ML19312D787

Second Set of Addl Answers to NRC 790115 Initial Interrogatories,Per ASLB 780621 Prehearing Conference Directive.Includes Info Re Stagg Sys Role in Wholesale Transactions & Economic Study of Generation.Affidavit Encl

ML19312D787
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	02/27/1980
From:	Franklin W BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19312D784	List: ML19312D783 ML19312D787 ML19312D791 ML19312D798
References
NUDOCS 8003250333
Download: ML19312D787 (5)

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UNITED' STATES-OF AMERICA

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NUCLEAR REGULATORY. COMMISSION BEFORE'THE ATOMIC SAFETY-AND-LICENSING BOARD

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-HOUSTON ~ LIGHTING-& POWER COMPANY- )' Docket Nos. 50-498A let al-.

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(South' Texas? Project,. Units l'

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- TEXAS UTILITIES GENERATING COMPANY -) Docket Nos. 50-445A

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.(Comanche Peak Steam Electric ).

Station, Units 1 and-2)- .

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HOUSTON LIGHTING & POWER COMPANY'S

=SECOND SET OF ADDITIONAL ANSWERS TO THE NRC STAFF'S INITIAL INTERROGATORIES TO HOUSTON LIGHTING & POWER COMPANY The NRC Staff (" Staff") served the Initial Interrogatories and'RequestsJfor Production of Documents Propounded to Houston Lighting & Power . Company (" Houston") and Texas Utilities Generating-Company;on January' 15, 1979. Houston filed its Objections and Answers on' February 120, 1979, and filed Additional Answers on May 24, 1979. Pursuant to the directive of the Board atLthe. June 21,.1978 Prehearing-Conference,=and pursuant ~to Instruction 10 of the-Staff's discovery requests, Houston.hereby supplementskits prior response.

iInterrogatory 5 (a) LList! separately, : the: names of all entities .which have l received: membership ini TIS and/or ERCOT since 1965 L (include (informalircquests).

((b): Give .the response -to each such request for membership in TIS and/or ERCOT. . . Explain in detail tho' bases for each such

responseRand

the;nameJor names.of the individual'or individuals

respondingjto such reque'st. (See

Instruction 8) .

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[(c)O Provide all5 documents which; relate to this -interrogatory.

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Supplementary Answer to Interrogatory No. 5

An application by the Texas Municipal-Power Agency to become-

a: member of TIS was apprezed by the TIS Administrative Committee-

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on January 30, 1980. The-TIS Agreement has1not yet been formally amended: to ~ reflect this': approval.- The Public Utilities Board of the City of Brownsville, Texas was~ admitted to TIS during 1979. Supplementary. documents responsive to the interrogatory are attached hereto as " Attachment A."

' Interrogatory No. 6 (a)

Describe in detail all known instances since 1961'in which TU/HL&P wholesale customer (s) and/or other-members of ERCOT considered interconnecting with or dealing in any way with. inter-

-state electric utility-companies.

. Supplementary Answer to Interrogatory No. 6(a)

-The December 17, 1979 study entitled " Economic Evaluation

-of Alternative Generation Expansion Plans for Electric Reliability Council of-Texas and Southwest Power Pool" performed for Houston by Stagg Systems, Inc., and the October 31, 1979 order of

' Administrative Law Judge Daniel M. Head in the proceeding Central

' Power & Light Company, FERC Docket No. EL79-8, supplement Houston'.s prior response. Houston believes that the staff has already been furnished a copy of-the Stagg' study, and a copy of

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Judge Head's order is attached hereto as " Attachment-B."  :

Interrogatory No. 6(c)

Name.those persons'having personal knowledge of any-dis- l cussions, negotiations, or studies involving,the possibility;of j

Ltransactions between TU/HL&P wholesale customers and/or other I

membersLof'ERCOTLwith interstato electric

utility' entities. l

. ~ Supplementary Answer to' Interrogatory No. 6(c)

Glenn-W. Stagg;has personal-knowledge of-the December 17, 31979 study: performedEfor . Houston Stagg Systems, Inc.

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Interrogatory No. 25(a)

EHL&P: state'the current capital cost: projections in Jdollars per kilowatt and the projected ~~ annual cash flow to

' meetithe projected construction schedule for the- South Texas f Project.,

Supplementary Answer to Interrogatory No. 25(a)

LThe:capitalLcost projection _is $1,080 per kilowatt.

-Houston's' forecast ofE: expenditures for the South Texas Project

'iscas follows:

HOUSTON LIGHTING &-POWER COMPANY

-SOUTH TEXAS PROJECT FORECAST OF EXPENDITURES (Dollars in Thousands)

Year' Amounts

. Prior to 1979 $224,238 1979 135,939 1980. 113,293

-1981 91,146 1982- 96,336 19831 86,691 1984 54,288 1985 27,987

.1986' 1,682 Total Project _

$831,600 (Houston's Portion Only)

Interrogatory No. 42 (a)

Provide' a computer printout, including input data and area

interchange' summaries,fof the latest normal peak load' system condition load flows for the = time' that the South- Texas Units or -

~ Comanche Peak Units willLfirst be in commercial operation. If.

~ the actual' system ' configurations! have ' not been determined as

yet, and several system configurations are being considered, ~

providcJ the

• computer printouts for each configuration and describe the considerations or. factors.which will determine the final 0 - configuration.

JSupplementary Answer to Interrogatory No. 42 (a)

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. Houston has updated its11oad. flow studies. These updated-Est6 dies :are available Jfor -the ~ Staf f's review at Houston's office

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, Respectfully submitted 1

William .J.. F,(anklin-

.. Attorney'for Houston Lighting o _

&: Power Company-

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^OFJCOUNSEL:

I' ' BAKER &.BOTTS -

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J3000 One Shell. Plaza. '

r' . Houston, Texas l.77002'-

LOWENSTEIN, NEWMAN,REIS,.

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AXELRAD'&" TOLL.

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--1025' Connecticut Avenuei-N.W.

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.. Washing t on , ; D . C . 20036

' Dated: 7 February 27',.1980 -

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-STATE 0F.: TEXAS ~ S-

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. COUNTY,OF HARRIS. S

~BEFORE ME,.THE UNDERSIGNED AUTHORITY, on this day personally appeared D. E. SIMMONS, who upon his oath stated t

that he has answered the foregoing Houston Lighting & Power Company,'s Second Set of Additional Answers to the NRC Staff's Initial' Interrogatories to Houston Lighting-& Power Company.

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. .in his~ capacity as Vice President-Engineering and Transmission

- and Distribution for. Houston Lighting & Power Company, and all statements contained therein are true and correct.

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D. E. SIMMONS SUBSCRIBED AND SWORN TO BEFORE ME by the said D. E. Simmons, on this c246 day of. February, 1980.

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" NOTARY PUBLIC in and for Harris County, T E X.A S ,

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