ML19308C979
| ML19308C979 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak, 05000448  |
| Issue date: | 01/30/1980 |
| From: | Ahearn C, Knotts J DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| 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 8002130031 | |
| Download: ML19308C979 (31) | |
Text
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DOCKETED USNRG UNITED STATES OF AMERICA p
4 NUCLEAR REGULATORY COMMISSION gg 311980>
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P ting &seta Bruch In the M.tter of
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.N dOUSTON LIGHTING AND POWER CO. )
Docket Nos. 50-498A
_et _al.
)
50-499A
)
(South Texas Project, Units
)
1 and 2)
)
i
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, _et _al.
)
50-446A (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM TEXAS UTILITIES GENERATING COMPANY TO CENTRAL AND SOUTH WEST CORPORATION 7 PUBLIC SERVICE COMPANY OF OKLAHOMA 7 WEST TEXAS UTILITIES COMPANY, SOUTHWESTERN ELECTRIC POWER COMPANYT CENTRAL POWER AND LIGHT COMPANY,V 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, Texas Utili-ties Generating Company (TUGCO)) propounds the following inter-rogatories 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 South-west Services, Inc., and its predecessor CSR Services, Inc.
Each interrogatory should be answered separately.and fully in writing l
under oath or affirmation by the person or persons 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.
8002180 Q
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DEFINITIONS As used herein the terms listed below, unless otherwise specifically indicated, are intended to have the following meaning:
1.
The word " person" or " persons" include natural persons, firms, partnerships, associations, joint ventures, unit operations and corporations, or any other legal entity.
2.
The terms " officers," "direccors," "agants," " employees" and other designations mean any person serving at any time during the relevant 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 Corporation and/or any affiliated companies of CSW includes, without 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 definition 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 Southwest l
Services, Inc., and its predecessor CSR Services, Inc.
j l
i I
4.
The term "TUGCO" means any or all of the following companies and their officers, directors, agents, or employees:
Texas Utilities Company, Texas Utilities Service Company, Texas Utilities Generating Company, Texas Power 'and Light Company, Dal'las Power and Light Company, Texas Electric Service Company, and any other subsidiary of their saility companies.
S.
The words " identify," " identifying" or " identification" -
i whe" used in reference to a natural person mean's to state his l
full name and present or last known address and telephone number, his present or last known position or business address and l
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 i
maintained, all identifying marks and codes, the addressee, i
the document date, author, and persons to whom copies were i
t 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, or (4) other-wise disposed of, and in each instance, explain the circumstances
surrounding an authorization for such disposition thereof and state the date or approximate date thereof.
6.
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, correspondence, memoranda, stenographic or handwritten notes, drafts, studies (including, but not limited to, engineering, market, and economic studies), publications, in'roices, ledgers,' comparisons, tabulations, charts, journals, books, records, accounts, pamphlets, voice recording, reports, surveys, statistica2 compilations, work papers, 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 Without limitation of the term " control," a document is copy.
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.
7.
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.
I
. f 8.
~ " Witness" refers to any person who may give testimony, l
whether direct or rebuttal.
f i
9.
" Relating to" means consist of, report to, reflect or i
l be in any way legally, logically or factually connected with i
the matter discussed.
~ENERAL' INSTRUCTIONS l
2 l
The following general instructions apply to each of the i
{
discovery requests contained herein.
1.
Documents produced shall be grouped and marked by i
interrogatory.
2.
If you claim privileges as to any document or as to I
any answer requested by these interrogatories, identify, in the case of documents, the date of the document, the sender (s-),
i 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.
i I
3.
In the event any document requested in these interro-gatories is unavailable, describe in detail the circumstances I
l 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.
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5.
Restate the interrogatory or document request as the first part 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 TUGCO'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 fs to i
be answered invidually by including them except where the
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answers would be the same, where it will be sufficient to l
simply indicate such entity so answering.
Documents should 1
be produced for each responding entity; exact duplicates may be listed (other means of avoiding duplication of actual production may of course be adopted by agreement).
All f
documents are requested to be produced at the law offices of i
Debevoise & Liberman, 1200 Seventeenth Street, N.W.,
Suite 700, j
Washington, D.C.
20036 or as may be otherwise mutually agreed upon by the parties.
t 8.
These interrogatories and requests for production of j
documents are not meant to duplicate answers already prov'ided f
or documents already produced to TUGCO earlier in this pro-ceeding or in the Dallas District Court proceeding.
If the 1
I
appropriate answer to an interrogatory has been previously given or the required documents have been previously produced, a specific reference to the previous response'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.
J i
I b
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS 1.
Identify spearately every area in which CSW competes with TUGCO, including but not limited to:
1 (a) Each relevant product'.and geographic market;
.(b) The nature and extent of competition between I
CSW and TUGCO in each such market; j
(c) The date upon which competition began and f
1 i
the length of time the competition has l
existed in each such market; (d) The identity of every actual competitor in each such market, and a description of such l
competitor's activities in that market; (e) The identity of each potential competitor in j
l each such market; (f) The market share of every competitor in each i
such market.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
a 2.
List and describe every instance since January 1,1968, i
known to CSW in which an officer or director of CSW has prepared t
or approved any writing, including handwritten notes, or l
made or approved any oral statement that concerns the presence, absence or extent of competition between CSW and TUGCO, excluding pleadings, motions or affidavits filed in any legal proceeding.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
j 2.
Identify every existing or potential industrial customer of CSW that has located a new facility in the service area of TUGCO instead of the service area of CSW, or has expanded an existing facility in the service area of TUGCO instead of building a new facility or expanding an existing facility in the service area of CSW, since January 1, 1968, because of the difference, if any, in the cost of electricity between a TUGCO service area and the service area of CSW, and for each such customer separately state:
(a) The date(s) such customer located or expanded in TUGCO's service area; I
(b) The identity of the entity in whose service area such customer did not locate or expand because of a difference in the cost of electricity; (c) Whether CSW had sold such customer electric power before such customer located or expanded in TUGCO's service area; (d) The megawatts and megawatt-hours per year of i
electric power that CSW or any affiliated company had sold such customer, if any, in each of the five years preceeding the year in which such l
customer located or expanded in TUGCO's service area and the identity of the company furnishing such electric power; i
a
(e) The basis for the assertion that the cost of electricity was the determining factor in the location.or expansion of the tacility or facilities in question; and j
(f) The identity of every customer's representative with whom CSW dealt with on this matter.
Produce every, document referring or relating to or setting forth the matters inquired into in'this interrogatory.
l 4.
Identify every existing or potential industrial customer of CSW that has cut back production in a plant located in the service area of CSW and has increased production in a plant making the same product in the service area of TUGCO since January 1, 1968, because of the difference in the cost of electric power between TUGCO's service area and the service area of CSW, and for each such customer separately state:
(a) The date(s) such customer cut back production in a service area of CSW; (b) The date(s) such customer increased production in TUGCO's service area; (c) Whether CSW sold such customer electric power i
before such customer cut back production in the service area of CSW and expanded production in TUGCO's service area; (d) The megawatts and megawatt-hours per year of
~
electric power that CSW sold such customer in each of the five years preceding the date upon which such customer cut back production in the i
i
service area of CSW and expanded production in TUGCO's service area, and the identity of the company making such sales; (e) The megawatts and megawatt-hours per year
[
of electricity that CSW sold such customer in each year following the date upon which such
(
customer cut back production in the service
(
area of CSW and expanded production in TUGCO's P
service area, and the identity of the company j
making such sales; and (f) The billing demand, the average price per kilowatt-hour, and the total revenue per year that CSW received from such customer, in each of the five years preceding and every year following the date upon which such customer cut back production in the l
service area of CSW and expanded production in TUGCO's service area, and the identity of the company making such sales.
Produce every document referring or relating to or setting forth the matters ingdired into in this interrogatory.
5.
Identify every industrial concern that has contacted CSW since January 1,1968 about the possible purchase of electric power from CSW, but to which CSW has responded, in whole or f
j in part, that CSW might not be'able to supply some or all of the d
,_____,_e,,.
, electric power inquired about by such concern, or to which CSW offered a more limited class of service than requested by such -
concern, and with respect to each such concern separat.ely state:
(a) The date (s) of such contacts; (b) The company such concern contacted; (c) The identity of the individual (s) at
~
such company who was contacted; and (d) The reason (s) given by CSW for such response.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
6.
Identify every existing or potential industrial customer of CSW that has located a new facility in TUGCO's service area instead of the service area of CSW or has expanded an existing facility in TUGCO's service area instead of expanding an existing facility in the CSW service area since January 1, 1968, because of the difference, if any, in the reliability of electric service between TUGCO's service area and the service area of CSW, and for each such customer separately state:
(a) The date(s) on which each customer located or expanded in TUGCO's service area; (b) The identity of the utility in whose service area such customer did not locate or expand because of a difference in reliability; i
i i
(c) Whether CSW had sold such customer electricity before such customer located or expanded in TUGCO's service area; (d) The megawatts and megawatt-hours per year of electricity that CSW had sold such customer, if any, in each of the five years preceding the year in which such customer located or expanded in TUGCO's service araa, and the identity of the company furnishing such electricity; (e) The number and length of all service interruptions suffered by such customers, if any, in each of the five years preceding the year in which such customer located or t
expanded in TUGCO's service area, and the identity of the company furnishing such elec-tricity; (f) The basis for the assertion that reliability was the determining factor in the location or expansion of the facility or facilities in question; and (g) The identity of every customer's representative with whom CSW dealt on this matter.
Produce all documents referring or relating to or setting forth the matters inquired into in this interrogatory.
l
. 7.
State whether TUGCO has ever denied CSW access to any service or facility that CSW considered necessary to e,ffectively service its customers, and if so, separately state:
(a) The identity of the company denied such l
service or facility; (b) The service or facility denied; (c) The date of such denial; (d) The person (s) ' at TUGCO denying such service i
or facility; (e) The manner in which such denial affected CSW's service to its customers; (f) The extent, if any, to which such denial caused CSW to be disadvantaged with respect to its competitors; and (g) The coepetitor(s) with respect to which t
CSW became disadvantaged as a result of such I
denial.
f Produce all documents referring or r&lating to or setting forth the matters inquired into in~this interrogatory.
8.
Separately describe every instance in which CSW considered the possibility of taking electric power from the Comanche Peak pro ect, and with respect to each such instance state, separately:
l l
i (a) Whether CSW made any study of the cost of obtaining power from the Comanche Peak Project under a Mode 2 arrangement, and if so, fully describe the cost identified by such study; (b) Whether CSW made any study of the cost of obtaining power from the Comanche Peak Project under a Mode 4 arrangment, and if so, fully describe the cost identified by such study; (c) Whether CSW gave any consideration to the cost of obtaining power from the Comanche Peak Project under a Mode 2 type condition prior to the closing of the participation offer in Comanche Peak; (d) The reasons participation was sought; and (e) The influence other members of CSW might have had upon the company seeking participation.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
9.
State every occasion upon which TUGCO has denied CSW access to or use of any nuclear power plant, or the electric power generated by such Plant and fully describe each such occasion, and produce all documents referring or relating to or setting forth the matters inquired into in this interrogatory.
l
10.
State every occasion upon which TUGCO has denied CSW access to or the use of TUGCO's transmission lines and fully describe each such occasion.
Produce all documents re' ferring or relating _to or setting forth the matters inquired into in this interrogatory.
11.
State whether CSW has received any requests for an ownership interest in or unit power purchase from the Comanche
~
Peak Project from any municipal electric system, electric company,: electric cooperative or other entity contingent upon CSW's acquisition of an interest in the Comanche Peak Project, and, if so, separately state:
(a) The identity of every entity from which such a request was r'eceived; (b) The date (s) of each such request; (c) The terms incorporated in such requests; (d) The response to such requests; and (e) The identity of every person known to CSW to have knowledge of such request and/or response.
Produce all documents referring or relating to or setting forth the matters inquired into in this interrogatory.
12.
State whether CSW has conducted, taken part in or is otherwise aware of any comparison, study, computation or other 1
l
. consideration of duplicating TUGCO's transmission lines and/or securing alternative transmission lines in the event that the and if l
transmission lines of TUGCO are not available to CSW, 1
so separately state:
The entity making each such comparison, etc.;
(a)
(b) The date (s) upon which each such comparison, etc., began; The identity of every person who contributed (c) information or data for such comparison, etc.;
The identity of every person outside of (d)
CSW who took part in or was consulted with respect to such comparison, etc.; and (e) The conclusion (s) reached by such comparison, 5
etc.
Produce all documents referring or relating to or setting forth the matters inquired into in this interrogatory.
State the occasions upon which CSW or its attorneys I
13.
have met with members of the Department of Justice or the i
i NRC Staff with respect to the antitrust implications of the l
construction and/or operation of the Comanche Peak Steam Electric l
t Station and separately state:
(a) The date(s), location and subject. matter of each such meeting; and The identity of every person present at each
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(b) such meeting.
r
. Produce all documents transferred between CSW, the Department of Justine ar.d the NRC Staff during or in connection with each such meeting and all documents referring or. relating to or setting forth the matters inquired into in this interrogatory.
14.
Identify every electric utility (including affiliated companies) that has requested to purchase electric power from CSW since January 1, 1968, but to which CSW has refused or declined to sell all or part of the electric power requested, and with respect to each such electric utility separately state:
(a) The identity of the entity to which the request was made; (b) The type of power requested, such as firm power, contract power, economy power, emergency power and wholesale power; (c) The date(s) upon which such utility requested each type of power identified in (b) above; (d) For each type of power identified in (b),
the amount of electric power in megawatts and megawatt-hours requested on each such date, and the amount, if any, sold to such utility; l
(e) Whether at the time of requesting electric power such electric utility was within or adjoining the service area of the company to which the request was made; and
- Ja (f) The reason (s), if any, given to the requesting utility for not selling the ' requested amount of electric power.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
15.
Identify every electric utility (including affiliated companies) to which CSW has offered to sell electric power since January 1, 1968 but which has refused or declined to purchase all or part of the electric power offered, and with respect to each such utility separately state:
(a) The identity of the offeror; (b) The type of power offered for sale, such as firm power, contract power, economy power, emergency power, and wholesale power; (c) For each type of power identified in (b),
the amount of electric power offered, the date of such offer, and the amount, if any, purchased by such utility; (d) Whether at the time of requesting electric power such electric utility was within or adjoining the service area of the company to which the request was made; and (f) The reason (s) if any given to the offering utility for not purchasing all of the electric power.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
16.
Identify every electric utility (including affilated companies) with which any CSW company has offered to negotiate an interconnection or polling arrangement, or joint construction of generation ' facilities, since January.1, 1968, but which has refused or declined to participate in such agreement, and -
with respect to each such utility separately state:
(a) The identity of the offeror; (b) The date (s) upon which such agreement (s) was offered to such utility; (c) Whether at the time of the offer such utility was in the service area of the company offering the arrangement; and (d) The reason (s), if any, given by the i
utility for not entering into such an i
agreement.
Produce all documents referring or relating to or setting forth
{
the matters inquired into in this interrogatory.
17.
Identify every electric utility (including affiliated f
companies) which 'has offered any CSW company an interconnection or pooling arrangement, or joint generating plant construction since January 1, 1968, but in which such CSW company has refused i
or declined to participate, and state separately with respect to each such utility:
i t
I l
(a) The identity of the entity to which such offer was made; (b) The date(s) upon which such offer was received; (c) Whether at the time of the offer such utility was within or adjoining the service area of the company receiving the offer; and (d) The reason (s), if any, given for not agreeing to the interconnection or joint construction arrangement.
Produce all documents referring or relating to or setting forth the matters inquired into in this interrogatory.
18.
Identify every electric utility thatjlas requested transmiscion services from any CSW company since January 1, 1968, but to which CSW has refused or declined to provide any of the transmission services requested, and with respect to each such electric utility separately state:
(a) The identity of the entity to which the request was made; (b) The type of transmission service requested; (c) The date of the request; (d) Whether at the time of the request such electric utility was within or adjoining the service area of the company to which the request was made; and (e) The reason (s), 'if any, given-for not providing the transmission services requested.
l
l l
j Produce all documents referring or relating to or setting forth I
l the matters inquired into in this interrogatory.
19.
Identify every electric utility that has requested an ownership interest in any coal or nuclear powered electric generating plant being planned or constructed by CSW, and with respect to each such electric utility separately state:
(a) The identity of the entity to which the request was made; (b) The electric generating plant in which the ownership interest was requested; and (c) The response, if any, given to the request.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
20.
Identify every electric utility that has requested access to services or facilities (other than those already identified in these interrogatories) from CSW, and with respect to each such electric utility separately state:
(a) The identity of the entity to which the request was made; (b) The type of service (s) or facility involved; (c) The type of access requested and the date of the request; and (d) The response, if any, given to the request.
Produce every document referring or relating to or setting forth the matters inquired into in this interrogatory.
21.
Identify every industrial concern that has requested to purchase electric power'from CSW since January 1, 1968 but to which CSW has refused or declined to sell all or part of the electric power requested, and with respect to each such concern separately state:
t (a) The identity of the entity to which the request was made; (b) The date (s) upon which such concern requested electric power; (c) The amount of electric power in megawatts i
requested on each such date, and the amount, i
if any, sold to such concern; (d) Whether at the time of requesting the electric power such concern was within or adjoining the service area of the company to which the request was made; and I
(e) The reason (s), if any, given to such concern for not selling the requested amount of electric power.
Produce all documents referring or relating co or setting forth l
the matters inquired into in this interrogatory.
~
22.
Identify every change to the existing or planned l
transmission or distribution systems of any of the CSW companies
which would be necessary to permit each of them to provide approximately the same level of reliability of service as they currently provide in the event CSW engages in Mode 4 operation.
Produce all documents relating to these changes.
- 23. (a) State the approximate cost of the changes identified in your answer to Interrogatory No. 22; (b) State the method by which the cost was computed; and (c) Identify the individual (s) who computed the cost.
24.
State separately the present attitude of the management of each of the CSW companies on the issue of interstate versus intrastate operation and identify every factor which was con-sidered by each management in forming that attitude including all considerations going to the maintenance of the CSW holding company status.
Rank each factor in terms of its relative importance in forming that attitude.
25.
Is CSW currently negotiating, or considering, the possible purchase from or sale to other electric utilities of electricity in any year between 1980 and 2000?
If so, describe each such transaction, including the type and amount of electricity involved, the utilities involved, the time for the transaction, and the initiator of the transaction.
26.
Has CSW entered into any agreement or understanding with any other electric utility for the provision of " wheeling" or other transmission services?
If so, for each such company state:
l
(a) The identities of the electric utilities involved; (b) Describe the terms of each such agreement or under-standing by stating the utility which will provide i
the " wheeling" or other transmission service, the amount of electricity to be " wheeled," the period of time during which such " wheeling" or other transmission service will be provided, and the charge for such " wheeling" or other transmission l
I service.
Produce all documents concerning any such agreements or under-
[
standings.
i 27.
State separately the policy or position of each of i
the CSW companies with respect to the provision by them of i
" wheeling" or other transmission services for other electric utilities and produce all documents relating to such policy or position.
28.
Describe every adverse consequence which CSW believes might result from:
(a) Disconnection"of TUGCO from CSW; s
(b) Disconnection of CSW from TUGCO and HL&P; and (c) Disconnection of CSW's' Texas subsidiaries from its non-Texas subsidiaries.
f 29.
Describe the manner in which CSW believes each adverse consequence described in the answer to Interrogatory No. 28 could be mitigated or el'iminated and state the approximate cost which such mitigation or elimination would entail.
Produce all documents prepared since January 1, 1970 analyzing or relating to:
l (a) The cost or price at which CSW will be able to sell electricity in the future; and/or l
(b) The impact of the cost or~ price of electricity i
on CSW's ability to retain existing customers or attract new ones.
30.
Produce all documents prepared since the PTI study relating to the effect, if any, on the CSW transmission or distribution system or on CSW's ability to provide service i
to its customers, of any of the proposals advanced by CSW for more complete coordination under either Mode 2 or Mode 4.
i 31.
Produce a copy of each advertisement placed since January 1, 1976 which attempted to encourage potential industrial or commercial customers to locate a plant or facility in the CSW service area, and identify the newspaper, journal, magazine or periodical in which, and state the time period during which, each such advertisement was run.
32.
State the amount which CSW has spent on advertising in each year since 1970.
33.
State the amount of the fuel adjustment to the industrial customers of CSW for each month since January, 1976 and state whether the fuel cost adjustment to industrial cus-tomers for each such month differed from the fuel cost adjustment applied to other customer classes.
l l
r-l 34.
Describe specifically each respect in which CSW believes l
that coordination within the Electric Reliability Council of Texas ("ERCOT") could be maximized in the period 1980 2000 and
\\
state the benefits which the ERCOT companies could achieve through r
such maximum coordination.
Produce all documents relating to I
any analysis of maximizing coordination within ERCOT and/or the benefits achievable through such coordiration.
l i
35.
Identify separately each person that CSW expects to call or present testimony on its behalf or as an expert witness at the hearing in this matter, and with respect to each such person identified state the subject matter on which the expert is expected to testify and the substance of the facts and opinions to which the expert is expected to testify, and give a summary j
of the grounds for each such opinion.
36.
Identify and produce efery document received, reviewed or generated by, or which formed in whole or in part the basis I
for or in any way contributed to the conclusions reached by, the experts identified in response to Interrogatory No. 35 in this matter.
j i
37.
Identify every non-expert witness that CSW expects to call as a witness at the hearing in this matter.
i 38.
Produce all documents that will be relied on by the non-expert witnesses identified in Interregatory No. 37 l
at the hearing in this matter.
l l
j u
. 39.
Produce all documents in CSW's possession that mention both TUGCO and any of the following entities in the same document:
(a) Tri-County Electric Cooperative; (b) Brazos Electric Cooperative; (c) The City of Azle; or i
(d) The City of Keller.
40.
State the name, business address, residence address and position in or affiliation with CSW of each person who provided infcrmation in connection with the answers to any or all of these interrogatories, and indicate by number those interrogatories with respect to which each such person provided information.
Respectfully submitted,
\\
f1' l
, J.'*
Joseph B.
Knotts, Jr.
s,-
. immi%
m.
C. Dennis Ahearn Debevoise &'Liberman 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 i
(202) 857-9800
~
Attorneys for Texas Utilities Generating Company January 30, 1980
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
In the Matter of
)
)
EOUSTON LIGHTING AND POWER CO.,
)
Docket Nos. 50-498A i
.et _al.
)
50-499A
)
(South Texas Project, Units
)
1 and 2)
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
i (Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "First Set of Interrogatories and Requests For Production of Documents From Texas Utilities Generating 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." in the above l
captioned matters, were served upon the following persons by deposit in the United States' mail, first class postagc prepaid this 30th day of January, 1980.
Marshall E. Miller, Esq.
Mr. Jerome D.
Saltzman U.S.
Nuclear Regulatory Chief, Antitrust and Commission Indemnity Group Washington, D.C.
20555 Nuclear Reactor Regulation U.S. Nuclear Regulatory l
Michael L.
Glaser, Esq.
Commission 1150 17th Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 i
J.
Irion Worsham, Esq.
l Sheldon J. We,1fe, Esq.
Merlyn D.
Sampels, Esq.
~
U.S.
Nuclear Regulatory Spencer C.
Relyea, Esq.
Commiscior.
Worsham, Forsythe & Sampels Washington, J.C.
20555 2001 Bryan Tower, Suite 2500 Dallas, Texas 75201 Atomic Safety and Licensing Appeal Boazd Panel Jon C. Wood, Esq.
U S. Nuclear Regulatory W.
Roger Wilson, Esq.
Commission Matthews, Nowlin, Macfarlane &
j Washington, D.C.
20555 Barrett 1500 Alamo National Building Chase R.
Stephens San Antonio, Texas 78205 Docketing and Service Branch U.S.
Nuclear Regulatery Dick Terrell Brown, Esq.
Commission 800 Milam Building i
Washington, D.C.
20555 San Antonio, Texas 78205 l
Charles G. Thrash, Jr., Esq.
Don R.
Butler, Esq.
E.W. Barnett, Esq.
Sneed, Vine, Wilkerson, Theodore F. Weiss, Esq.
Selman & Perry J. Gregory Copeland, Esq.
P.O. Box 1409 Baker & Botts Austin, Texas 78767 3000 One Shell Plaza Houston, Texas 77002 Jerry L. Harris, Esq.
Steven R.
Hunsicker, Esq.
Richard C. Balough, Esq.
R.Gordon Gooch, Esq.
City of Austin i
John P. Mathis, Esq.
P.O. Box-1088 Baker & Botts Austin, Texas 78767 1701 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 Robert Lowenstein, Esq.
J.A.
Bouknight, Jr., Esq.
Roy P.
Lessy, Sr., Esq.
William J. Franklin, Esq.
Michael B.
Blumt, Esq.
Douglas G.
Green, Esq.
Fredric D.
Chanania, Esq.
Lowenstein, Newman, Reis, Ann P.
Hodgdon, Esq.
Axelrad and Toll U.S.
Nuclear Regulatory 1025 Connecticut Avenue, N.W.
Commissio.'
Washington, D.C.
20036 Washington, L C.
20555 John W. Davidson, Esq.
Roff Hardy Sawtelle, Goode, Davidson &
Chairman and Chief Executive Tioilo officer 1100 San Antonio Savings Bldg.
Central Power and Light Company San Antonio, Texas 78205 P.O. Box 2121 Corpus Christi, Texas 78403 Douglas F.
John, Esq.
Akin, Gump, Haver & Feld Mr. Perry G. Brittain 1333 New Hampshire Ave., N.F.
President Suite 400 Texas Utiliti.es Generating Washington, D.C.
20036 Company 2001 Bryan Tower Bill D.
St. Clair, Esq.
Dallas, Texas 75201 Morgan Hunter, Esq.
McGinnis, Lockridge & Kilgore R.L.
Hancock, Director Fifth Floor, Texas State City of Austin Electric Utility Bank Building P. O. Box 1086 900 Congress Avenue Austin, Texas 78767 Austin, Texas 78701 G.W.
Oprea, Jr.
Executive Vice President Houston Lighting & Power David M.
Stahl, Esq.
Company Isham, Lincoln & Beale P.O.
Box 1700 1050 17th Street, N.W.
Houston, Texas 77001 Suite 701 Washington, D.C.
20036 Susan B,.
Cyphert, Esq.
Frederick H. Parmenter, Esq.
Mr. W. N. Woolsey David A.
Dopsovic, Esq.
Kleberg, Dyer, Redford & Weil Nancy Luque, Esq.
1030 Petroleum Tower U.S. Department of Justice Corpus Christi, Texas 78474 Antitrust Division P.O.
Box 14141 Washington, D.C.
20044 i
(
. s' Sarah Welling, Esq.
Michael I. Miller, Esq.
Kevin B.
Pratt, Esq.
James A.
Carney, Esq.
Attorney General's Office Isham, Lincoln & Beale State of Texas One First National Plaza P.O. Box 12548 Suite 4200 Austin, Texas 78711 Chicago, Illinois 60603 Frederick H.
Ritts, Esq.
Don H. Davidson William H. Burchette, Esq.
City Manager Northcutt Ely i
City of Austin Watergate 600 Building P.O. Box 1088 Washington, D.C.
20037 Austin, Texas 78767 W.S.
2cbson General Manager i
~
South Texas Electric Cooperative, Inc.
[]
A' jggf
~
Route 6, Building 102 C.
Dennis Ahearn Victoria Regional Airport Victoria, Texas 77901 Robert C. McDiarmid, Esq.
Robert Jablon, Esq.
Marc Poirier, Esq.
2600 Virginia Avenue, N.W.
Washington, D.C.
20037 l
W.N. Woolsey, Esq.
Dyer and Redford 1030 Petroleum Tower Corpus Christi, Texas 78474 j
Donald M.
Clements I
Gulf States Utilities Company Post Office Box 2951 Beaumont, Texas 77704 Marc J. Wetterhahn, Esq.
Rober,t M.
Rader, Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 j
Mr. William C. Price Central Power & Light Co.
P.O. Box 2121 Corpus Christi, Texas 78403 Mr.
G. Holman King West Texas Utilities Co.
P.O. Box 841 Abilene, Texas 79604
_ -.