ML19322E725
| ML19322E725 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak, 05000598  |
| Issue date: | 02/22/1980 |
| From: | Scarth E AFFILIATION NOT ASSIGNED, Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML19322E710 | List: |
| References | |
| NUDOCS 8004020175 | |
| Download: ML19322E725 (9) | |
Text
._______
rwO s
Certification of Questions from the Oral Deposition of E.
Dale Scarth February 12, 1980 l
l 8004020l7 5
1 1
UNITED STATES OF AMERICA 1
2 NUCLEAR REGULATORY COMMISSION 3
4 BEFORE TIIE ATOMIC SAFETY AND LICENSING FOA9D 5
6 In the Matter of
)
7 IlOUSTON LIG!! TING & POWER
(
NRC Docket Mos.
8 COMPANY, et al
)
50-498A and 50-499A y
f 9
(South Texas' Project,
(
10 Unit Mos. I and 2)
)
11 12 d(
13 14 In the Matter of
)
15 TEXAS UTILITIES GENERATIMG
(
16 COMPANY, et al
)
NRC Docket Hos.
17 (Cananche Peak Steam
(
50-445A and 50-4a4A 18 Electric Station,
)
19 Units 1 and 2)
(
20 21 (Consolidated for Discovery) 4 22 23 CERTIFICATIOM OP OUEST10MS 24 FROM T!!E ORhl DEPOSITION OF E.
DALE SCARTi!
25 L
2 1
Questions by Mr. Blume:
2 9
I see.
Mr. Scarth, are you aware of any load 3
flow or stability studies run by either University or any 4
other TU consultants or any employees of the Texas 5
Utilities Company Systen which are directed toward 6
evaluating the effects of synchronously interconnecting 7
ERCOT with the Southwest Power Pool?
8 (idh e r eupon, there was a 9
(discussion off the record.
J 10 MR. FNOTTS:
Mr. Scarth, to the 11 extent that your answer would necessarily embrace 12 settlement discussions which may be ongoing or may have
{
13 been ongoing i' some stage of these proceedings or 14 related proceedings, I'll direct you not to answer.
But 15 to the extent you can answer without impinging on the 16 settlement discussions, go right ahead.
17 THE WITNESS:
There is a study 18 y
underway jointly by a planning task force, the Southwest 19 PSwer Pool, and the planning subcommittee of ERCOT, in 20 connection with the FERC hearing that will address the 21 synchror.o..m operation of ERCOT and the Southwest Power 22 Pool, the interconnection of ERccT and Southwest Pouer 23 Pool at DC, and the operation of ERCOT and Southwest 24 Power Pool without any interconnection for the future.
25 O.
(By Mr. Blume):
Thank you, Mr. Scarth.
I
3 i
1 don't mean to intrude on any settlement discussions or
(
2 the content of any such discussions.
What I'n interested 3
in is whether TU or any of its consultants have done any 4
load flow or stability stu91es which evaluate the effects 5
of interconnecting synchronously ERCOT and the Southwest 6
Power Pool.
7 A.
All right.
Now, we have made many studies in S
the past that exanine the operation of ERCOT and how it 9
is doing, th'e reliability of it.
We have -- there have o
10 been studies that have looked at operating ERCOT and the 11 Southwest Power Pool synchronously over the last 15 or 20 12 years they have gone -- been done with fairly --
- Well,
(
13 every three or four years it seems like sone question 14 would cone up about it.
15 I specifically remember, I 16 guess in about '68 or '9 when the Federal Power 17 Conmission recommended that it be done, and a study was 38 done by Houston and Gulf States and Texas Power & Light.
19 That sort of thing has been done repeatedly.
And the 20 opinions that we have forned based on those studies and 21 based on what was done, of course, in more detail as far 22 as ERCOT planning was concerned, because once we decided 23 there wasn't any advantage to us to interconnect with 24 Southwest Power Pool, well, then we did the more specific 25 development which incorporated a whole lot nore studies
f i
4 1
i 1
l 1
on ERCOT as it has been operated.
But those have besn 2
ongoing for nany years.
l 3
0 Okay.
I'n sure I wasn't clear enough.
I.et me 4
try again.
Again I don't want to intrude on any
- the 5
substance of any discussions you have had with any other 6
party to settle with this proceeding.
We are certainly 7
not going to try to frustrate those efforts, but what I'm 8
interested in knowing is whether TU or any of its 9
consultants have run any stability or load flow studies 10 evaluating the effects on the TU System of synchronously 11 interconnecting TIS with Southwest Power Pool.
12 A.
Do you have any period of time that you are
(
13 asking that question over?
14 0
Are you aware of any?
15 A.
I guess the answer to that question is "t!o, 16 I'm not aware of any."
There may have been some that 17 were done in connection with the '59 or some of those la studies back there.
I looked at the results of that n
19 report.
I was not involved in actually making any 20 studies that were done at that point, so I think the 21 answer to that question is "I'm not aware of any."
22 O.
Okay.
23 A.
Other than what may be done under settlement.
24 0
Under '-
25 A.
Under the settlement discussions.
Other than
f.
r, I
what may be privileged information from this.
(.
2 0
Well, are you saying "No, I'm not aware of any,"
3 or "No, there aren't any stability studies that have been 4
done which weren't in connection with settlement"?
5 (Mhereupon, there was a 6
(discussion of f the record.
7 MR. KNOTTS:
Let's go off the 8
record for a second.
9 (Whereupon, there was a e
10 (discussion off the record.
11 Q.
(af Mr. Blum e) :
So, Mr. Scarth, is it your 12 testimony that no stability or load flow studies have
{
13 been run by TU or its consultants either inside or 14 outside the ambit of settlement?
15 MR. KNOTTS:
Okay.
For the 16 record I guess I have to object to the form of that 17 question and direct the witness not to answer to the 18 extent that he would necessarily have to reveal i
19 information regarding settlement discussions in this and 20 related proceedings.
21 MR. BLUME:
Okay.
Staff's 22 position is that the board's order on the settlement 23 privilege is designed to protect discussions on 24 settlement between the parties to tnis proceeding and not 25 to protect technical studies which may somehow l
G 6
l 1
tangentially be the subject of settlement talks.
2 MR. KNOTTS:
Just for l
3 clarification would the staff's position be different if i
4 the hypothetical studies that we are discussing were not l
5 tangential?
6 tm. BLUME:
Tangential is a 7
gratuitous word.
It's not the studies the board sought 8
to protect.
It's the content and the substance of the 9
discussions between the parties to settle this proceeding.
10 And I think that we will request that this request be 11 certified to the board.
12 MR. DOPSOVIC:
The department
(
13 also concurs in the staff's request and logic of its 14 arguments.
15 (idh e r eupon, there was a 16 (discussion off the record.
17 MR. BLUME:
Just one core 18 addition, and that is -- the question to start with in 9
19 whether any study has even been done, e.nd, as I 20 understand it, the instruction is the same on that 21 question as to the results of such studies; in that 22 correct, Mr. Knotts?
23 MR. KNOTTS:
Mr. Scarth has 24 answered the question outside the context of settlement 25 discussions, and his answer, as I understand it, is that
I there have not been any studies during his period.
2 T!!C WITNESS:
That I was aware 3
of.
4 MR. KNOTTS:
That he was aware 5
of outside the context of settlement discussions, and he 6
is on the horns of a dilemma as to how he can answer a 7
question with regard to studies in the context of 8
settlement discussions without revealing whether or not 9
there are settlement discussions; if so, with whom.
10 MR. BLUME:
Okay.
Thank you.
11 MR. KNOTTS:
And the 12 assumptions that might be going into studies.
{
13 14 15 16 17 18 1
19 20 21 22 23 24
(..
25
^
l....
l l
1 THE STATE OF TEXAS
}
2 COUNTY OF DALLAS
)
3 I, JAY HARPER, Certified 4
Shorthand Reporter in and for the State of Texas, do 5
hereby certify that, pursuant to agreement of counsel, 6
there came before me on the 12th day of February, A.
D.
7 1930, at 9:27 o' clock A.
M.,
the following named person, 8
to-wit:
E. DALE SCARTH, who was by me duly sworn to 9
testify to the truth and nothing but the truth of his 10 knowledge touching and concerning the matters in 11 controversy in this cause, that he was thereupon 12 carefully exanined upon his oath and his examination
(
13 reduced to typewriting under my supervision; thnt the 14 following execrpt is a true record of the testimony given 15 by the witness.
16 IN WITNESS HHEREOF I have 17 hereunto set my hand and af fixed my Notarial seal on this 18 the 12th day of February, A.
D.
1980.
4 19 20 21 22 23 JAY HARPER 24 Notary Public in and for 25 Bexar County, Texas