ML19344D873

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

ML19344D873
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	08/18/1980
From:	Copeland J, Newman J BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	Potthoff J AFFILIATION NOT ASSIGNED
Shared Package
ML19344D872	List: ML19344D871 ML19344D873
References
ISSUANCES-CP, NUDOCS 8008260206
Download: ML19344D873 (7)

Text

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8/18/80 UNITED STATES OF AMERICA ~

1 NUCLEAR REGULATORY COMMISSION $, '

'.i ' , r-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD " - .

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- I 3_.j,le:ke In the Matter of S 's__.-MNo S J' HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S

(Allens Creek Nuclear Generating S Station, Unit 1) S APPLICANT'S RESPONSE TO POTTHOFF'S SECOND SET OF INTERROGATORIES In response to the Second Set of Interrogatories propounded by Intervenor Potthoff, Houston Lighting &

Power Company (Applicant) ansvers as follows:

INTERROGATORY NO. 1: What is the average price for natural gas EL&P paid or will pay from 1973-19907 Give average for each year.

ANSWER:

Applicant objects that this interrogatory is not relevant to Potthoff Contention 6. Nonetheless, Applicant l

l does answer that the average prices paid by HL&P for gas l

l during 1973 through 1979 are shown below. The prices for 1

natural gas in the future are not known, but we estimate that the average compound escalation rate for natural gas will be 13-20% between 1979 and 1990.

Year Natural Gas Price (S/MBtu) 1973 .25 1974 .36

. 1975 .59 l 1976 .81 l 1977 1.05 l

1978 1.24 1979 1.66 8008200 24f __

INTERROGATORY NO. 2: What percentage of HL&P's generating capacity was or will be generated by natural gas for the years 1973-1990? Give the percentage for each year.

ANSWER:

Applicant objects that this interrogatory is not relevant to Potthoff Contention 6. Nonetheless, Applicant does answer that the percentage of electric generation by natural cas during 1973 through 1979 is shown below. The future per-centages are dependent on a number of factors, including availability of gas, completion of presently planned capacity on a timely schedule, and the effect of government regulations.

Our present best estimate indicates that by 1985 and 1990 the percentage of electric generation by natural gas will be 68%

and 21%, respectively.

Year  % Natural Gas Generation 1973 99.1 1974 99.3 1975 99.9 1976 99.9 1977 99.1 1978 97.6 1979 89.9 I INTERROGATORY NO. 3: Describe any difficulties that would occur if HL&P were to re-start any natural gas fueled generating or plants that have been phased out.

ANSWER:

Applicant objects that this interrogatory is not relevant to Potthoff Contention 6. Nonetheless, Applicant does l

l

answer that the last natural gas fueled plant phased out was in the early 1970's. The total capacity was less than 50 mw and that equipment was subsequently dismantled. There has been no other gas fueled plant phased out.

INTERROGATORY NO. 4: What would be the cost of a natural gas generating plant of 1200 MW? What would several smaller such plants adding up to 1200 MW cost?

ANSWER:

Applicant objects that this interrogatory is not relevant to Potthoff Contention 6. Nonetheless, Applicant does answer that EL&P has not prepared recent estimates of the cost of any natural gas plants, either 1200 mw size or smaller sizes.

INTERROGATORY NO. 5: In answer to one of my first interrogatories, Applicant has said it did not commission a study on the feasibility of a marine biomass farm because it was " obvious . . . without any study that a marine biomass farm is not a feasible alternative to ACNGS." To whom specifically was this obvious? List any documents or facts this person used to support her/his idea of feasibility.

ANSWER:

See Applicant's Motion for Summary Disposition of Potthoff Contention 6, filed on August 4, 1980.

i i

l Respectfully submitted,

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[ Lh] M1C 8%

OF COUNSEL: pt'egogr pel4Lnd (

J.[/Thoma#

C .4 'ddle, Jr.

Clsarles G. Thrash, Jr.

BAKER & BOTTS 3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEh%LN, REIS, Jack R. Ne' nan AXILRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, D. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY

- .1 -

STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared J. D. Guy, who upon his oath stated that he has answerad the foregoing Houston Lighting & Power Company's Response to Potthoff's Second Set of Interrogatories in his capacity as Manager of Corporate Plani.ing for Houston Lighting & Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

. ,/

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/

J7D . Guy /

SUBSCRIBED AND SWORN TO BEFORE b4E by the said J. D. Guy, on this /fi.L day of A m m-8, , 1980.

U RAJ/

N6tary Public in and for Harris County, Texas

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BZFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 5

(Allens Creek Nuclear Generating S Station, Unit 1) S CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Applicant's Response to Potthoff's Second Set of Interroga-tories in the above-captioned proceeding were served on the following by deposit in the United S ates mail postage prepaid, or by hand-delivery this - day of cruy- ,

V 1980.

Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomf: Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D. C. 20555 Hon. Leroy H. Grebe Dr. E. Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O. Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 .

Mr. Gustave A. Linenberger Atcmic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Atomic Safety and Licensing Mr. Chase R. Stephens Appeal Board Docketing and Service Section U.S. Nuclear Regulatory Commission i Office of the Secretary Washington, D. C. 20555 of the Commission U.S. Nuclear Regulatory Commission Steve Schinki, Esq.

Washington, D. C. 20555 Staff Counsel U.S. Nuclear Regulatory Commission l Richard Lowerre, Esq. Washington, D. C. 20555 Assistant Attorney General for the State of Texas P. O. Box 12548 Capitol Station Austin, Texas 73711

I Bryan L. Baker D. Marrack 1118 Montrose 420 Mulberry Lane Houston, Texas 77019 Bellaire, Texas 77401 J. Morgan Bishop Brenda McCorkle 11418 Oak Spring 6140 Darnell Houston, Texas 77043 Houston, Texas 77074 Stephen A. Doggett W. Matthew Perrenod P. O. Box 592 4070 Merrick Rosenberg, Texas 77471 Houston, Texas 77025 John F. Doherty F. H. Potthoff 4327 Alconbury 7200 Shady Villa, No. 110 Houston, Texas 77021 Houston, Texas 77055 Carro Hinderstein Wayne E. Rentfro 609 Fannin, Suito 521 P. O. Box 1335 Houston, Texas 77002 Rosenberg, Texas 77471 James M. Scott 13935 Ivy Mount Sugar Land, Texas 77478 J. (fregg pelhhd

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