ML19312D787
| 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: |
| References | |
| NUDOCS 8003250333 | |
| Download: ML19312D787 (5) | |
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UNITED' STATES-OF AMERICA NUCLEAR REGULATORY. COMMISSION BEFORE'THE ATOMIC SAFETY-AND-LICENSING BOARD tin the-Matterfof.
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-HOUSTON ~ LIGHTING-& POWER COMPANY-
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Docket Nos. 50-498A let al-.
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50-499A
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(South' Texas? Project,. Units l'
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and-2)
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- TEXAS UTILITIES GENERATING COMPANY
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Docket Nos. 50-445A
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50-446A
.(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).
, m 8003.250333-
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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
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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 Judge Head's order is attached hereto as " Attachment-B."
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Interrogatory No. 6(c)
Name.those persons'having personal knowledge of any-dis-cussions, negotiations, or studies involving,the possibility;of j
Ltransactions between TU/HL&P wholesale customers and/or other
- membersLof'ERCOTLwith interstato electric
- utility' entities.
~ 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)
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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
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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:
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' BAKER &.BOTTS J3000 One Shell. Plaza.
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. Houston, Texas l.77002'-
LOWENSTEIN, NEWMAN,REIS,.
AXELRAD'&" TOLL.
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--1025' Connecticut Avenuei-N.W.
.. Washing t on, ; D. C.
20036
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' Dated: 7 February 27',.1980 v
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-STATE 0F.: TEXAS ~
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. COUNTY,OF HARRIS.
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~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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