ML19309B995
| ML19309B995 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 03/11/1980 |
| From: | Burchette W NORTHCUTT ELY, LAW OFFICES OF, TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC. (FORMERLY |
| To: | TEXAS UTILITIES CO. |
| References | |
| NUDOCS 8004080018 | |
| Download: ML19309B995 (29) | |
Text
?
T624
.f sy E
- ~THED UNITED STATES OF AMERICA US ;F.0 V-NUCLEAR REGULATORY COMMISSION 4-
. MAR 19 ESO>
t OfE:e cf D.s Sc:t:Y
~
E D::kdcIL S:abt In the Matter of
)
N'h,8 8
)
4/
HOUSTON LIGHTING & POWER
)
Docket Nos. 50-498A 4.1 % U COMPANY, _e_t _al.
)
50-499A
)
(South Texas Project, Unit
)
Nos. 1 and 2)
)
)
In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
)
50-446A
)
(Comanche Peak System
)
Electric Station, Units 1
)
and 2)
)
(Consolidated for Discovery)
UPDATED RESPONSE OF TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC., TO FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS FROM TEXAS UTILITIES GENERATING COMPANY Tex-La Electric Cooperative of Texas, Inc.
(" Tex-La"), here-by updates its earlier response to the First Set of Interrogatories
'and Request for Production of Documents from Texas Utilities Generat-ing Company ("TUGCO").
Interrogatory 1(a) :
Identify each witness, other-than an expert witness, whom Tex-La expects to or may call in these proceedings and provide i
- a. summary 'of all matters (including the substance of all facts) as to which each such witness is expected to or may testify.
8004080 O\\S
. Answer:
In addition to the individuals listed in the initial response, Tex-La may call upon the following individuals to testify:
Mr. J.
B. Phillips The Carter 011 Company P.O. Box 2180 Houston, Texas 77001 Mr. Michael Ozymy Texas Power and Light Company These individuals may be asked to testify to, inter alia, Carter Oil Company's proposed siting of a coal gasification facility in East Texas.
Interrogatory 1(b) :
Identify.all documents upon which each such witness is ex-pected to or may rely in any way, and provide copies of any such document not already in the possession of TUGCO.
Answer:
Documents to be relied upon by these witnesses have previously been produced in this proceeding and are in the possession of TUGCO.
Interrogatory 2(a):
Identify each expert witness whom Tex-La expects to or may call.in these proceedings.
4 u.
~ Answer:
Mr. O.
Franklin Rogers should be removed as possible expert witness on behalf of Tex-La in this proceeding.
Mr. Gross and Mr. Springs remain as possible expert witnesses whom Tex-La ex-pects to call in this proceeding.
Interrogatory 2(b):
State (or produce) the educational and professional quali-fications, experience, and credentials of each such expert witness.
Answer:
With respect to Mr. Gross, the answer is unchanged.
With respect to Mr. Springs, see Attachment A.
Interrogatory 2 (c) :
State the subject matter on which the expert is expected to or may testify.
Answer:
With respect to Mr. Gross, the answer is unchanged.
With respect to Mr. Springs, see Attachment A.
Interrogatory 2 (d) :
Provide a summary'of the testimony which each such witness i
is expected to or may offer, including the substance of all
1
' facts and all opinions to which the expert is expected to or may testify.
Answer:
-Mr. Springs will identify those wholesale services needed by Tex-La to make ownership in the Comanche Peak Project a viable resource in an overall viable power supply arrangement.
In connection with these services, Mr. Springs will also identify which of these services are required of Texas Power and Light Company and for what period of time these services will be re-quired of Texas Power and Light Company.
Such services are to include but not be limited to the following areas:
(a)
Transmission services and related control and coordination services.
(b)
Supplemental partial requirements wholesale power purchases.
(c)
Reserve capacity and related back-up energy purchases.
All such services provided under contractual arrangements which would also provide for appropriate notice on the part of Tex-La and appropriate commitments on the part of Texas Power and Light Company to provide the required services as well as the filing of wholesale rate schedules covering such services to the appropriate governing commission.
Mr. Springs will also testify, in a generic sense, on the possible benefits that would be obtained by Tex-La if, at a time in the future, ERCOT and the SIG?P are electrically intercon-nected in a' synchronous manner.
4
'f For 'an overview of the areas to be covered by Mr. Springs should he be called upon to-testify, please see Attachment A.
Interrogatory 2(e):
State the grounds for each opinion each such expert witness expects to or may present in his/her testimony.
Answer:
The grounds upon which Mr. Springs will base his opinion (s) will be derived primarily from his knowledge of the Tex-La of Texas cooperatives; his experience in supervising generating and transmission planning studies for the purposes of testing the feasibility of proposed systems and for the step by step system
- expansion'of existing systems; and on his experience gained in providing or supervising the technical assistance necessary to negotiate contracts regarding joint arrangements between small
. utility systems and other power suppliers.
1 Interrogatory 2 (f) :
Identify all documents prepared by, for, or under the super-vision of each such expert witness, or reviewed or relied upon in any way by such expert in the performance of his/her duties,
- formulation of his/her conclusions or opinions, or preparation i
of his/her testimony, including particularly work papers, status reports, preliminary outlines and memoranda, and communications 1
n
between such expert and Tex-La or any of its members, any party to the proceeding, or any person with knowledge in any way relied upon by such expert, and provide copies of any such document not already~in'the possession of TUGCO.
Answer:
At the present time, all documents requested pursuant to 1
Interrogatory 2(f) have been provided TUGCO in this proceeding, are already'in the possession of TUGCO or readily available from '
the FERC, NRC, and state commissions referenced in Attachment A.
i Interrogatory 2(g):
Identify any person affiliate'd with a party to these pro-ceedings, and (separately) each other person, from whom infor-mation was obtained which is in any way relied upon or taken into account by such expert, with whom such expert has communicated.
Answer:
No change.
. Interrogatory 2 (h) :
Provide a copy of any contracts, letter agreements, or other understandings between the prospective witness or his employer.and Tex-La or any of its members or successors of either
' which relate in any way to these proceedings.
1 e
6 4
=
. ' Answer:
No change.
' Interrogatory 2 (i) :
Identify all documents not produced in response to the fore-going which have been sent or-given to the prospective witness or his or her employer or to which his/her/their attention has been directed which relate in any way to these proceedings, and provide copies of any such document not already in the possession of TUGCO.
Answer:
No change.
Interrogatory 3:
With respect to each expert witness listed in your response to Item 2.(a),
(a) list each judicial or administrative proceeding since January 1, 1970 in.which each individual has been proferred as an expert. witness.
Answer:
1k) c.hange.
(b). As to each such proceeding, indicate whether he or she was accepted as an expert witness.
Answer:
No change.
+
o
+ -
- a.
. (c)
Provide a copy of the testimony of each such witness as an expert witness in any judicial or administrative proceeding since January 1, 1970.
Answer:
No change.
(d)
List the publications of each such witness.
Answer:
No change.
Interrogatory 4(a):
Identify every document or thing which Tex-La expects to offer in evidence in these proceedings, other than the testimony of witnesses summarized in response to the preceding interroga-tories.
Answer:
There~is no change except to say that all documents to be offered have e'ither been provided by Tex-La to TUGCO, already in the possession of TUGCO or available to TUGCO at the respective-state and federal agencies.
Interrogatory 4(b):
Produce or make available the documents or things identified in 4 (a) ' to the extent not.already in the possession of TUGCO.
. Answer:
No change.
Interrogatory 5 (a) :
Identify each. person affiliated with Tex-La who has, since January 1,11972, communicated with either the NRC Staff (or pre-4 decessor AEC Staff) or the Antitrust Division of the Department of Justice (state which) with regard to any matter pertaining to the antitrust review or antitrust aspects of the Comanche Peak proceeding.
Answer:
No change.
Interrogatory 5 (b) :
Specify (by date) and describe each occasion on which such communication took place and the nature and form of such communi-cation.
Answer:
-No change.
Interrogatory 5 (c) :
. Identify. the other person or persons involved in the communi-cation.
Answer:
No change.
,w r
Interrogatory 5(d):
State the substance of each ccmmunication to the extent such is not documented in correspondence, memoranda, summaries,
~
notes, minutes or the like, which you are hereby requested to identify and produce.
Answer:
No change.
Interrogatory 5 (e) :
Identify any other document which relates to any such com-munication or series of communications, as well as any document provided to or obtained from the NRC Staff or the Antitrust Division (state which) and produce each such document not already in the possession of TUGCO.
Answer:
No change.
Interrogatory 6 (a) :
Has Tex-La or any of its member cooperatives or successors of either intervened as a party (or parties) in any proceeding (or with, regard to any request to institute a proceeding) before FERC under mmendments to Part 2 of the Federal Power Act made by the Public Utilities Regulatory Policy Act of 1978 (PURPA), or otherwise, relating to any request for relief from any order of any agency of the State of Texas, for interconnection or wheeling, or any or all of the foregoing?
6 e
Answer:
No' change.-
Interrogatory 6(b):
Does Tex-La or any of its member cooperatives or successors of either expect to institute such a proceeding before FERC at any time in the next ten years?
Answer:
No change.
Interrogatory 6 (c) :
If the answer to (a) or (b) is affirmative, would such request, if granted, involve or potentially involve use,-by or for Tex-La or any member or successor, of the transmission system of (i) any of the operating subsidiaries of Texas Utilities Company (i.e., DP&L, TP&L, or TESCO).or (ii) of any system which is a member of TIS?
Answer:
No change.
Interrogatory 6 (d) :
If so, identify each system which wou17 bc J,nvolved, and describe the_ transactions for which use a p ess would be re-quired, including the nature of the sefyice, tt;a approximate duration, and the-transmission and/or interconnection configura-tion and capacity contemplated.
Produce any maps, diagram's or
.a
' other documents relating to this subparagraph.
Answer:
No change.
Interrogatory 6(e):
If the answer to 6 (a) or (b) and (c) are in the affirmative, state briefly whether Tex-La believes that there is any relief to which it might be entitled in the Comanche Peak operating license antitrust proceeding which is not also available under PURPA and the' Federal Power Act, as amended.
Answer:
No change.
Interrogatory 6 (f) :
If your answer to 6(e) is in the affirmative, state briefly
. hy.
w Answer:
No change.
Interrogatory 7(a):
State whether Tex-La believes that it is now or may be in the'fdture (and if so when in the future) in competition with DPEL, TP&L' or TESCO (state which).
Answer::
No changet O
e 9
Interrocatory 7 (b) :
If the response to subpart (a) is in any respect in the affirmative, state briefly the product and geographic market or markets involved, and generally the nature and extent of co'mpetition claimed.
Answer:
No change.
Interrogatory 7 (c) :
Identify and produce all documents relating to this inter-rogatory.
Answer:
No change.
Interrogatory 8:
Reference is made to Tex-La's petition to intervene.
Re-ference is also made to the existing conditions in the Comanche Peak construction permits.
(a)
In what respects specifically does Tex-La contend such 1
conditions shoul'd be modified in order to afford relief to which Tex-La. asserts it is entitled?
Answer:
In addition to the answer provided in its initial response, Tex-La contends the existing licensing conditions should be
. Interrogatorv 7(b):
If the response to subpart (a) is in any respect.in the affirmative, state briefly the product and geographic market or markets:invc ved, and generally the nature and extent of competition claimed.
Answer:
No change.
Interrogatory 7 (c) :
Identify and produce all documents relating to this inter-
~rogatory.
Answer:
No change.
Interrogatory 8:
Reference is made to Tex-La's petition to intervene.
Re-ference is also made to the existing conditions in the Comanche Peak construction permits.
(a)
In what respects specifically does Tex-La contend such conditions should be modified in order to afford relief to which Tex-La asserts it is entitled?
Answer:
l In addition to the answer provided in its initial response, Tex-La contends the existing licensing conditions should be I
=
modified to provide Tex-La with the opportunity to seek access to all possible bulk power supplies wherever they may be situated.
Moreover, the existing restrictions placed on Tex-La by TP,&L which require power generated in the. state of Texas to remain within said state should be removed.
(b)
Identify and produce all documents relating to. (a).
Answer:
No change.
Interrogatorv 9 (a) :
Please describe generally how Tex-La anticipates that its members will be constituted or configured over the next thirty-forty years (the approximate duration of the Comanche Peak license) l and state how, if at all, such is different from the situation pre-l vailing at the time your petition to intervene herein was filed.
(Reference is made, inter alia, to Tex-La's answer to TUGCO's motion to dismiss CSW, et al..and for other relief, wherein mention is made of formation of three G&T cooperatives.)
Answer:
No change.
Interrogatory 9 (b) :
Explain generally,how such configuration and expected future pattern of operations bears on the relief. sought and Tex-La's theory of this case, including how such have changed, if at all, since.the petition _to intervene was filed.
15 -
Answer:
~
No change Interrogatory 9 (c) :
Identify and produce all maps, diagrams, or other documents relating to this interrogatory.
Answer:
No change.
Respectfully submitted, At A
Law Offices of Northcutt Ely by William H. Burchette Watergate 600 Building Washington, D.C.
20037 (202) 342-0800 Attorney for Tex-La Electric Cooperative of Texas, Inc.
. March 11, 1980 4
e 9
Sir O
D
. ATTACHMENT A
^ ' - m,1T*3 c
8
.;;;:3.
J U W' '. S 20 > - ].
SUMMARY
OF PROFESSIONAL
\\4Jf.hg@.gg n
EXPERIENCE OF DAVID A. SPRINGS
.\\ y - g.3 p
/,%
ile pursuing graduate studies in electrical engineering from 1948 to 1949 at the Georgia Inst'itute of ~ Technology, Atlanta, Georgia, I was the Assistant Operator of the Georgia Tech A. C. Network Calculator under a Westinghouse Fellowship /1'.
The types of studies we performed on.'the A. C. Network Calculator were
.. diverse, 'and the engineering data and information obtained were substantial..
For instance, I performed numerous " load flow studies," which simulated electric powerflows through networks of transmission lines and substations, which flows were monitored and measured to determine where weaknesses existed or might occur under certain system fault conditions.
The same networks were used to " calculate" short circuit current values for various types'of electrical faults or short circuits over the systems. Without such a device, these calculations would be almos_t impossible or at least impractical to make with respect to complex inter-connected transmission systems.
Dynamic stability studies can also be performed by adding into the computation the inertia characteristics of different generating equipment.
Through step by step computation of changing generator loading and phase -angle changes the simulated electric system can be tested to determine
/1 An A. C. Network Calculator is a device used extensively by utilities during the late forties and 1950's.to study the electrical characteristics of generation and transmission systems.
The device is an analog computer consisting of miniature electrical elements representing power generating units, synchronous condensers, transmission lines, transformers, series or shunt capacitors and reactors, and loads of differing power factors.
Those elements are connected in the configu-
, ration of the generation and transmission system to be studied and appropriate
' precalculated values of resistance and reactance for the various elements the inserted plus appropriate transformer tap settings, generation schedules and voltage levels.
An electric system can thus be operated and tested in miniature.
The system so -set up can be either an existing system or a planned system.
1 t
ATTACHMENT A' whether it will' hold together or separate under various fault conditions.
Such studie,s serve to evaluate system reliability and to determine optimum siting for new gen 2 ration, new transmission lines, new substations, added capacity for exbting substations, and new or additional capacitor bank installations.
The same types of studies are now performed on digital computer equipment with con-siderably expanded capabilities.
Southern Engineering Company has such equipment available in its offices in Atlanta, Georgia.for this purpose.
However, many such studies today involve such large interconnected systems that it is necessary to go to larger computer centers such as the University Computer Center in Dallas, Texas, where I assisted in load flow studies involving a Southwest Power Pool member in Oklahoma.
Upon completion of my graudate studies at Georgia Tech, I was employed from 1949 to 1952 by Southern Engineering Company of Georgia, Atlanta, Georgia as an engineer.
This work included the making of system studies for rural electric cooperatives involving recommendations (in report form) of new substation capacity and location, new lines and line conversion construction, protective equipment including type, capacity and location.
I also prepared schedules of construction
'and cost. estimates based upon present and projected future growth of the areas involved.
During this period, I assisted in the design of the completely new power transmission system of the Central Electric Power Cooperative, Inc., con-structed to serve its 16 rural electric cooperative members in South Carolina.
'Ihis included responsibility for the planning and performance of A. C. Network Calculator studies and the preparation of preliminary design specifications.for transmission lines.and substations includin'g cost estimates.
This system is operated by the' South Carolina Public Service Authority under lease agreements
~between Central Electric Power Cooperative, Inc. and the Authority.
2
4 ATTACliMENT A.
From 1952 until 1963 I was employed by the South. Carolina Public Service Authority, Moncks Corner, South Carolina.
From 1952 to 1956 I was the Wholesale 1 Supervisor in the Planning Section.
My work included the ce=putation of power costs for wholesale and industrial customers under power contract provisions and rate schedules applicable to such service.
It also included studies of past, present and projected costs of the South Carolina Public Service Authority including capital recovery, taxes and required sums in lieu of taxes, insurance and operation and maintenance. expenses.
I allocated such expenses to production, transmission, and distribution ~ functions - (with appropriate allocation of general-plant responsibility and administrative and ger.eral expenses to these three functions) and then separated such costs into appropriate fixed and variable categories for the purpose of testing the adequacy of demand charges and energy charges 'n rate schedules.- I performed the preliminary studies for this purpose and assisted the independent engineer who performed the final studies upon which recommendations were based.
These studies required the accumulation of billing determinants (kilowatt months of demand and/or monthly kilowatt hours of energy) for. all classes of customers. My responsibilities included the wholesale customers and large industrial customers.
In the early fif ties, the South Carolina Public Service Authority added steam generation to their previously all hydro operation.
This required an altogether new and different approach to operating hydro reservoirs to obtain maximum effective use:of the capacity and energy available at the Santee-Cooper hydro-L
. electric,proj ect..The addition of steam generating resources on.the system not l
l only allowed a' redetermination of higher levels of dependable capacity from the project,; but also required the development of a " rule. curve" for seasonal reservoir elevations to use as a guide for reservoir operations to maximi::e energy 3
ATTACHMENT A
- availability.
I was assigned the responsibility of ' developing the appropriate
. rule, curve./2' From 1956 to 1962 I was Planning Engineer for the South Carolina Public Service Authority in charge of the Planning Section of the Engineering Department.
My responsibilities included the preparation of annual construction-budget ite:as including transmission lines, new transmission substation facilities, distri-bution substation facilities,'and capacitor bank additions.
This work also included the preparation of engineering studies including cost estimates upon which the proposed equipment selection was based.
Also, when necessary, the investment and operating costs of alternative solutions to system problems were determined for the purpose of selecting between two or more alternatives.
This work usually took me back to the A. C. Network Calculator at Georgia Tech for engineering studies.
Between 1956 and 1962~ while I was Planning Engineer, the Authority, together with the Central Electric Power Cooperative, added additional generation to the system at a new site.
The siting of this new plant and associated transmission facilities to connect the plant with the existing systers were established through' load flow studies and stability studies performed on the Georgia Tech A.-C. Network Calculator.
These studies were my responsibility.
/2
--- This procedure consisted of a series of computations based upon actual inflow records over a period of years comparing at various reservoir levels the energy production at each level weighed agains.t the risk of spilling additional water over the spillways due to operating at the higher elevations when floodwaters occur.
With.a given amount of discharge through the turbines, energy production varies almost proportionately with the reservoir elevation (net head).
- However, when high. inflow causes spilling from the reservoirs, ' the higher the reservoirs are at the beginning of the inflow, the greater the amount of spilling.
Com-puting these plusses and minuses monthly over a period of years based upon actual
-inflov. conditions develops the optimum reservoir level under average conditions.
The operators used the " rule curve" as a guideline.
That is, if watershed con-ditions are dry, operators may feel safe in operating above the curve to get more
- effective use of water; however, if watershed conditions are wet, the operators may draw the reservoir down below the curve to avoid unnecessary spilling.
F 4
~
i ATTAC11 MENT AL From 1962 to 1963 I was the Industrial Engineer in charge of the Industrial Department of the ' South Carolina Public Service Authority with the primary
- responsibility for sale of wholesale power and for wholesale customer relations.
In December of 1963, I returned to Southern Engineering Company of Georgia as an engineer.
I was, and am, in charge of the Power Supply Planning and Power System Planning Section. My work includes the supervision of generating and transmission planning studies for the purposes of testing the feasibility of proposed systems and for the step-by-step system expansion of-existing sys,tems to meet load growth.
I have also been responsible for providing or supervising technical assistance in negotiating contracts regarding joint arrangements and coordination between our clients and other power suppliers.
I have been involved as Principal Engineer for such planning in Maine, Vermont, Virginia, North Carolina, South Carolina,' Georgia, Florida, Alabama, Mississippi, Oklahoma, Kansas, Illinois, Kentucky and Ohio.
I have also testified as an expert witness before the Federal Power Commission in Carolina Power & Light Company FPC Docket No.
E-7564; Georgia Power Company FPC Docket No. E-7548 and E-9091; Florida Power Corporation FPC Docket No. E-7679; Duke Power Company FPC Docket No. E-7720; Central Vermont Public Service Company FPC Docket No. E-7685; Florida Power and Ligh~t FERC Docket No. ER78-19; Southern Company Services FERC Docket No. ER78-76; Georgia Power Company FERC Docket No. ER78-166;' Nantahala Power and Light Company FERC Docket Nos. ER76-828 and ER78-18; Public Service Board of the State of Vermont; and before the Nuclear Regulatory Commission Board in Docket Nos.
50-348A and 50-364A.
.There follows summaries of several. of the projects similar to the KEPCo project for which I am responsible:
9 4
5
'1 ATTACHMENT A lFrom 1962 to 1963 I-vas the Industrial Engineer in charge of the' Industrial
' Department of the South CarolinaLPublic Service Authority with -the primary responsibility for sale of wholesale power and for wholesale customer relations.
In December of 1963, lt returned to Southern Engineering Company of Georgia l
as an engineer.
I was, and am, in charge of the Power Supply Planning and Power System Planning'Section.
My work includes the supervision of generating and transmission planning studies for.the purposes of testing the feasibility o'f proposed systems and for the step-by-step system expansion of. existing systems to meet load growth.
I have also been responsible for providing or supervising i
technical assistance in negotiating contracts regarding joint arrangements and coordination between our clients and other power suppliers.
I have been involved as Principal Engineer for such planning in Maine, Vermont, Virginia, North Carolina, South Carolina,' Georgia, Florida, Alabama, FEssissippi, Oklahoma, Kansas, Ill'nois, Kentucky and Ohio.
I have also testified as an expert witness before i
the Federal Power Commission in Carolina Power & Light Company FPC Docket No.
E-7564; Georgia Power Company FPC Docket No. E-7548 and E-9091; Florida Power Corporation FPC Docket No. E-7679; Duke Power Company FPC Docket No. E-7720; Central Vermont Public Service Company FP.C Docket No. E-7685; Florida Power and Light FERC Docket No. ER78-19; Southern Company Services FERC Docket No. ER78-76; Georgia Power Company FERC Docket No. ER78-166;' Nantahala Power and Light Company FERC Docket Nos.-ER76-828 and ER78-18; Public Service Board of the State of Vermont; and before the Nuclear Regulatory Commission Board in Docket Nos.
50-348A and 50-364A.
There follows summaries of several. of the projects similar to the. KEPCo
~
project-for which I am responsible:
6 5
c
--3
-n e,,,
._y-
,+.-y
a ATTACHbiENT_A BUCKEYE POWER, INC.
R 1965 to Date Buckeye Power, Inc. of Columbus, Ohio is a generation and trans=ission cooperative whose membership includes all of the 28 distribution cooperatives in the State of Ohio.
The " Buckeye Project" is an arrangement for the joint owner-ship and operation of generating facilities in the State of Ohio by the Ohio Power Company'and Buckeye Power, Inc.
This is the Cardinal Plant located on the 0hio River at Brilliant, Ohio,'which presently consists of three approximately 615 megawatt generating units, one owned by Ohio Power Company and two-owned by Buckeye Power, Inc.
All units are operated by Cardinal Operating Company, which is jointly owned by Ohio Power Company (50%) and Buckeye Power, Inc. (50%).
Th'e principle contract between the parties is known as the " Station Agreement" which provides for the ownership responsibility at the plant and for the entitlements of power and energy from the plant.
It also provides for the operation and maintenance of the plant by Cardinal Operating Company.
A second principle agreement is j
the " Power Delivery Agreement" among Buckeye Power, Inc., Ohio Power Company, Cincinnati Gas & Electric Company, _ Columbus & Southern Ohio Power Company, Dayton Power and Light Company, Monongahela Power Company, and Toledo Edison Company.
This agreement provides for the delivery of Cardinal Station power first through the bulk transmission system of Ohio Power Company and then through the systems of the above-named companies throughout the State of Ohio to the cooperative membership delivery points of Buckeye Power, Inc.
The original' two units at the Cardinal Station site were completed in 1967
. and a contractual arrangement for Buckeye to purchase Unit No. 2 was closed in
-June of 1968.
Unit No. 3 vent into commercial operation in 1977.
i e
6
ATTACliMENT A
. Southern Engineering Company of' Georgia has been consulting engineer for Buck'aye Power, 'Inc and. responsible for the negotiations and centractual arrange-ments for_ this project since 1962s I have been involved since 1964 on behalf of
- Buckeye Power with primary responsibility for engineering and economic analyses of the positions of.the parties throughout.the negotiations of the contractual arranger,ents and with the continuing evaluation of feasibility (cost of power) as conditions changed to the final feasibility' study upon which was based the sale of bonds to finance ninety percent of the purchase price of Buckeye's fi.rst unit in 1968, In 1969 discussions began concerning Buckeye's additional unit (Cardinal Unit No. 3),
This required negotiation of an amended Station Agreement.
- Again, l
the engineering and economic analyses in the step-by-step negotiations and the continuing evaluation of economic feasibility were my responsibility.
Amendment No.1 to the Station, Agreement (dated October 1, 1973) has been executed and Cardinal Unit No. 3 is in commercial operation.
OGLETHORPE PO'JER CORPORATION
' 1974 to'Date Oglethorpe Power Corporation (OPC) of Atlanta, Georgia is a G&T Cooperative
. with. membership consisting of 39 rural electric cooperatives in the State of Georgia.
OPC is a party to an arrangement for the joint ownership and operation of generating and transmission facilities in the State of Georgia between the Geo.rgia Power Company. (GPC) and Oglethorpe Power Corporation (there are similar arrangements.between GPC and the Municipal Electric Authority of Georgia (MEAG) and also between GPC and the City of Dalton, Georgia (Dalton)).
The facilities involved include the Edwin I. ' Hatch Nuclear Plant, both units of which are now I
in commercial operation, the H. B. Wansley Coal Plant, both units of which are in.
7 I
ATTACHMENT A commercial operation.
The - ownership of Plants Hatch and Wansicy is 70% GPC, MEAG and Dalten combined, and 30" OPC. The generating units are operated and maintained by GPC.
The principle contracts between GPC and the other parties related to
^
Plant Hatch is the "Edwin I. Hatch Nuclear Plant Purchase and ownership Partici-pation Agreement".
Similar contracts are in effect for Plant Wansley.
OPC's agreements provide for the purchase by OPC of 30% undivided interest in each plant.
They also describe the ownership responsibilities of the parties.
Additional agreements, entitled " Operating Agreement" establish the operating cost responsi-bilities and power and energy _ entitlements of the parties and provides for the operation and maintenance of the plant by GPC on behalf of both parties.
An agreement entitled " Integrated Transmission System Agreement" between OPC and GPC (with similar agreements for MEAG and for Dalton) sets forth the owner-ship and investment responsibilities of the parties and provides for the use of the integrated transmission system by both GPC and OPC (also MEAG and Dalton).
The
" Integrated Transmission System Agreement" was arrived at to obtain for all parties the benefits of coordinated development and make it unnecessary for any party to construct duplicate transmission facilities.
In order to assume its responsibilities under the " Integrated Transmission System Agreement," OPC has purchased approximately one thousand miles of transmission line and associated substations from Georgia Power Company.
This arrangement between Georgia Power Company and Oglethorpe Power Corporation constitutes close coordination involving the sharing of both responsibilties and entitlements in a jointly-planned and jointly-owned integrated power system.
Southern Engineering Company of Georgia has been consulting engineer for Georgia Electric Membership Corporation, OPC's predecessor, for power supply matters for more than 20 years. We are also OPC's consulting engineer and are responsible for negotiations and contractual arrangements for this project.
I have been involved since the beginning of this project with primary responsibility 8
ATTACHMENT A for engineering and economic analyses of the negotiating positions.of the parties throughout the negotiations of the contractual arrangements and for the continuing evaluation of feasibility (cost of power).
Feasibility studies for this project required a proj ection of the GPC system cost with power generation costs cate-This was gorized as base load, intermediate load, peaking load, and reserve.
,. necessary because of the proposed unbalanced ownership of generating equipment by the parties.
OPC would own all base load equipment in the beginning.
I was involved in negotiations with GPC to develop a " Partial Requirements Rate" for filing with the Federal Power Commission under which OPC would purchase its remaining capacity and energy require =ents from GPC. My responsibility in these negotiations included proposing a rationale describing the cost responsi-bility and power scui energy entitlements of the parties in the combined systems.
This responsibility inclu'ded not only the engineering 'and economic analyses of the rationale but its technical correctness as well.
OLD DOMINION ELECTRIC COOPERATIVE, INC.
1972 to Date Old Dominion Electric Cooperative, Inc. of Richmond, Virginia is a generation and tranmsission cooperative with membership including all rural electric coopera-tives in the state of Virginia served by the Virginia Electric and Power Company plus those served by Delmarva Power and Light Company.
Old Dominion has been interested in developing generation and transmission capabilities for power supply purposes since the late 1940's.
Their latest effort began in 1972. Old Dominion is now negotiating with the Virginia Electric and Power Company con-cerning arrangements under which Old Dominion would own both generating and transmission facilities in a combined integrated system in the State of Virginia.
6 6
9
ATTACHMENT A-Southern Engineering has been the consulting engineer for the.Old Dominion 1 Electric Cooperative since th'e late 40's.-
I.have-been involved since 1972.
I Ean responsible for the -engineering input-to _ the negotiations and for the engin-eering and economic analyses necessary throughout the steps of the negotiations.
SEMINOLE' ELECTRIC COOPERATIVE, INC.
1973 to-Date The Seminole Electric Cooperative, Ihe. is a generation and transmission i
cooperative-with membership including eleven rural electric cooperatives in the j
State of Florida.
The " Seminole First-Project" is an arrangement for the joint ownership and operation of a generating facility in Florida among the. Florida Fower Corporation, Seminole Electric Cooperative, Inc., and various municipal
-electric systems.
The facility involved is the Crystal River Unit No. 3' Nuclear Generating Unit being constructed by Florida Power Corporation.
The Crystal River No. 3 Unit is a 825 megawatt unit, and Seminole's share of this first project will be 14.02 megawatts.
The " Crystal River Unit No. 3 Participation Agreement" was signed and executed by the participants on July 31, 1975.
Crystal
. River No. 3 is in commercial operation.
Seminole now has under construction two 600 MW coal-fired units at a site on the St. Johns River.
i Seminole is now negotiating with Florida Power and Light Company regarding
- participation (approximately 50 MW) in the Company's St. Lucie No. 2 Nuclear Unit.
tais unit is expected to go into commercial
- operation in the early 1980's and will have a planned capability of 801 ~ megawatts.
Southern Engineering Company of Georgia has been the consulting engineer for Seminole Electric Cooperative for a number of years and is responsible for the negotiation:of contractual arrangements involved in the projects described above.
c.-
I have been involved since_ the first project efforts began in 1973.
My j
l 10-t i
ATTACHMENT A~
~
responsibility has included not only the engineering and economic input to the negotiations, but also the preparation of projected feasibility studies (cost of power studies) testing changing conditions, and the final feasibility studies Lin support of financing.
SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION 1976-to Date South Mississippi Electric Power Assocation (SMEPA) of Hattiesburg, Mississippi is a generation and transmission cooperative with membership including most of the rural electric cooperatives (" Associations") in the state of Mississippi.
SMIPA is at present negotiating with Mississippi Power. & Light Company and Middle South Energy, Inc. with respect to a 107. participation in the Grand Gulf Nuclear Plant, being constructed by MP&L as agent for Middle South Energy, Inc.
Southern Engineering Company of Ceorgia has been engineering consultant to SMEPA since the beginning of.SMEPA back in the early 1950's; however, my responsibilities have been related to the. negotiations with Mississippi Power
~
and Light and the continuing test of economic feasibility with respect to the Grand Gulf participation.
e t
4 g
11
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
-)
HOUSTON LIGHTING & POWER
)
Docket Nos. 50-498A COMPANY, et al.
)
50-499A
)
'(South Texas Project, Units
)
No.:1 &.2)
)
2'
)
In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445A COMPANY, et al.
) 446A
)
(Comanche Peak Steam Electric
)
Station,-Units No. 1 & 2)
)
)
(Consolidated for Dis,covery)
CERTIFICATE OF SERVICE I hereby certify that a: copy of the foregoing " Updated Response of_ Tex-La Electric Cooperative of Texas, Inc., to First Set of Interrogatories and Requests for Production of Documents from Texas Utilities' Generating Company" has been served on each of the follow-ing persons by deposit in the United States Mail, first class postage prepaid, this lith day of March 1980.
Samuel J.
Chilk, Secretary Chase R.
Stephens, Secretary U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C.
20555 U.S. Nuclear Regulatory Commissi Washington, D.C.
20555 Marshall E. Miller, Esquire.
Michael'L. Glaser, Esquire Jerome Saltzman Sheldon J. Wolfe, Esquire' Chief, Antitrust and Indemnity Atomic Safety and Licensing Group Board Panel U.S. Nuclear Regulatory Commissi U.S. Nuclear' Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555-Alan S.
Rosenthal, Esquire Richard'S. Salzman, Esquire Michael C. Farrar, Esquire U.S. Nuclear Regulatory Commission Thomas S. Moore, Esquire Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel Jerome E.
Sharfman, Esquire U.S. Nuclear Regulatory Commissi U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
~4.
- - - ~
v Mr.
William C. Price David A. Dopsovic Central Power & Light Company Antitrust Division P.O. Box.2121 Department of Justice Corpus-Christi, Texas 78403~
Post Ottice-Bcx.14141 Washington, D.C.
20044
-Mr. G.K.
Spruce General Manager Roy P.
Lessey, Esquire City Public Service Board Michael Blume, Esquire P.O.
Box 1771 U.S.' Nuclear Regulatory Commissi San Antonio, Texas 78203 Washington, D.C.
20555 Fredric D. Chanania.
Jerry L. Harris, Esquire Office of the Executive Legal Director City Attorney U.S. Nuclear Regulatory Commission Richard C. Balough, Esquire
-Washington, D.C.
20555 Assistant City Attorney-City of Austin 1Mr. Perry G. Brittain P.O. Box 1088 President Austin, Texas 78767 Texas Utilities Generating Co.
2001 Bryan Tower Mr. Dan H. Davidson Dallas, Texas 75201 City Manager City of Austin Mr.
R.L. Hancock, Director P.O. Box 1088 City of Austin Electric Austin, Texas 78767 Utility Department P.O. Box 1088 Don R.
Butler, Esquire Austin, Texas 78767 1225 Southwest Tower Austin, Texas 78701 Mr. G.W. Oprea, Jr.
Executive Vice President Joseph Irion Worsham, Esquire Houston Lighting & Power Co.
Merlyn D.
Sampels, Esquire 1
P.O.
Box 1700 Spencer C. Relyea, Esquire Houston, Texas 77001 Worsham, Forsythe & Sampels 2001 Bryan Tower, Suite 2500 Jon C. Wood, Esquire Dallas, Texas 75201 W.-Roger Wilson, Esquire Matthews, Nowlin, MacFarlane Joseph Knotts, Esquire
& Barrett Nicholas S.
Reynolds, Esquire 1500 Alamo National Building Debevoise & Liberman San Antonio,. Texas 78205 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 David M.
Stahl, Esquire Isham, Lincoln and Beale Ronald Clark, Esquire 1050 17th Street, N.W.
Energy Section Washington, D.C.
20036 Antitrust Division Department of Justice Michael I. Miller, Esquire P.O.
Box 14141 James A. Carney, Esquire Washington, D.C.
20044 Sarah N. Welling, Esquire Isham, Lincoln and Beale One'First-National Plaza
. Chicago, Illinois 60603
.m
...,., +
r,
w w
J' !
fDouglas F.' John, Esquire Kevin B. Pratt, Esquire Akin, Gump,-Hauer & Feld.
Assistant. Attorney General 1333 Newz Hampshire Avenue, N.W.
P.O.
Box.12548 Capital. Station
. Suite.-400:
-Washington, D.C.
L L
. Morgan Hunter, Esquire' Robert C.-McDiarmid, Esquire l
'McGinnis, Lochridge & Kilgore Robert A. Jablon, Esquire L
900 Congress Avenue Spiegel & McDiarmid l
Austin,. Texas 78701 2600 Virginia Avenue, N.W.
Washington, D.C.
20037
'~
t Jay M. Galt, Esquire Looney, Nichols, Johnson.
W.N. Woolsey,- Esquire
& Hayes.
. Dyer and Redford 219 Couch ~ Drive 1030 Petroleum Tower Oklahoma City, Oklahoma 73101 Corpus Christi, Texas 78474 Knoland J.,Plucknett Robert M.
Rader, Esquire Executive Director, Committee-Conner, Moore & Corber on Power for the Southwest 1747 Pennsylvania Ave., N.W.
5541_ East-Skelly Drive Washington, D.C.
20006 Tulsa, Oklahoma 74135 Donald M.
Clements, Esquire Mr. W.S.-Robson Gulf States Utilities Company
-South Texas Electric Coopera-Post Office Box 2951 tive, Inc.
Beaumont, Texas 77704 '
. Route 6, Building 102 Victoria Regional Airport John W. Davidson, Es, quire Victoria, Texas 77901 Sawtelle, Goode, Davidson
& Tioilo R.
Gordon Gooch, Esquire 1100 San Antonio Savings John P. Mathis, Esquire Building ~
~
l Baker'and Botts San Antonio, Texas 78205
- 1701 Pennsylvania. Avenue, N.W.
. Washington, D.C.
20006 Mr. G. Holman King West Texas Utilities Co.
Robert Lowenstein, Esquire P.O.
Box 841 J.A. Bouknight, Jr., Esquire Abilene, Texas 79604 William J.
Franklin, Esquire Douglas'G. Green Susan B. Cyphert, Esquire Lowenstein, Newman,'Reis Department of Justice and:Axelrad Room 8308--Star Building 1025 Connecticut Avenue, N.W.
Washington, D.C.
20530 Washington,cD.C.
20036 E.W.
Barnett,. Esquire o
Charles G.-Thrash, Jr., Esquire p
/
['
/
.J.
Gregory Copeland, Esquire
'g 67,1//
//ev uf
~
Theodore'F. Weiss, Jr., Esquire William H.
Burchette BakerLand Botts 3000 One Shell Plaza-Attorney for Tex-La Electric Houston, Texas 77002 Cooperative of Texas, Inc.
a
,-,-nv+---
~
--~v
---w--
r---+-
- - e w 4+-##
-