ML19329B246
| ML19329B246 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 08/26/1974 |
| From: | Goldberg R CLEVELAND, OH, GOLDBERG, FIELDMAN & HJELMFELT |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19329B247 | List: |
| References | |
| NUDOCS 8001310593 | |
| Download: ML19329B246 (25) | |
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G UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
The Toledo Edison Compe- ) Docket No. 50-346A The Cleveland Electric In .ninating )
Company )
(Davis-Besse Nuclear Power Station) )
)
The Cleveland Electric Illuminating ) Docket Nos. 50-440A Company, et al. ) and 50-441A (Perry Nuclear Power Plant, Units )
l and 2)' )
FIRST REQUEST OF THE CITY OF CLEVELAND FOR THE PRODUCTION OF DOCUMENTS BY APPLICANTS, THE TOLEDO EDISON COMPANY, PENNSYLVANIA POWER COMPANY, OHIO EDISON COMPANY ;
AND DUQUESNE LIGHT COMPANY :
Pursuant to 10 C. F. R. , Seetions 2. 740b and 2. 741, City of Cleveland requests each of the Applicants, The Toledo Edison Company, l
Pennsylvania Power Company, Ohio Edison Company and Duquesne Light l Company, to produce the documents requested herein.
The documents requested hereby are necessary in order for the City of Cleveland to prepare for the antitrust hearing ordered to be held in the Perry and Davis-Besse proceedings. The document request has i
been framed in an attempt to minimize the necessity for later discovery; I l
howeve_, City of Cleveland reserves the right to submit additional dis- l covery requests including interrogatories and depositions.
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8001310S D
It is requested that any documents within the categories in the attached schedule withheld by reason of any assertion of privilege be identified individually by listing the person (s) preparing, sending, or receiving the document withheld, the subject and date thereof, and a brief statement of the basis for asserting privilege as to each such document.
Except as otherwise stated it is requested that documents received, prepared, mailed, or obtained after January 1,1964 be produced.
Schedule A. Definitions
- 1. " Company" means each and any of the Applicants, their subsidiaries or affiliates, predecessor companies and any entities pro- 1 1
viding electric services at wholesale or retail, the properties or assets ,
l of which have been acquired by Applicants.
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- 2. " Documents" means all writings and records of every type '
i in the possession, control or custody of the Company, its dieectors, I officers, employees or agents, including but not limited to memoranda, I
correspondence, reports, surveys, tabulations, charts, books, pamphlets, !
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photographs, maps, bulletins, minutes, notes, diaries, log sheets, l I
ledgers, transcripts, microfilm, computer printouts, vouchers, account-ing statements, engineering diagrams ("one-line" diagrams), mechanical l
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and electrical recordings, telephone and telegraphic communications, speeches, testimony and all other records, written, electrical, mechan-ical or otherwise.
" Documents" shall also mean copies of documents, even though the originals thereof are not in the possession, custody or control of the Company, and every copy of a document which contains handwritten or other notations or which otherwise does not duplicate the original or any other copy.
- 3. " Electric Utility" means a private corporation, rural electric cooperative, municipality, or any political subdivision, agency or instru-mentality of the Federal or any state or municipal government which owns or controls, or proposes to own or control, facilities for the generation, -
transmission or distribution of electric power and energy.
- 4. " Coordination" and " coordinating" shall include but are not limited to, reserve sharing, coordinated development, economic dispatch or economy interchange, and pooling of load growth for joint or staggered additions of generating or transmission facilities.
" Coordination" and " coordinating" shall also mean joint ventures or.the sharing of participation in the ownership, operation or output of generating facilities and the sharing of ownership, construction or use of transmission facilities.
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- 5. " Competition" includes actual, estimated or possible effects of any action taken by, planned or considered by Company on any other electric utility company relating to: actual, potential or possible sales of electric power; gain or loss of customers; rates and rate changes for each class of business; to profits; ability to secure funds; quality of service; market share by class of customer and by geographical region; cost of generation, transmission and distribution; additional supply of electric power of any sort; reliability of electric service. " Competition" includes also actual, possible, or contemplated actions by any electric utility company relating to the areas specified above o 1 Company.
B. Documents No Longer in Company's Pos s ession, Custody or Control If any document described in this schedule was, but is no longer 4 in the Company's possession, or subject to the Company's control, or in ,
exi'stence, state whether: (a) it is missing or lost, (b) it has been de-stroyed,-(c) it has been transferred, voluntarily or involuntarily, to others, or (d) it has been disposed of otherwise. In each instance, explain the circumstances surrounding such disposition and identify the
. person (s) direc.ing or authorizing same, and the date(s) thereof. Identify I
each such document by listing its author and addressee, type (e. g. , letter, 1 memorandum,- telegram, chart, photograph, etc. ), date, subject matter, l
present location (s) and c.ustodian(s), if the document (or copies) are still l
in existence.
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C. Documents Requested
- 1. Documents showing the Company's corporate organization for each year from January 1,1960 to date, including:
(a-) Names of departments, divisions and cubunits and dates of their organization and reorganization; (b) Names of all directors, corporate officers, department or division managers and the dates of their service in each office held (indicate date of election or appointment, if prior to January 1,1960) for each individual serving in such capacity as of that date; (c) Function and responsibilities of each officer, manager and department or division listed in (a) and (b) above and the dates of any changes therein; (d) Occupations of all directors and/or the names and addresses of all other businesses with which they serve as directors or officers; (e) Name or identification, period of existence, function of, and persons comprising each committee reporting to company' officers or the Board of Directors on a regular or ad hoc basis (chart (s), tabulations or lists setting forth the above information and verified by a company l
officer may be furnished in lieu of the foregoing docu-r l ments);
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d (f) Names and job titles of all persons assigned to committees of CAPCO and a list of all CAPCO committees; (g) Articles of Incorporation, by-laws and amendments thereto.
- 2. Documents, including minutes of meetings of the Board of Directors and the executive committee of the Company, documents prepared in advance of meetings (e. g. , agenda, memoranda in summary or critique of plans, costs, proposals or status of negotiations), and letters and memoranda to or from Company officers relating to:
(a) Competition at wholesale; (b) Acquisitions by Company of electric utility properties
- and proposals for such acquisitions or invitations to purchase electric utility properties; (c) Acquisitions of large groups of customers of another electric utility; (d) Legislation and constitutional revision affecting the ability of electric utilities to own, finance, and construct facili-ties and to sell electricity; (e) Litigation, actual and considered, before courts or agencies in opposition to the construction of competing generation or transmission facilities.
- 3. - Any narrative history (or histories) of the Company.
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- Any Property employed in generation, transmission and distribution of electricity.
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- 4. Documents relating to the following:
(a) New electrical loads, area growth or development and locations available for sites for commercial or industrial development in areas in which such electrical loads might be served by electric utilities other than the Company; (b) h)olicies or practices, understandings or arrangements with other electric utilities as to allocation of wholesale or retail service arc as; (c) Inquiries, invitations, negotiations, evaluations and pro-posals for the acquisition of electric power facilities of municipalities, electric cooperatives or other electric utilities, including:
(i) CV.ers to serve at wholesale; (ii) Communications to or about elected officials, councils and boards; (iii) Sponsorship, support or opposition by the Company of activities sponsored by citizen or taxpayer com-mittees, community advisory councils, or the like.
- 5. Correspondence between the Company and Edison Electric Institute or any committee thereof, the National Association of Electric Com-panies, and any electric utilities; and documents referring to these entities relating to:
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(a) System construction, financing, ownership, operation of electric generation, transmission or distribution
. I facilities'by any municipal and/or electric cooperative j utility, including acquisitions of any such utility by the !
Company, or competition between any such utility and the Company; (b) Wholesale power supply to municipal and cooperative utilities; (c) Coordination, interconnection or pooling arrangements with municipal and cooperative systems; (d) Wholesale or retail territorial or customer allocations.
- 6. Documents pertaining to the following subjects located in the files of those individuals who by job or title are now or have been since January 1,1960 responsible for, prepared analyses of or forecast the effects of the following subjects:
(a) Long-term competitive aspects of the Company's rela-tionship with other electric utilities serving or able to serve at wholesale or retail in areas overlapping or in close proximity to the Company's service area; (b) Interconnection arrangements with other electric utilities; (c) Coordinated system operation, generation and trans-mission facilities expansion, and pooling arrangements involving other electric utilities.
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- 7. Documents referring or relating to c.mmunications between the Company and other applicants and members of CAPCO and among Company personnel in connection with CAPCO:
(a) Its formulation and the evaluation of any advantages or disadvantages thereof; (b) Participation by third parties and limitations thereon; i
(c) Documents relating to the National Electric Reliability Counbil, ECAR, NAPSIC (Northeast region), their formation and activities and Company's participation therein, including but not limited to any docum ts pertaining to the decisions setting qualifications for membership and full participation.
- 8. Documents referring or relating to the formation df a holding Com-pany to become the parent company of some or all of Applicants.
- 9. All agreements, modifications or supplements thereto executed or under consideration relating to the organization and/or operation of-CAPCO.
l 10.- Any contract for the sale or exchange of electric power between ,
Company and any other electric utility and a copy of any power l
pooling arrangement under consideration but not yet entered into.
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- 11. Documents describing the economic condition of the area served i by Company or projections of future economic conditions.
- 12. Documents including minutes of meetings of the Board of Directors and the executive committee of the Company, documents prepared in advance of meetings (e. g. , agenda, memoranda in summary or critique of plan-, cost, proposals, or status of negotiations), and letters and memoranda to or from Company officers relating to:
(a) Interconnection plans, proposals or agreements with other electric utilities; (b) Expansion'of, or additions to, generating capacity or transmission systemc to be (1) owned and utilized solely by the Company or (2) shared on any basis with one or more electric utilities.
- 13. Minutes of meetings and reports of each committee established under pooling or coordination agreements to which Company is a
'- party, those of each subcommittee or task force thereof, and documents relating thereto prepared or circulated within the Com-
.. pany including committees established pursuant to the CAPCO Memorandum of Understanding and the CAPCO Administrative ,
Agreement dated September 14, 1967.
- 14. Documents relating to the following:
(a) Studies of joint ownership or other participation con-sidered, -proposed or agreed upon betwesn the Company and other electric utilities, especially other members of CAPCO, with respect to nuclear, fossil-fuel or
. hydroelectric generating facilities and transmission facilities, and the guarantee of the obligations of Quarto Mining Company; (b) Present and future planned interconnections with other electric utilities, and their proposed capacity and status (tentative or assured);
(c) Studies or analyses of full generation and/or transmission integration or coordination between Company and any other electric utility; (d) The Company's line extension policy, including any modi-fications or interpretations thereof; (e) Reliability data for each generating unit, including forced and planned outages, number of hours down-time, number of outages, reason for down-time, nature of forced caage rate and calculation thereof, and number of hours operated 1
during the past year; (f) Reliability data for transmission lines, including outages per 100 miles per year for each of the various voltage classifications of lines, reasons for outages, and maxi-mum single-occurrence outage time, in hours, during 1
the past year; i i
(g) The outage time in 1973 per customer pe'. year in each of Company's districts and the number of outages per customer per year (in lieu of documents, a verified summary of such information may be supplied);
(h) Financing:
(i) Methods and mix; (ii) Cost of new capital; (iii) Cost of existing capital; (iv) Terms and condnions associated with capital -
(1) restricted funds and payments thereto (2) interest and debt service coverage (3) accumulative nature of preferred dividends; (v) Schedule of projected payments on debt (principal and interest payments);
(vi) Plans for future financing through December 31, 1979; (i) Complete description of the method used in determining desired levels of spinning and standby reserves based on probability and statistics including a copy of the most recent study relating to consideration of expansion plans.
- 15. Names of all engineers retained by the Company for generation and transmission services, design, studies, consultation and expert e- , ee*
s s tes timony. (In lieu of the forege' , a verified list containing the 4
information would be acceptab:
- 16. One small scale and one large scale copy of the most recent geo-graphic one-line diagram or map of the Company's electric genera-tion and bulk transmission system anel points of interconnection with other electric utilities indicating transmissions or subtransmission of 23kv and above, delivery points and supply voltage for municipali-ties and cooperatives; further, large scale maps of CAPCO and the area covered by any pooling agreements not exclusively limited to CAPCO.
- 17. The most recent electrical one-line diagrams showing the genera-tion and transmission systems corresponding to the diagrams requested in Request No. 16.
- 18. Maps or diagrams for each planning period or year through 1985 corresponding to those requested in Request Nos. 16 and 17.
- 19. Yearly peak flow diagrams through 1985 for Company's system, and for such larger bulk power supply system areas as may be studied by any power planning or operating groups in which Company partici-pates by furnishing personnel, data or otherwise.
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20.- The operating manuals or equivalent documents for CAPCO. ;
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- 21. Each press release or article containing data supplied by the Company, l or any internal document; describing the Company's bulk power N
- supply control center, or the major features thereof, such as equip-ment for load-frequency control, economic dispatch, security moni-toring, systems diagram board, remote supervisory equipment, information brought in to the control center from remote points, and the like.
- 22. . Documents relating to pooling agreements or interchange agreements in which the Company is a participant, directly or indirectly, which show:
(a) The method (s) used to interpret and determine any installed, spinning or operating reserve requirement (s) under the terms of such agreements; (b) The method (s) and bases whereby payments are made, receipts disbursed and the manner in which funds flow among the participants in determining any settlement of balances for such reserve obligations.
- 23. Reports and analyses (excluding load fic- diagrams not a part of any such report or analyses except as requested in (c) below) pertaining to:
(a) Joint transmission studies with the other Applicants, or any of them; (b) Joint transmission studies with any other electric util-ities;
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1 (c) Company transmission; in addition, all transmission load flow studies (plotted on a system one-line diagram of 100kv and above) for Company's complete system relating to planned bulk power additions for the period 1960-1985; (d) Comparative or alternative programs of generation and transmission expansion for Company, CAPCO, any other coordinating group in which Company participates, and letters or memoranda pertaining thereto; (e) Maximum uncommitted line capacity in Mva available for wheeling over individual transmission line sections be-tween present and future substations.
- 24. Documents containing or pertaining to capital and operation and main-tenance cost estimating factors utilized by the Company for:
(a) Transmission facilities (by varying voltages and range of capacities for each voltage) per mile or per hundred miles; (b) Ancillary substation facilities (by major cost components) and right-of-way; (c) Generation (by types) and ancillary facilities (provid,e, ,
breakdown by major components for both generation and ancillary facilities);
(d) Escalation factors relating to (a), (b), and (c) of this partgraph, and for fossil fuel, nuclear fuel and other s
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expenses, including but not limited to labor and adminis-trative and general expenses which Company projects or would project through 1983; (e) Depreciation factors, including method, term, and rate of depreciation; (f) Tax factors, including incremental income tax rate,
, property tax rate and amount for each generating unit and transmission line at substations, and other taxes.
- 25. Documents indicating:
(a) The most recent nuclear unit cost estimates, in accordance with the FPC Uniform System of Accounts, showing separately the rate of return used; (b) The total demand and energy cost of the nuclear unit as of the first year of operation showing as a distinct factor escalation percentages adopted for cost projec-tion purposes through 1985.
- 26. Documents regarding:
(a) Cost studies of nuclear vs fossil-fueled generation; ..
(b) Planning studies made in the period 1960 to date, alone or jointly with other utilities; (c) Transmission load flow studies made in the period 1960 to date which have been used in planning;
[5 (d) Discussions with other electric utilities regarding the allocation of responsibility for, the location of, and the timing of transmission construction.
- 27. ~ Documents showing the following with respect to each existing generating unit on Company's system and estimates thereof with respect to each unit under construction or planned:
(a) Incremental costs at various levels of unit output including incremental fuel cost and variable operation and maintenance cost; 4
(b) No-load running cost of each unit including fixed fuel cost; (c) Start-up costs in dollars following a:
(i) Four-hour shutdown; (ii) Twelve-hour shutdown; (iii) Twenty-four-hour shutdown; (d) Average annual fixed costs for each unit, including:
(1) Fixed operation and maintenance; (ii) Fixed charges, including a breakdown of fixed charge rate by all components; (iii) Other fixed costs, including administrative and 4
general expense allocable to each unit; (e) Original investment cost and date of commercial operation; s
(f) Incremental heat rate and total heat rate throughout normal net loading range; (g) Average annual fuel cost in cents /MMBtu for each year 1960-1985; (h) Minimum and maximum net output in mw; (i) Normal annual amount of time for scheduled maintenance and refueling; (j) For future nuclear units, documents describing how amortization of the initial fuel core is handled in the above costs and providing a breakdown of total capital cost and unit cost amounts for each unit; (k) Unit rating (nameplate and gross capacity), summer and winter; 1
(1) Type of each generating unit (steam trubine, gas turbine, l l
hydro, diesel, etc. ) and whether used for base load, '
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intermediate, peaking, or standby service; l
1 (m) Insurance rates a2 d amounts, including types and coverag,e l 1
.. (coinsurance, fire, boiler, extended coverage, etc. );
(n) Steam temperature, pressure, ar.d flow conditions for each unit, existing and planned; (o) Unit operating personnel including number and classifica- !
tion of employees, hourly wage rates, fringe benefits and administrative overheads, etc. ;
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(p) Copy of studies on nuclear fuel management, including design criteria, such as number of regions, size of inventory and of core, reptocessing time, design load factor, initial and final enrichment, etc. , and studies on costs and method of financing nuclear fuel, including unit costs for ore, conversion, enrichment, fabrication, shipping spent fuel, recovery, plutonium, credit, etc. ;
(q) Sequence of loading units (incremental loading plan) and derivation thereof.
- 28. Documents showing all actual and proposed power purchasea and sales for the period 1970-1985, indicating mw and mwh quantities and fixed and variable charges for each such transaction.
- 29. All cost of service studies relating to wheeling or transmission service on Company's system for the period 1965 to date and in the future from date through 1985.
- 30. Total system load data, including:
(a) Load duration data and curve (hourly loads since Dec,embe r, 1969);
(b) Monthly load data in mw and mwh, gross and net; (c) Projected load forecast (including method) in mw and mwh for period 1973 to 1990 with maximum expected
derivation, also separate load projections 1973-1990 for each wholesale customer; (d) System power factor in percent for peak load period and light load period;
, (e) Percent station usage energy by generating unit and/or by station; (f) Percent system losses and unaccounted-for energy; (g) Da2.ly load curves (24-hour) for Company system's loads, .
including typical week in the spring, summer, fall and winter for the peak load,say in 1973.
- 31. Planned power supply sources to serve projected loads through 1990,
' including:
(a) Generating unit additions; (b) Ratings and types of generating units; (c) Individual in-service dates contemplated; (d) Purchased capacity and energy and names of potential power suppliers; (e) Schedule for retirement of units.
- 32. Financial reports by auditors, including:
(a) Position Statement (Balance Sheet);
(b) Income Statement;
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(c) Statement of Sources and Uses of Funds; (d) Statement of Change in Restricted Accounts; (e) Notes to Financial Statements; (f) Other comments, reports and tables, prepared by audito rs.
- 33. All documents concerning and relating to the transmission of 30 mw of PASNY power by CEI to the City of Cleveland including negotiations with AMPO.
- 34. Documents concerning the offering for bid by the City of Cleveland of $9,800,000 Temporary Electric Light System Subordinate Mortgage Revenue Bonds.
- 35. . Documents concerning the request made by the City of Cleveland i for membership in CAPCO including correspondence with other members of CAPCO.
- 36. Annual reports to stockholders and each separate prospectus filed with the SEC since January 1,1960, FPC Forms 1 and 12 for the years 1960,1965 and 1968 through 1973. l
- 37. Indexes to general and departmental files maintained by the Company.
- 38. Documents setting forth the Company's policy regarding the destruc-tion of documents and files.
- 39. Documents relating to the proposed Yankee-Dixie generation and transmission system.
- 40. Documents pertaining to the activities of CCO Company including minutes of meetings, reports, correspondence, studies, and pro -
jections prepared by CCO Company.
CITY OF CLEymLAND, OHIO ~
By ! bf Rduben Goldfaerg Its Attorney [
Reuben Goldberg i David C. Hjelmfelt 1700 Pennsylvania Avenue, N. W.
Washington, D. C. 20006 Telephone (202) 659-2333 Herbert R. Whiting Director of Law Robert D. Hart i Assistant Director of Law City of Cleveland City Hall Cleveland, Ohio 44114 Telephone (216) 694-2717 August 26, 1974 j i
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CERTIFICATE OF SERVICE
-I hereby certify that service of'the foregoing " Interrogatories of the City of Cleveland to The Toledo Edison Company, Pennsylvania Power Company, Ohio Edison Company and Duquesne Light Company" and "First Request of the City of Cleveland for the Production of Documents by Applicants, The Toledo Edison Company, Pennsylvania Power Company, Ohio Edison Company and Duquesne Light Company" has been made on the following parties listed on the attachment hereto this 26th day of August, 1974, by depositing copies thereof in the United States mail, first class or air mail, postage prepaid.
LM N JCfrik'M ,
Reuben Goldberg
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Attachment m
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' ATTACHMENT Abmic Safety and Licensing Board J seph J. Saunders, Esq.
U.S. Atomic Energy Commission Steven Charno, Esq.
Washington, D. C . - 20545 Antitrust Division Department of Justice
- Mr. Frank W. Karas, Chief Post Office Box 7513 Public Proceedings Branch Washington, D. C. 20044 Office of the Secre.tary Abraham Braitman, Esq.
U. S. Atomic Energy Commission Office of Antitrust and Indemnity
' Washington, D. C. 20545 U. S. Atomic Energy Commission Washington, D. C. 20545 John B. Farmakides, Esq.
Chairman William T. Clabault, Esq.
Atomic Safety and' Licensing Board David A. Leckie Esq.
U. S. Atomic Energy Commission Department of Justice Washington, D. C. 20545 Post Office Box 7513 Washington, D. C. 20044 John H. B : ebbia, ' Esq.
Atomic Safety and Licensing Board Gerald Charnoff, Esq.
Alston, Miller & Gaines Shaw, Pittman, Potts & Trowbridge 1776 K Street, N. W. 910 - 17th Street, N. W. j Washington, D. C. 20006 Washington, D. C. 20006 !
Dr. G'eorge R. Hall Frank R. Clokey, Esq.
Atomic Safety and Licensing Board Special Assistant Attorney General U. S. Atomic Energy Commission Room 219 - Towne House Apartments Washington, D. C. 20545 Harrisburg, Pennsylvania 17105 Benjamin H. Vogler, Esq. Thomas J. Munsch, Jr. , Esq.
Joseph Rutberg, Esq. General Attorney Office of the General Counsel Duquesne Light Company Regulation 435 Sixth Avenue U. S. Atomic Energy Commission Pittsburgh, Pennsylvania 15219 Washington, D. C. 20545 David McNeil Olds, Esq.
Robert J. Verdisco, Esq. John McN. Cramer, Esq.
Office of the General Counsel Reed, Smith, Shaw & McClay R egulation 747 Union Trust Building U. S. Atomic Energy Commission Pittsburgh, Pennsylvania 15219 Washington, D. C. 20545 John R. White, Esq. ;
Jon T. B rown, Esq. .
Duncan, Brown, Weinberg & Palmer Vice President and General Counsel l Ohio Edison Company Suite 777 47 North Main Street 1700 Pennsylvania Avenue, N. W. Akron, Ohio 44308 l
- Washington,- D. C. 20006 l
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Page 2 ATTACHMENT (Continued)
Pennsylvania Power Company 1 East Washington Street New Castle, = Pennsylvania 16103 Leslie Henry, Esq.
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Fuller, Henry, Hodge & Snyder 300 Madison Avenue Toledo, Ohio 43604 Donald H. Hauser, Esq.
The Cleveland Electric Illuminating Co.
Post Office Box 5000 Cleveland, Ohio 44101 John Lansdale, Jr. , Esq.
C ox, Langford & Brown 21 Dupont Circle, N. W.
Washington, D. C. 20036 Alan S. Rosenthal, Chairman .
Atomic Safety and Licensing Appeals Board U. S. Atomic Energy Commission Washington, D. C. 20545 Dr. John H. Buck Atomic Safety and Licensing Appeals Board U. S. Atomic Energy Commission Washington, D. C . 20545 Dr. Lawrence K. Quarles Atomic Safety and Licensing Appeals Board U. S. Atomic Energy Commission Washington, D. C. 20545 C. Raymond Marvin, Esq.
Deborah M. , Powell, Esq.
Antitrust Section 8 East Long Street Suite 510 Columbus, ' Ohio 43215
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