ML19312D791
| 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: |
| References | |
| NUDOCS 8003250339 | |
| Download: ML19312D791 (4) | |
Text
..
t ti.g
=,x Q)?
UNITED S"s'ES OF AMERICA
' 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
)
(South Texas Project, Units 1
)
and 2)
)
)
)
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
-8'003250337 a-r 3
'g-
-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-
.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.
u
p
... ~
- 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
9
j-- <
}
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
~
President-Engineering and Transmission and Distribution for Houston-Lighting & Power Company, and all statements contained therein are true and-correct.
_=
D.T. SIMMONS J'
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 Harris County, T E X A'S s}.
z M
-1 s
r
- .