ML19312D791

Supplemental Answers to Central Power & Light 780727 First Interrogatories,Per ASLB 780621 Prehearing Conference Directive.Includes Info Re Public Utils Board of City of Brownsville,Tx Interest in Purchasing Base Load.W/Affidavit

ML19312D791
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:	CENTRAL POWER & LIGHT CO.
Shared Package
ML19312D784	List: ML19312D783 ML19312D787 ML19312D791 ML19312D798
References
NUDOCS 8003250339
Download: ML19312D791 (4)

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UNITED S"s'ES OF AMERICA

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' NUCLEAR REL.. .ATORY' COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'In the Matter'of )

)

HOUSTON LIGHTING & POWER COMPANY  ? Docket Nos. 50-498A et -- al . ) 50-499A

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(South Texas Project, Units 1 )

, and 2) )

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

) 50-446A (Comanche Peak Steam Electric )

Station, Units 1 and 2) )

- SUPPLEMENTAL ANSWERS OF HOUSTON

~ LIGHTING & POWER COMPANY TO CENTRAL POWER AND LIGHT COMPANY 'S FIRST INTERROGATORIES

-Central Power and Light - Company ("CP&L") , a wholly-owned subsidiary of Central-and Southwest Corporation ("CSW") , served ,

its Interrogatories to Houston. Lighting and Power Company T

(" Houston") on July 27, 1978. " Houston filed its Answer on

- Augus t:- 31, 1978. Pursuant to the directive of the Board at the June 21, 1978 Prehearing Conference, Houston hereby supplements its prior-responses.

Interrogatory No. 2 Describe every/ rate schedule under.wh'ich HL&P has extended

or offered'.cleetric3 service'to industrial customers since January 1, 1968.

Supplementary-Answer to Interrogatory No. 2

Copies ' of a recent rate order' of the Texas Public Utilities Commission ("PUC")fand the proposed Tariff filed in response

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-a thereto are-attached as " Attachment-A."

~ Interrogatory No. 8 (a) Identify every electric utility which has, since

' January 1, 1968, inquired whether HL&P would-supply such utility

with-all or part of its requirements of electricity.

'(b)' Describe HL&P's response to each inquiry identified in'your answer:to subpart (a) of this Interrogatory.

Supplementary Answer to Interrogatory No. 8

On May 21, 1979, the Public Utilities Board of Brownsville, Texas -(" PUB")- expressed an interect in purchasing " base load" capacity from Houston. Copies of the PUB's letter and of Houston's response are attached hereto as " Attachment B."

PUB has recently requested that the participants in the

. South-Texas Project sell to PUB up to fifty megawatts in that project. . 'A copy of PUB's letter communicating its request is attached hereto as " Attachment C."

Interrogatory No. 9 .

Describe each study performed in whole or in part since

. January 1, 1968 (including studies currently in progress) which analyzes-the effects, if any, on the HL&P system if HL&P's facilities were to be used for the transmission of electricity in interstate commerce.

-Supplementary Answer to Interrogatory No. 9 The. December 17, 1979 study entitled " Economic Evaluation of Alternative Generation Expansion Plans for Electric Relia-bility 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 pro-

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.ceeding' Central" Power & Light Company, FERC Docket No. EL79-8,  !

supplement Houston's prior response. Houston believes that CSW has been furnished copies of both documents.

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. . . - Interrogatory No. 24'

State (a) the amount of the fuel cost adjustment to your industrial customers for each month in 1978, and (b) whether

' the!. fuel cost ~ adjustment to your-industrial customers for such

- period differed from the fuel cost adjustment applied to your other classes of' customers.

- Supplementary Answer to Interrogatory No. 24 Industrial (Transmission) Others

-(cents per KWH) ~ (cents per KWH)

October 1978 .6545 .7023 November 1978 .7031 .7544 December 1978 Old Rates .5733 .6151 New Rates *- 1.2722 1.3377

• New rates effective December 7, 1978, contained no base fuel costs while.the old rates contained a base fuel cost of approximately 0.7386 cents per KWH.

Respectfully submitted e

William J. tranklin Attorney for Houston Lighting

& Power' Company OF. COUNSEL:'

BAKER AND BOTTS 3000 One Shell Plaza Houston,iTexas .77002

_LOWENSTEIN,- NEWMAN, REIS, AXELRAD & TOLL.

1025 Connecticut. Avenue, N.W.

Washington, D.C. 20036- -

Datedi' February' 27,.1980 s

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STATE.OF TEXAS _ 'S S '

' COUNTY OF' HARRIS S

BEFORE-ME,.THE. UNDERSIGNED. AUTHORITY, on this day

, personally appeared ~D. E. SIMMONS, who upon his oath stated tilat he has answered the foregoing Supplemental Answers of Houston Lighting & Power Company.to Central Power and Light Company's First: Interrogatories in his capacity as Vice

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President-Engineering and Transmission and Distribution for

Houston-Lighting & Power Company, and all statements contained

, therein are true and-correct.

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J' D.T. SIMMONS SUBSCRIBED AND SWORN TO BEFORE ME by the said D. E. Simmons, on this .24 95' day of- February, 1980.

Mb WOTARY PUBLIC in and for

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Harris County, T E X A'S z s}.

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