers 1 at rates equal or comparabic to Company's retail rates.

37. Rate design studies, documents relating to the decision )

I to file, all correspondence, memoranda, etc. , regarding the filing i uith respect to the wholesale fuel adjustment clsuse (FPC Dochet I i

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As to all nu'elear facilities, exp:rimental or opera-

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rional, documents relating to information, advice, participation and assistance rendered by any agency of the United States Govern-ment (including the AEC) to Company, or to any other entity through which any of such was provided to Company or for the benefit of Company. Please respond as to the time periods prior and subsecucut to 1960. (Referral to documents in the public files of the AEC will be acceptable.)

39. Documents describing the economic condition of the area served by Company, projections of future economic conditions, or the prospect for attracting commercial and industrial customers ,

or other potential stimuli of economic growth, to the area.

40. Documents including but not limited to advertising rqnti rial prepared for the purpose of encouraging commercial and industrial customers to locate in the Company's service area or for the purpose of encouraging increased use of electricity in that service area, and documents concerning Company's approach to, discuccion or other contact with any commercial or industrial customer (actual or potential) .for either of the'se two purposes.

41.* Documents showing the following with respect to each

.cxisting generating unit on Company's system and estimates thereof with respect to cach unit under constiuction:

(a) incremental costs at various levcis of unit output including incremental fuel cost and variable operationfan'd' maintenance cost; .

(b) no-load running cost of each unit including fi::ed fuel cost; 22  !

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(c) start-up costs in dollars following a (1) four-hour shtitdown, (2) 12-hour shutdown, (3) 24-hour shutdown; .

(d) average cnnual fixed costs for each unit including:

(1) fixed operation and maintenance; (2) fixed charges, including a breakdown of fixed charge rate by all components; (3) other fixed costs, including administrative and general expense allocable to each unit; (e) .criginal investment cost and date of commercial operation; (f) incremental heat rate and total heat rate through-out nornal net loading range; ,

(g) average annual fuel cost in cents /mmBett for cach year 1970-1985; (h) minimum and max *1 mum not output in mw; a

A (i) normal annual amount of time for scheduled main-tenance and refueling; (j) for future nucledh units, documents describing how nmortization of the initial fuel core is handlad in the above costs and providing a breakdown of total capital cost at d unit cost amounts for each unit; 42.* Documents showing all actual and proposed po:.cr purchases and sales for the period 1970-1985, indicating mw and mwh quanti-tics and fixed and variabic charges for each such transaction.

43.* All cost of service studies relating to whccling or G

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trcacmicciou service: on Company's syntem for the period 1962-1972 and for the future in the period 1972-1985.

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. Q e David A. Leckic

' Wallace A. Brand William T. Clabsult Attorneys, Antitrust Division Department of Juctice Washington, D. C. 20530 For the Joint Discoverers Sepecmber 5, 1972 1

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