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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20155F7031988-06-10010 June 1988 Applicant Supplemental Responses to Case Discovery Requests.* Suppls Responses to Interrogatories 31 & 32 & Interrogatory 32 .W/Certificate of Svc. Related Correspondence ML20155F6751988-06-0808 June 1988 Applicant Supplementation to Answers to Case 850827 Interrogatories to Applicant (850827).* No Further Documents Will Be Provided in Response to Interrogatories H-3 & H-6. Certificate of Svc Encl.Related Correspondence ML20148D4911988-03-22022 March 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicant (870825).* Certificate of Svc Encl.Related Correspondence ML20148D0571988-01-22022 January 1988 Applicant Supplementation to Answers to Case Interrogatories to Applicants (850827).* W/Certificate of Svc.Related Correspondence ML20236X2161987-12-0404 December 1987 Permittees Supplemental Response to Meddie Gregory Interrogatories & Request for Documents (Set 5).* Response to 870409 Interrogatories Re Seismic Design of Control Room Ceiling.Certificate of Svc Encl.Related Correspondence ML20236X3191987-12-0404 December 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant 850827.* Related Correspondence.Certificate of Svc Encl ML20236X3301987-12-0404 December 1987 Supplemental Response to Intervenors Document Production Request Dtd 870619.* Related Correspondence.Certificate of Svc Encl ML20235W1931987-10-0707 October 1987 Supplemental Response to Intervenors Document Production Requests.* Applicants Will Make Listed Matls Available to Intervenors Representatives for Exam & Copying in Dallas,Tx Ofcs.W/Certificate of Svc.Related Correspondence ML20235F2521987-09-22022 September 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Organization Charts Available for Review.Resumes Will Be Obtained Upon Request. W/Certificate of Svc.Related Correspondence ML20237L7181987-08-19019 August 1987 Supplemental Responses to Case Interrogatories Re Mac Rept & Issues Raised by Mac Rept ML20238A7531987-08-14014 August 1987 Responses to Consolidated Intervenors (870619) Interrogatories & Request for Production of Documents.* Certificate of Svc Encl.Related Correspondence ML20237K1941987-08-10010 August 1987 Further Answers to Comanche Peak Review Team Interrogatories (Set 12) Re Reinsp Program for Random Errors.* Related Correspondence ML20236E8041987-07-22022 July 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20235G5011987-07-0606 July 1987 Case Supplementary Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc & Three Oversize Newspaper Articles Encl ML20215J8801987-06-19019 June 1987 Consolidated Intervnors Interrogatories & Reguest for Production of Documents to Applicant Texas Utilities Electric Co (870619).* Related Correspondence ML20215J7741987-06-19019 June 1987 Applicants Interrogatories to Intervenor (Set No. 1987-9).* Certificate of Svc Encl.Related Correspondence ML20215K2951987-06-15015 June 1987 M Gregory Response to Applicants Interrogatories to Consolidated Intervenors (Set 1987-1) & Motion for Protective Order.* Certificate of Svc Encl ML20214W5711987-06-0808 June 1987 Applicant Supplemental Responses to Case 860630 Interrogatories & Request for Documents.* Info Requested from Stone & Webster Submitted as Interrogatory 32.W/ Certificate of Svc.Related Correspondence ML20214W5601987-06-0606 June 1987 Case Response to Applicant Interrogatories to Consolidated Intervenors (Set 1987-1).* Case Would Object to & Moves for Protective Order Against Having to Go Into More Extensive Detail Pending Completion of Discovery ML20214P0861987-05-28028 May 1987 Further Answers to Interrogatories (Comanche Peak Response Team Sets 1-7).* Applicant Suppls Responses to Certain Interrogatories Propounded by Case,Per Board Orders Rendered on 861215.W/Certificate of Svc.Related Correspondence ML20214N1021987-05-21021 May 1987 Applicants Supplementation to Answers to Case Interrogatories to Applicants (850827).* Related Correspondence ML20206M4411987-04-15015 April 1987 Permittees Final Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0201987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Responds to Interrogatories Re Housekeeping & Sys Cleanliness. Certificate of Svc Encl.Related Correspondence ML20206H0941987-04-13013 April 1987 Permittees Further Responses to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20206H0031987-04-13013 April 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205M2781987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Cables Must Be Separated from Conduits Inside Panels by Min Distance of 6 Inches.W/Certificate of Svc.Related Correspondence ML20205L8151987-03-30030 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20205L8281987-03-28028 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-4) & Motion for Protective Order.* Applicant Discovery Conflicts W/Board Assurance That Case Will Have Sufficient Time to Analyze Data.W/Certificate of Svc ML20205R5201987-03-27027 March 1987 Permittees Further Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20204B7441987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-6) & Motion for Protective Order.* Identification of Experts Not Discoverable Due to Irrelevancy of Opinions Based on Work in Progress.Certificate of Svc Encl ML20205M1831987-03-20020 March 1987 Applicant Supplementation to Answers to Case Interrogatories to Applicant (850827).* Updated Charts Available for Review. Resumes Obtained & Will Be Provided If Specifically Requested.W/Certificate of Svc.Related Correspondence ML20204B7211987-03-20020 March 1987 Case Response to Applicant Interrogatories to Intervenor (Set 1987-5) & Motion for Protective Order.* Applicant Requests Premature & Unanswerable by Case Until Comanche Peak Response Team Discovery Complete.W/Certificate of Svc ML20204B6651987-03-18018 March 1987 Applicant Interrogatories to Consolidated Intervenors (Set 1987 -1).* All Instances of Alleged Applicant Intentional Conduct to Delay Const of Unit 1 Requested.Certificate of Svc Encl.Related Correspondence ML20212N5981987-03-0505 March 1987 Applicants Interrogatories to Intervenor (Set Number 1987-8).* Interrogatories Concern Application for Ol. Certificate of Svc Encl.Related Correspondence ML20212D0511987-02-26026 February 1987 Applicant Interrogatories to Intervenor (Set 1987-6).* Set of Interrogatories Re Identifying Experts Consulted W/Or Retained by Intervenor W/Respect to Problems in Facility. Related Correspondence.Certificate of Svc Encl ML20212C8581987-02-26026 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-7).* Info Re Walsh/Doyle Issues &/Or Allegations Requested. W/Certificate of Svc.Related Correspondence ML20212D1381987-02-24024 February 1987 Applicants Interrogatories to Intervenor (Set No. 1987-5).* Interrogatories Re Application for Ol.Certificate of Svc Encl.Related Correspondence ML20211F5681987-02-18018 February 1987 Applicants Interrogatories to Intervenor (Set No 1987-4).* Certificate of Svc Encl.Related Correspondence ML20211C9641987-02-13013 February 1987 Permittees Supplemental Response (Motion for Protective Order) to Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20211D0011987-02-10010 February 1987 Permittees Supplemental Responses to M Gregory Interrogatories (Set 5).* Suppls Responses to M Gregory Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence ML20210E4481987-02-0303 February 1987 Permittees Initial Responses to M Gregory Interrogatories & Request for Production of Documents (Set 5).* Related Correspondence ML20209B0791987-01-29029 January 1987 Applicant Interrogatories to Intervenor (Set 1987-3).* W/Certificate of Svc.Related Correspondence ML20209B0321987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20209B0581987-01-29029 January 1987 Applicant Interrogatories to Case (Set 1987-1).* Related Correspondence ML20212R6211987-01-27027 January 1987 Supplemental Staff Answers to Case Interrogatories.* Suppls 861205 Answers to Case 860922 Discovery Request & Interrogatories 2,4 & 8.Affidavit & Certificate of Svc Encl. Related Correspondence ML20212K6991987-01-21021 January 1987 Applicants Supplementation to Answer to Case Interrogatories to Applicants (850827).* Certificate of Svc Encl.Related Correspondence ML20207Q2721987-01-16016 January 1987 M Gregory Request for Production of Documents (Set 6).* Certificate of Svc Encl.Related Correspondence ML20212E7501986-12-30030 December 1986 Meddie Gregory Interrogatories & Request for Production of Documents (Set 5).* Certificate of Svc Encl.Related Correspondence ML20211M8661986-12-0808 December 1986 Response to Case 860918 Eleventh Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence ML20211M8901986-12-0808 December 1986 Answers to Case 860918 Tenth Set of Interrogatories Re Adequacy of Design Aspects of Comanche Peak Response Team Program Plan.Applicant Moves for Protective Order.W/ Certificate of Svc.Related Correspondence 1988-06-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20127L9321993-01-26026 January 1993 Affidavit of Re Architzel Re Thermo-Lag Installation at Testing for Unit 2.* Statement of Prof Qualifications Encl ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied ML20127L9661993-01-26026 January 1993 Affidavit of Rl Pettis Re Borg-Warner Check Valves.* Statement of Prof Qualifications & Certificate of Svc Encl ML20127L9091993-01-25025 January 1993 Tx Util Electric Response to Citizens for Fair Util Regulation Request of 930113.* Request Fails to Raise Worthy Issue & Should Be Denied.W/Certificate of Svc ML20127L8891993-01-21021 January 1993 Order.* License Should File Response to Citizens for Fair Util Regulation Ltr Requesting That Commission Issue Fr Notice Providing for Opportunity for Hearing Re Issuance of OL by 930125.W/Certificate of Svc.Served on 930122 ML20127G9191993-01-19019 January 1993 Order.* Grants Petitioners Extension of Time Until 930122 to File Brief.Replies to Petitioners Brief Shall Be Filed on or Before 930208.W/Certificate of Svc.Served on 930119 ML20127G9441993-01-19019 January 1993 TU Electric Brief in Opposition to Petitioners Appeal of ASLB Memorandum & Order.* Requests That Petitioners Appeal Be Denied & Licensing Board 921215 Memorandum & Order Be Affirmed.W/Certificate of Svc ML20127G8041993-01-15015 January 1993 NRC Staff Response to Appeal of Licensing Board Decision Denying Petition for Leave to Intervene & Request for Hearing Filed by Bi & Di Orr.* Board 921215 Decision Should Be Upheld.Certificate of Svc Encl ML20127G7451993-01-14014 January 1993 NRC Staff Response to Motion of Petitioners RM Dow & SL Dow, (Disposable Workers of Comanche Peak Steam Electric Station),For Leave to File Out of Time & Request for Extension of Time to File Brief.* W/Certificate of Svc ML20127G7941993-01-12012 January 1993 Opposition of TU Electric to Motion for Leave to File Out of Time & Request for Extension of Time to File Brief by SL Dow (Disposable Workers of Comanche Peak Steam Electric Station) & RM Dow.* W/Certificate of Svc ML20127A5931993-01-0808 January 1993 Brief in Support of Petitioner Notice of Appeal.Aslb Erred by Not Admitting Petitioner Contention & Action Should Be Reversed.W/Certificate of Svc ML20127A6371993-01-0707 January 1993 Notice of Appeal.* Appeal Submitted Due to 921215 Memo Denying Petitioner Motion for Rehearing & Petition for Intervention & Request for Hearings.Proceedings Were Terminated by Aslb.W/Certificate of Svc 1999-06-18
[Table view] |
Text
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3/17/81 - e, g
UNITED STATES OF AMERICA k 4190l h S)
NUCLEAR RIGUIATORY COMMISS]ON s, M
1, C".ce kQ.&lmicf the mEFORE TEE ATWIC SAFFfY AED UCENSIE 30ARD
~
N, In the Matter of l ,
l Docket Bos. 50 APFLICATICE OF TEIA8 IffILITIES l c) oEnERAT:Es C m FAsr, ET AL. FOR AN l aidg $[f'
- p OPERATIED LICEBE FOR C(3dABCIE PEAK STEAM EI2CTRIC STATION l
[
'/ /[f UNITS fl AED $2 (CPBIB) ,
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CASE'S FIFTH SET OF IFfERROGATORIES Q*
TO APPLICAETS AMD IEQUESTS TO PRODUCE g/
CQtBS NOli CASE (Citizens Association for Sound Energy), hereinafter referred to as CASE, Intervonor herein, and files' this, its Fifth Set of Interrogatories to Applicants and Requezts to Produce.
Pureuant to 10 CFR 2.7kOb and 2 741, please answer the following interroga-tories in the manner set forth herewith. Each interrogatory should be answered fully in writing, under cath or affirmation, and include all pertinent informa.
tion knoen to Applicants, their officers, directors or employees as well as any pertinent information known to their advisors or counsel. Each request to produce applies to pertinent documents which are in the nossession, custody or control of APplicants, their officers, directors or emp)Jyees as well as their advisors or counsel. Answer each interrogatory in the order in which it is asked, numbered
~
to correspond to the ntamber of the interrogatory; do not ecubine answers. Please identify the person providing each answer or response.
These interrogatories and requests to produce shall be continuing in nature.
Thus, may time Applicaats obtain inforestion which renders any previous response Q pS 8104060f g
i -
incorrect or induates that a response was incorrect vben made, Applicants should supplement their previous response to the apprcpriate interrogatory or request to produce. Applicants should also supplement their responses as necessary with respect to identification of each person expected to be called et the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall include any writings, drawings, graphs, charts, photographs, reports, studies, and other data capilations frce which infcmation can be obtained. We request that at G date or dates to be agreed upon by mutual consent, Applicants make available for inspection and copying all documents which CASE has specifically repeated cr subject to the requests set forth below. All interrogatories which do act request documents should be answered pursu-st to 10 CFR 2 7kOb(b). '
CASE'S IFTERROGATORIES AND REQUESTS M PRODUCE Ccntentien 25 The require =ents of the Atc=ic Energy Act, as a ended,10 CFR 50 57(a)(L) and 10 CFR SC, Appendix C, have not been =et in that the Applicant is act financially qualified to operate the preposed facility.
Questiens 1 thrcugh 10. Ansver CASE Questions.1 through 10 ca pages 3 through 11 attached. (These are the same questicas regarding financial infor=atica which were asked by the GC Staff in its March 1961 letter to R. J. Gary .-- see CASE Attach =ent A to this pleading.) -
)
If the infor=ation is not presently available, it is not necessary for Applicants ;
to so advise CASE. It vill be satisfactory for Applicants to send us the infer =a- 1 tien requested at the same ti=e they answer the IGC Staff's March 1981 requests, j unless there are objections to any of the questions, i~n which case we request tha,.
the usual time frs=e be ec= plied with under 3C Rules (10 CFR 2 7L0b(b) and 2,.7L1(d)1 The date of the IGC Staff'a request was not clear en CASE's copy; hcVever, we received cur ecpy en 3/14/61. ae therefore vould expect an answer to be filed not later than April 13,1981.
WAOSU46
REQUEST FOR FitiAf4CIAL If4FORMATI0ti CASE QUESTION NO.
- 1. a. Indicate the estimated annual cost by year to operate each unit of the subject facility for the first seven full years of' each unit's commercial operation. The types of costs included in the estinates should be indicated and include (bu't not necessarily be limited to) operation and maintenance expense (with fuel costs shown separately), depreciation, taxes and a reasonable return on investment. (Enclosed is a form which
- should be used for each year of the seven year period.)
4, Indicate the projecttd plant capacity factor (in percent) for each unit dtring each of the seven years. Previce separate estimates using 50 percent and 60 percent plant capacity factors.
- b. Indicate the unit price per kWh experienced by each applicant on system-wide sales of electric power to all custcmers for the most recent 12-month period.
- 2. Indicate the estimated costs of permanently shutting down each unit of the facility, stating what is included in such costs, the assumptiens CASE PAGE.3 j
W
2 made in estimating the costs, tne type of shutdown contemplated, and the intended source of fundi to cover these costs.
- 3. Provide an estimate of the annual cost to maintain each unit of the shutdown facility in a safe condition. Indicate what is, included in the estimate, assumptions made in estimating costs, and the intended source of funds to cover these costs.
4 If the facility is jointly-owned provide copies of the joint participation agreement setting forth the procedures by which the applicants will share operating expenses and dscom .sioning costs.
The following financial inforration is re ed for each investor-owned participant:
- 5. Provide copies of the prospectus for the tc t rgcent security issue +
. -and cocies of the most recent SEC, Form 10-K d50-0. Provide copies of the preliminary prospectus for any i ' ding s,ecurity issue. Submit copies of the Annual Report to Stecks.v.ders each year as required by 10 CFR 50.71(b).
- 6. Describe aspects of its regulatory environment including, but not necessarily limited to, the following: prescribed treatment of allowance for funds used during construction; rate base (original cost,-fair value, other); accounting for deferred income taxes and CASE PAGE 15 de.
l b
I l
! investmenttaxcredits;fueladIusthentclausesineffectorcroposed; historical, partially projected, or fully projected test year.
l
- 7. Describe the nature and amount of its most recent rate relief action (s). In addition, indicate the nature and amount of any l pending rate relief action (i). Use the attached fonn to provide this information.
Provide copies of the submitted, financially i
l related testimony and exhibits of the staff and company in the most.
recent rate relief action or pending action. Furnish copies of the hearing examirer's report and recommendation, and final opinion l last issued viith respect to eacn participant, including all financially related exhibits referred to therein.
i
- 8. Complete the enclosed form entitled, " Financial Statistics," for the most recent twelve-month period and for the , previous three w calendar years. .
e l .
l-l l
e CASE PAGE 5 0 .
e e * ** '* .
1.a .
ATTACHMENT FOR ITEM NO.
E5ill',ATED AfiNUAL COST OF OPERATING NUCIEAR GEtiERATIfiG UNIT:
FOR THE CALENDAR YEAR 19__
(thousands of dollars)
Ooeration and maintenance expenses -
huclear ocwer ceneration t
hs: lear fuel expense (plant factor i)........~...$ __
Other operating expenses . . . . . . . . . . . . . . . . . . . . .
Maintenance expenses . . . . . ..'. . . . . . .. ......... .........
Total nuclear power generation . . . .
Transmission expenses. . . . . . . . . . . . . . . . . . . . . . . .
Administrative and ceneral expenses Property and liability insurance . . . . . . . . . . . . . . . . .
Other A.&G. expenses . . . . . . . . . . . . . . . . . . . . . . . '
Total A.&G. expenses . . . . . . . . . . . . . . . . . . . .
' "~ '((
TOTAL 0&M EXPENSES . . . . . . . . . . . . . . . . . . . . .
Depre:iation expens e . . . . . . . . . . . . . . . . . . . . . . . . .
Taxes other than incere taxes Property taxes . . . . . . . . . . . . . . . . . . . . . . . . . . .
Other. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '
Total taxes other than income taxes. . . . .. . . . . .
Income taxes - Federai . . . . . . . . . . . . . . . . . . . . . . . .
I n come ta xe s - o t he r . . . . . . . . . . . . . . . . . . . . . . . . .
Deferred income taxes - net .....................
l l
l Investment tax credit adjustments - net. . . . .. . . . ........
Return (rate of return: %) . . . . . . . .' . . . . . . . . . .
TOTAL ANNUAL COST OF OPERATION CASE PAGE 6 e
7 ATTACK:Er.T F07. It!" :...
RATE DEVE!.0T".ENTS Ele:tric Gas Steam Grante::
Test year utilized Annual at unt of revenue increase requested- *
- test year basis (000's)
Cate petition filed ,
Annual a cunt of revenue increase. allowed-
, test year basis (000's)-
Percent in:rease in revenues allcwed Cate of final order Effe:tive date -
Rate base finding (000's)
Constru:tien work in progress includen in Rate base (000's)
Rate of return on rate base authcrized Rate of return en ec=en equity authorized Revenue Effect (CCO's)
~
A.: ant re:eived in year granted A=cnt re:eived in subsequent year (If not available, annualize amounts received in year granted)
-~
l . Pendine Re:uests ,
Test year utilized -
t A=unt (r.00's )
- Per:ent increese Date petitien filed i Date by which decisica cust be issued Rate of return on rate base requested Rate of return en co=en equity requested A::unt of rate base requested -
A=unt of construction work in progress requested for inclusion in rate base O
du.
=
y- -
- ~ . , .,,
ATTACH" Crit FOR ITE" 140. A FifiAt;CI A'. STATISTICS 12 n:nths' ended (dollars in millions)
Earnings available to comon equity Average co=en equity Rate of return on average comon equity limes total interest earned before FIT:
Gross income (both including and excluding
- AFDC) + current and deferred FIT + total .
interest charges + amortization of debt discount and expense ,
Times long-term interest earned before FIT:
Grcss income (both including and excluding AFDC) + current and deferred FIT + long-term interest charges + amortization of der,'; discount and expense .
knd atings (end of period)
Standard and Poor's Y.cody's Times interest and preferred dividends earned after FIT:
Gross income (both including and excluding AFDC) + total interest charges + amortization of debt discount and expense + preferred dividends.
AFljDC Net income af ter preferred dividends -
1 .
Market price of comon .
Book value of comon Market-book ratio (end of period)*
Earnings avail for comon less AFDC +
depreciation and amortization, deferred taxes, and invest. tax credit adjust.- .
deferred. .
Co con dividends Ratio Short-term debt Bank loans '.
Cwcercia1 paper Capitalization (Amount & Percent)
Leng-term debt Preferred stock ,
Comen equity ,
CASE PAGE 8
- If subsidiary company, use parent's. data.
_,,_,t'g
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CASE QUESTION 9 -- When ansveric.3, refer to ansvers as 9-1., 9-2., etc.
The following financial information is required for each nunicipal applicant:
- 1. Describe the nature, amount, ratings and success of each municipal
~
applicant's most recent revenue and general cbligatich bond sales.
Indicate the current tota) outstanding indebtedness in each category a for each entity.
- 2. Provide copies of the offic.ial statement for the most recent bond
. issue. Provide copies of the preliminary staterent for any pending security issue. -
- 3. Provide copies of the most recent annual financial report and the most recent interim financial state ents. Centinue to submit copies of the annual financial report for each year thereafter as required by 10 CFR 50.71(b). .
- 4. Is each particoant's ;ercentage evner hip share in the facility equal to its percentage entitlement in the electrical capacity and output cf the plant? If not, explain the difference (s) and any resultant effect on any participant's . obligation to provide its share of operating costs.
- 5. Describe the rate-setting authority of each municipal applicant and how tkat authority may be used to ensure the satisfaction of financial CASE PAGE 9
2 obligations related to operating costs and eventual shutdown cess of the facility. Describe any restrictions on such rate-setting authority and how this may affect the applicant's ability to satisfy its obligations to the project. Desc-ibe the nature and amount i each municipal applicant's ,rpost recent rate relief action and tte anticipated' effect on reven0es. Indicate th'e nature and amount c' any pending ' rate relief action (s).
- 6. If a trembership organi:ation is participating in the joint ownerzus, explain the contractual arrangement ceeng the . members that assurs that funds will be available to r9eet the entity's obligations tn the project. Provide copies of the poer sales contract.
- 7. Describe the applicant's plan for finan:ing its share of the cost of cventual shut down of the facility and t.ainte, nance in a safe ,
shutdown ondition. .
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f u
CASE PAGE,10 ,
. a'ns
CASE QUESTION 10 -- When answering, refer to answers as 10-1., 10-2., etc. j The following financial inforr.ation is required for each ecoperative ;
applicant:
- l. Is each partic pant's percentage ownership share in the facility i
equal to its percentage entitlement in the electrical capacity and output of the plant? li . Tot, explain the difference (s) and any resultant effect on any participant's obligation to provide,its share of operating costs.
- 2. Describe the rate-setting authority and rate covenants of the co-operatives and' how that authority will be used to ensure the satisfaction of financial cbligations in relation to operation and eventual shutdcEn of the facility. .
- 3. Describe the nature and amount of the cdoperative's rOst recent l
rate relief action (s) and its anticipated effect on net margins.
1 In addition, indicate the nature and ammant of any pending rate relief action (s). ,
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- 4. If membership cooperatives are involved, explain the, contractual arrangements between the cooperative and its members that'.will l
provide funds for operation and eventual shutdcwn of the facilityi Provide representative ccpies of such contracts.
- 5. Provide copies of the latest annual and interim financial statements.
Also provide 1 copies of similar statements for the corresponding ,
periods enced in the previous year. Continuetosubmitchpiesof the annual financial statements each year as,' required by 10 CFR 50.71(b). '.
CASE PAGE 11 -
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I Re's pSctfully sub:nitted,
(
' 1 2: w E f N 1J ps.)JuanitaEllis, President i
CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)
Ik26 S. Polk Dallas, Texas 75224 21k/946-9446 ,
21k/941-12n, work,part-time,usually Tuesdayc and Fridays only 3/17/81 I
?
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e CASE PAGE 12 O