ML19309A754
| ML19309A754 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, South Texas  |
| Issue date: | 03/21/1980 |
| From: | Blume M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Green D LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| References | |
| NUDOCS 8004010262 | |
| Download: ML19309A754 (2) | |
Text
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March 21, 1980 HAND-DELIVERED Douglas G. Green, Esq.
Lowenstein, Newman, Reis, Axelrad &
Toll 1025 Connecticut Avenue, N.W.
Washington, D.C.
20036 Houston Lid.cing & Power Company, et al., (South Texas Project, Units 1 and 2), Docket Nos. 50-498A and 50-499A; Texas Utilities Generating Company, et al., (Comanche Peak Steam Electric Station, Units 1 & 2) Docket Nos. 50-445A and 50-446A Re: Clarification of Staff's Updated Response to Houston Lighting and Power Company's First Set of Interrogatories and Request for Production of Documents
Dear Doug:
In response to your letter of February 25, 1980, Staff responds as follows:
Staff contends that Houston competes with Gulf States Utilities:
for new retail load such as industrial customers considering plant expansions or location of new facilities in Houston's or Gulf States' service areas; new commercial and residential load in dually certified araas shared by Houston and Gulf States; and new commercial loads in areas singly certified to Houston and Gulf States, to the extent that rates and other considerations influence choices of location by potential commercial customers.
2.
Staff's proposed wholesale power market includes only full or partial requirements wholesale power.
It does not include the other types of pro-ducts which are included in Staff's coordination services market.
3.
Staff supplements its response to Houston's interrogatory 10(a)-(c) by stating that the following officers of Houston and TU have or had an under-s'.anding that Houston and TU will or would disconnect in the event that any
(:ntity with which they are or were interconnected enters or entered into interstate interconnections:
D.D. Jordan, 0.E. Simr.ons, P.H. Robinson, 4.R. Brown, J.G. Reese, W.G. Marquardt, J.F. Skelton, R.K. Campbell, J.S. Farrington, E.D. Scarth, L.F. Fikar, W. Lynch, G. MacGregor, and T.L. Austin. The circumstances surrounding the participation of these officers in the agreement to disconnect can be found as follows:
testimony of W.G. Marquardt, U.S. District Court Proceeding, tr. at 1397, 1410, 1434; testimony of E.D. Scarth, deposition in NRC proceeding, tr. at 59, 245, 8004010262
'b Q 243-50, 274-76, 302-08; testimony of L.F. Fikar, deposition in ilRC proceeding, tr. at 79-93, 200-01, 247-52, 264-70; testimony of D.E. Simmons, U.S. District Court proceeding, deposition of March 11, 1977, tr. at 133-38; testimony of D.D. Jordan, U.S. District Court proceeding, tr. of trial, at 2755-56, 2763-65, 2778-79, 2789-2812, 2867-71; testimony of J.G. Reese, U.S. District Court proceeding, deposition of June 8,1977, tr. at 31-32, 37, 60-61; testimony of D.E. Simmons, U S. District Court proceeding, tr. of trial at 2951-59, 2985-93, 3002-08, 3080-83; testimony of P.H. Robinson, U.S. District Court proceeding, deposition of ilarch 9,1977, tr. at 19-23, 63-66, 80-83, 86-87, 213-27, 232-33, 254-61, 263-64, 400-01.
4.
Staff does not presently contend that TU, pursuant to an express agree-ment with HL&P, has conditioned participation in joint generation projects with entities other than HL&P on a " bring your own fuel basis."
Insofar as Houston, by this request, seeks a legal conclusion, however, Staff objects.
I apologi::e for the delay in responding to your letter of February 25, and appreciate your efforts to seek clarifications informally.
If I can be of any further assistance please do not hesitate to contact me.
Sincerely, f!
//1 k w Michael B. Blune Counsel for NRC Staff cc:
Susan Braden Cyphert, Esq.
David M. Stahl, Esq.
Joseph B. Knotts, Esq.
Marc R. Poirier, Esq.
William H. Burchette, Esq.
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