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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence ML20010G0731981-08-24024 August 1981 First Set of Interrogatories Directed to NRC Re Contention 21.Certificate of Svc Encl.Related Correspondence ML19343B7071980-12-0505 December 1980 Response to First Set of Interrogatories & Request for Production of Documents from Util on Health Effects of Low Level Radiation.Certificate of Svc Encl.Related Correspondence ML19340C3141980-11-10010 November 1980 Response to W Schuessler Request for Addl Answers to First Set of Interrogatories.Applicant Is Not in Possession of Data Analyzing Hypothetical Significant Offsite Radiological Releases.Certificate of Svc Encl ML19339C0471980-11-0606 November 1980 Response to W Schuessler Second Set of Interrogatories & Requests for Production of Documents.Describes Discussions W/Austin County,Tx Sheriff Dept Re Evacuation Analysis. W/Affidavit,Prof Qualifications & Certificate of Svc ML20008E3971980-10-22022 October 1980 First Set of Interrogatories & Requests for Production of Documents Directed to E Cumings,R Griffith,L Johnston & R Lemmer Re Consolidated Contention on Effects of low-level Radiation.W/Certificate of Svc.Related Correspondence ML20062J4311980-10-20020 October 1980 Informal Request for Addl Responses to First Set of Interrogatories & Requests for Production of Documents,In Lieu of Motion to Compel.Includes Second Set of Interrogatories Directed to Util.Related Correspondence ML19347C1851980-10-14014 October 1980 Amended Response to First Set of Interrogatories.Info Includes Identity of Individuals Directing Site Selection. Certificate of Svc Encl.Related Correspondence ML19332B1801980-09-24024 September 1980 Response to Intervenor Schuessler First Set of Interrogatories & Requests for Production of Documents. Requested Documents & Certificate of Svc Encl ML19347A6951980-09-22022 September 1980 Response to Fh Potthoff Third Set of Interrogatories.Objects to All Questions Due to Irrelevancy.Affidavits & Certificate of Svc Encl.Related Correspondence ML19332A8501980-09-0909 September 1980 Further Response to Tx Pirg 16th Interrogatories.Discusses Future Prices of Gas,Nuclear & Coal Energy,Personnel Qualifications,Control Room Design,Safety Relief Valve Setpoints & Hydrogen Explosion.Certificate of Svc Encl ML19351D1451980-09-0505 September 1980 First Set of Interrogatories & Request for Production of Documents Soliciting Info Re Results of Accident at Site, Emergency Plan & Demographics.Certificate of Svc Encl. Related Correspondence ML19344D8731980-08-18018 August 1980 Response to Potthoff Second Set of Interrogatories. Percentage of Electric Generation by Natural Gas Will Be 68% & 21% by 1985 & 1990,respectively.Objects to Remaining Interrogatories.Certificate of Svc Encl ML19327A5091980-08-0101 August 1980 Second Set of Interrogatories Directed to Applicant. Questions Feasibility of Marine Biomass Farm as Alternative to Facility.Certificate of Svc Encl ML19327A5021980-08-0101 August 1980 Response to Applicant First Set of Interrogatories. Intervenor Has No Intention to Call Expert Witnesses at Present Time ML19327A2261980-07-28028 July 1980 Response to Financial Qualifications Intervenors Fourth Set of Interrogatories.Discusses Program Improvements Made as Result of South Tx Project Incidents,Prefiling Package & H Dean Testimony.Affidavit & Certificate of Svc Encl ML19330B2061980-07-25025 July 1980 Response to Jm & M Bishop 800705 Interrogatories & Requests for Production of Documents.Identifies Witnesses & Summarizes Substance of Testimony.Certificate of Svc & Prof Qualifications Encl.Related Correspondence ML19321B2591980-07-25025 July 1980 Response to 800709 Interrogatories & Request for Production of Documents.Includes Info Re Natural Gas Alternative, Conservation & Interconnect,Error in Computer Program & Technical Qualifications.Certificate of Svc Encl ML19321B2641980-07-25025 July 1980 Response to 800706 Interrogatories & Requests for Production of Documents.Includes Info Re Movement of Brazos River Toward Proposed Pipeline Route & Max Peak Overpressure for Each Critical Structure.Certificate of Svc Encl ML19330A7151980-07-23023 July 1980 Response to Potthoff First Set of Interrogatories.Objects to Majority of Interrogatories on Basis of Irrelevancy. Applicant Has Not Commissioned Study on Marine Bio Farm Feasibility to Provide Synthetic Gas.W/Certificate of Svc ML19330C5521980-07-0909 July 1980 Response to First Set of Interrogatories.Lists Documents Relied Upon in Study of Effect of Power Transmission Lines on Migratory Waterfowl & Identifies Experts.Affidavit, Resume & Certificate of Svc Encl.Related Correspondence ML19320C3151980-07-0909 July 1980 Response to Intervenor D Marrack 800508 Interrogatories. Identifies Expert Witnesses Expected to Be Called in Support of Consolidated Rentfro Contention 2.Affidavit & Certificate of Svc Encl ML19320C5611980-07-0909 July 1980 Interrogatories & Request for Production of Documents Directed to Nrc.Requests Factual Basis of Anticipated Testimony Re Natural Gas Use as Fuel & Subsequent Costs of Electricity.W/Certification of Svc.Related Correspondence ML19320C9271980-07-0909 July 1980 First Set of Interrogatories Directed to Houston Lighting & Power.Requests Factual Info Re U Fuel Sources,Costs,Method of Mining & Stripping,Site & Extent of Mining & Feasibility of Marine Biofarm for Synthetic Natural Gas Supply ML19320C2691980-07-0808 July 1980 Response to Applicant Second Set of Interrogatories & Request for Production of Documents Re Intervenor Pleadings Before ASLB & Aslab.Certificate of Svc Encl ML19330A3501980-07-0808 July 1980 First Set of Interrogatories Directed to NRC Re Financial Qualifications,Hearing Expectation & Witnesses Intended to Be Called ML19330A3421980-07-0808 July 1980 Fourth Set of Interrogatories Directed to Util Re Financial Qualifications.Includes Questions on Disciplinary Actions & Role of Houston Industries.Related Correspondence ML19320C2651980-07-0808 July 1980 Response to Applicant First Set of Interrogatories & Request for Production of Documents Re Impact of Transmission Lines & Fes ML19320C2701980-07-0808 July 1980 Response to D Marrack First Set of Interrogatories.Includes Statements Re Transmission Lines & Alternative Transmission Sites & Routes.Prospective Witness Fj Schlight Prof Qualifications,Affidavit & Certificate of Svc Encl ML19330B2091980-07-0606 July 1980 Interrogatories & Request for Documents Directed to Util. Requests Most Recent Population Projection Data & Methodology Used for Updating Projection.Related Correspondence 1982-06-15
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042B2381982-03-15015 March 1982 Sixth Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20042B2451982-03-15015 March 1982 Motion for Subpoena of Quadrex Corp Employees.Testimony Necessary for Clear Understanding of Brown & Root Deficiencies Despite Util Supervision & Specific Steps Needed to Correct & Prevent Problems.W/Certificate of Svc ML20041F0761982-03-10010 March 1982 Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept.Certificate of Svc Encl.Related Correspondence ML20041F0871982-03-10010 March 1982 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Addl Time Needed to Complete Discovery.Certificate of Svc Encl ML20049J6571982-03-0808 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl ML20041E1001982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl ML20041E1071982-03-0505 March 1982 First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31.Certificate of Svc Encl ML20041E1181982-03-0505 March 1982 Third Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Rept Matters.Related Correspondence ML20041E1201982-03-0505 March 1982 Motion for Order Directing Applicant to Provide Forthcoming Bechtel Quadrex Rept Review.Rept Pertinent to Remaining Issue.Certificate of Svc Encl.Related Correspondence ML20041E1741982-03-0505 March 1982 Brief Opposing R Alexander Appeal from ASLB 820112 Order Denying Petition to Intervene.Aslb Did Not Abuse Discretion in Denying Petition.Certificate of Svc Encl ML20041E0711982-03-0404 March 1982 Second Set of Interrogatories Re Tx Pirg Contention 21 & Quadrex Rept Matters.Certificate of Svc Encl.Related Correspondence ML20049H8881982-03-0101 March 1982 Response Opposing D Marrack 820213 Motion for Review of Dates for Reopening Hearings & Continuance.No Commission Regulations or Atomic Energy Act Provisions Require Applicant Irrevocable Commitment.Certificate of Svc Encl ML20041B5381982-02-22022 February 1982 Reply to Intervenors Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20041C0671982-02-22022 February 1982 Response Opposing Tx Pirg 820209 Motion for Addl Time to File Proposed Findings of Fact & Conclusion of Law.Motion Mooted by Tx Pirg Filing Proposed Findings on 820212. Certificate of Svc Encl ML20041B5421982-02-17017 February 1982 First Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters.Certificate of Svc Encl.Related Correspondence 1982-07-02
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l act.xrEU tonnEggME UNITED STATES OF AE".ICA NUCLEAR REGULATORY COIGIISSION BEFORE THE ATOIGC SAFETY AND LICENSING SOAP.D I
In the Matter of $ DOCKET NUMBER 8
Houston Lighting & Power Co=pany $ 50-L66 4
(Allen's Creek Nuclear Generating S // .
Station, Unit 1) $ ;
ugge jull 41980 *
- l FOURTH SET OF INTES.ROGATORIES FROM FINANCIAL -
C.UALIFICATIONS INTIRVENORS TO HOUSTON LIGHTING 6 Chh'ge,e
' I '*** #
.ct '/
AND POWER stad Preface 4 N s.4 Pursuant to Section 2.760b of the Cor.cission's Rules of Practice, the Financial C.ualifications Intervenors pro-pound the following Interrogatories to HOUSTON LIGHTING &
POWER COMPANY (hereinafter " Applicant"). Each interrogatory should be answered separately and fully in writing under oath or affir..ation by the person or persons taking them no later thanfourteen flL) davs after service of these Interrogatories.
Inter- ocaterv FO-L.1 Please define the following ter=s as clearly, precisely, and unambiguously as possible. Define them as they are, have been, and will be used by officers of, enployees of, or wit-
/
800'nb \V1 DS03 50/i
e r ?(
FQ-L.1 . . . nesses on behalf of, Houston Lighting and Power or Houston Industries, in applications, briefs, exhibits, other docu=ents, or in hearings, before either the Texas Public
- Uti'11ty Co==1ssion or the Nuclear Regulatory Co==ission.
t If the =eaning of any ter= varies according to ti=e, place, or individual usage, please so specify. .
(a) Allowance for Funds Used During Construction (b) Construction Work In Progress (CWIP)
(c) rate base (d) rate of return on rate base (e) co==en equity (f) rate of return on co==on eccity (g) allowed return on co==on ecuity (h) percentage of CWI? allowed in 'the rate ' base (i) =agnitude of C?lI? expenditures allowed in the rate base (j) financial integrity (k) ability to attract capital on reasonable ter=s (1) internally generated funds
(=) externally generated funds .
.A. .
3 FQ-A.1 (n) interest coverage (o) balanced capital structure (p) net income (q) equity security (r) financial standards -
4 (s) investment tax credits Interrocatorv FO-L.2 Interrogatories FQ-E.2 through FQ-L.6 refer to Applicant's answegs to Doggett's First Set of Interrogatories (June 5, 1980).
Subsequent to consolidation of the financial qualifications con-centions, these interrogatories became theThird Set of Interroga-tories Fro = Financial Qualifications Intervenors (FQ-3), and have been're-numbered FQ-3 1 through FQ-3 21.
(a) how, if at all, has the problem of " rapidly increasing construction costs ," referred to in reply to FQ-3 6 as partly responsible for deferral of ACNGS, been a:eliorated since 1976?
(b) What change has there been in the "esnimates of the growth of electric peak load require =ents" since 1976? Provide the following specific infor=ation: 1970 projection of peak for 1971, 1972, . . . 1999, 2'000; 1971 projection of peak for 1972-2001; 1972 projection for thirty future years; etc. , through 1980 projec-tion. Also provide the actual peak for each year 1971 thrcugh 1980.
Interrocator FO-L.3 (a) What are the " program i=provenents learned from the experience on STNP (which) will be added to the ACNGS quality assurance program"? (reply to FQ-3 13) Please be as specific as possible.
.b-L (b) Does Applicant acknowledge the fact that there have .
FQ-L.3 bsen substantial construction deficiencies at STNP? =-:
Interrocatorv FQ-L.E (a) Has Applicant or its representative (contractor) construction personnel yet taken any disciplinary action against for harrassment or threatening of cuality control inspectors?
(?Q-3 15) If so, please give details.
(b)
What scecific steps have been taken ac STNp to insure that "all personnel shall be encouraged and cold how to report any incidents of this type (harrassment of QC inspectors)...
without fear of disciplinary action." as outlined in reply to Will these sa=e steps be taken at ACNGS?
Interro,gatory FQ-3 15?
Interrocatorv FO-E.5 stated (a) In reply to FQ-3 17 through FQ-3 20 Applicant h remote
.in each case that it "does not make plans based en suc speculation." What possibility raised by Int _rrogatory does Applica..t consider " remote", that Applicant or its contractor would " engage in substandard construction practices," er that it would "ever experience a shortage of funds."
What level of probability does Applicant consider (b)
'"re=ote"?
Interrocaterv FQ-L.6 the estimate of Applicants reply to FQ-3 21 implies that construction costs-included in SER Supplement No. 2 (March 1979) was two years out of date even though the "esti= ate is reviewed .
be at least annually and may/ reviewed = ore often. . .".
5 FQ-A.6 (a) Is this 2=pression correct?
(b) When was the last esti= ate made befcre March '79?
(c) What was this estimate?
(d) Was this esti= ate provided to the NRC Staff? When?
Interrozatorv FO-E.7 Applicant's answers to Interrogatories FQ-1.E and FQ-1.5 indicate that Applicant has given little or no thought to the costs associated with unexpected premature shutdown of the facility (a la Three Mile Island) or even to the inevitable costs of waste storage and disposal.
(a) Does Applicant acknowled;e any responsibility for meeting these costs associated with protecting the public health and safety?
(b)- If so, what does Applicant consider that responsibility to be?
(c) Does Applicant consider 8300 tillion in property insurance adecuate to protect its financial integrity against a loss-of-plant accident?
Interrocaterv FO-L.8 Several witnesses for EL&P in ?UC Docket 2676 (EL&P rate increase) testified that a large part of the construction cost was overruns at STNP/ attributable to changes in "the regulations".
Vice-president Oprea in particular complained that since 1973 There had been a cuadrupling effect of regulatory cuidelines that affect what you do and you have to do some retrofitting or retro-engineering in regard to meeting guidelines.
(Tran. 225)
Later he explained wTat he =eant by " quadrupling effect":
That means that we go for naybe eighty or so regulations up to well over four hundred some odd reculations that we have to comply with. . . . (?iC 2673, Tran. 292)
6 PQ-L.8 (a) What specific " regulations" is Mr. Oprea referring to?
(b) Please identify any regulations which have led to cost increases at STMP. Please include a list of thespecific changes in construction which were candated by each particular change in.or add- '
ition to, regulations, and the cost of those changes in construction.
(c) What is the total cost to Applicant of changes in regu-lations affecting STNP?
4 Interrocaterv FC-L.o In PUC 2676 HL&P officer Hollis Dean was asked what would be the effect of " whittling down" the allowed level of CWIP from the recuested 100% to 90%, 80%, etc. He replied, "You can go through it all the way down to zero and I'll say that we're dead if you got down What did Mr. Dean mean by the phrase "we're there." '(Tran. E98) dead"?
Interrecatorv FC-L.10 In PUC 2676 "L&P officer Dean agreed with the state =ent that "unless the overa ll package of co=pensation meets various guidelines of financial integrity, the Company'will be unable to raise additional capital." (Tran. 5E2)
What are the "various guidelines" referred to ain this statement, and what values of these cuidelines are censidered
! to be necessary? Se specific and inclusive in replying.
Incerrocatorv FO-L.ll In FUC 2676, investment banker Iugene Meyer, testif:ing on 1
! behalf of HL&P, made the following state =ents:
I would rank HL&P in the top five in this country in tha utility industrv so far as inflexibility as to future fidan-cing recuire=ents, and this ste=s pri=arily from the enormous I
l
7 FQ-4.ll . . . absolute a=ount of dollars that this Company needs to raise as it goes into the next one, two, and three years. Thus, I place it easily in the top five in the least amount of flexi-bility. It's hard to imagine a conth going by over the next two years where this Co= pny will not either be selling some for= of security or co= leting the preparation for the next
=onths sale of them." Tran. 585)
The Double A rating should give the Co=pany as wide a market into which to sell its debt securities as is necessary to finance the program. I do not believe that is so of an A rating, given the absolute size of EL&F.'s program. (Tran. 586)
I'll warn you that I think there is a first class chance this co=pany will not raise all the capital it needs with either an A-rating through the -n-kets that I see in the next two or three years ahead, especially given the size of its construction budget. I think that is one first-class ga=ble , to ga=ble that this co=pany can get the job done with an A-rating. (Tran. 620)
(a) Does Applicant agree with these statements of its witness, Mr. Meyer?
(b) Would Applicant be able to sell A-rated bonds in suffi-cient quantities to cover construction costs of ACNGS?
(c) Would Applicant be able to sell sufficient A-rated bonds even if no CWIP were allowed in the rate base?
(d) Please provide basis for answers to parts (b) and (c) of this Interrogatory.
Interrocatore FO-L.12 Dr. Steven Sherwin, testifying on behalf of elk? in FUC 2676, spoke of the accident a Three Mile Island as follows:
If a ce=pany loses one of its generators, as happened to General Public Utilities , and then doesn't have sufficient spare capacity to =ect its custo=er requirements, it is forced into purchasing power on a large scale basis. And, as you may recall, the Pennsylvania Cc= mission was not i==e-diately willing to grant that ec=pany reimburse =ent for the increased purchase power cost.
We ec=puted, our office, that it would have taken 118 days only, without rei= burse =ent of the increased purchase power cost, before the entire ecuity of all General Public Utility subsidiary would have been wiped out. (Tran. 529)
. . r ,
8 (a) Does Applicant consider that the Texas FUC would FQ-L.12' p automatically provide "rei=bursement of the increased purchase l
power cost" as well as the cleanup costs in the event of such a financially devastating accident at ACNGS?
If (b) If so, what is the basis for such a belief?
not, does Applicant have any plan for avoiding bankruptcy in I the event of such an accident?
i Interrocaterv FO L.13_
In FUC 2676, ELi? Comptroller R.S. Letbetter testified i
that "if you continue your construction program without recogn z-7 the centinuing operations cf the Company.
ing CWIp, it will affect i
' In other words, it will not be able to fund its payroll. =eet its What precisely nor=al operation expenses, or anything." (Tran. 966) did Mr. Letbetter =ean by the phrase "without recognicing CWIp"?
Interrocaterv FO-a.11 _
Schedule C-4 of the pre-filing package submitted by Applicant in FUC 2676 is a list of " Projects in Construction Works In Progress Ixpenditures to in Excess of $100,000 as of March 31, 1979."
" Install Unit 1 - Allen's Creek" are given as S130,669.000, which of ecnstruction!
was over ten percent of the total estimated cost (a) Is this figure correct?
is the most current figure on expenditures to install (b) What Unit 1? When was this figure last. updated?
( c)
Please give as complete a breakdown as possible of the components of the CWIP expenditures to date en ACNGS.
(d)
How does Applicant expect to reco;er these costs if .
in this proceeding before tk NRC?
'it is denied a construction per=1t 2-
o 9
Interrocaterv FO-L.15 In answer to previous interrogatories, Applicant stated that Mr. Hollis Dean would testify as to Applicant's financial cualifications, but that he had not yet prepared his testimony or identified the docu=ents upon which he will rely.
(a) Will Mr. Dean be prepared to explicate, repudiate or defend the testi=cny of other witnesses on behalf of HL&P in past, current, and future rate proceedings before the FUC?
(b) Will Mr. Dean provide Intervenors with copies of documents upon which his testi=ony is based as they beco=e available to him?
Interrocaterv 70-L.16 It is =y understanding that Houston Lighting and Power is a wholly ~ owned subsidiary of a ec=pany called Housten Industries (HI).
(a) Is this understanding correct? If not, what is the exact relationship of HL&P to HI?
(b) Is HI subject to regulation by the NRC? How?
(c) Is EI subject to regulation by the PUC? 2cw?
(d) Could HL&P survive the financial failure of HI?
(e) Is it possible for' financial difficulties within HI as a whole to affect financial integrity of HL&??
(f) Are construction bonds sold by HLk?. HI, or both?
(g) Which co=pany would be -liable for da= ages caused by routine operation or by an accident at one of HL&P's licensed nuclear facilities?
(h) What role does EI play in monitorring and directing HLk?'s nuclear plant construction?
FOR THE INTERVINORS July 8, 1980
'A]) h)
Eryan StL. Baker cc All Ph::ies