ML20031F673
| ML20031F673 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/15/1981 |
| From: | Horin W, Reynolds N DEBEVOISE & LIBERMAN, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| NUDOCS 8110200286 | |
| Download: ML20031F673 (5) | |
Text
_-_
RCTED CORRESPONDE';CE DOCKETED l
October 15, 1981
- 00716193,
~9
% 2 R t w $p Braq UNITED STATES OF AMERICA s
NUCLEAR REGULATORY COMMISSION s
N.
3
~
BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 COMPANY, et _al.
)
50-446 (Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating Licenses)
)::p g
N f6 APPLICANTS' SUPPLEMENTAL RESPONSE TO INTERROGATORY 3 OF CASE'S FOGTH c2 00T2 9 ;gg SET OF INTERROGATORIES g
si.s,,oceu,,am,,g_')
CO%f 3s w y-Pursuant to CASE's recent request for furtheY,/,( -
s P
clarification of Applicants' response to Interrogatory 3
' id/
of CASE's Fourth Set of Interrogatories, Applicants hereby provide the following additional-*/ supplemental response to that interrogatory:
3.
The ability of each applicant to pay its share of the costs associated with the operation of Comanche Peak is de-pendent upon the receipt of adequate revenues derived from the sale of electricity.
The rates which may be l
charged for those sales are established by the Texas Public Utility Commission
("PUC") for DP&L, TESCO, TP&L, Brazos and Tex-La.
The PUC is obligated by statute and its own regulations to fix the rates of each regulated utility at g503 levels sufficient to provide revenues to cover its share of operating expenses y/
together with a reasonable rate of jy return, to assure confidence in the
- /
Applicants previously supplied an amended response to Interrogatory 3 in " Applicants' Supplemental Response to CASE's Fourth Set of Interrogatories," dated September 25, 1981.
8110200286 811015 PDR ADDCK 05000445
-9 PDR-
r financial integrity of the utility, to maintain its credit, and to attract the capital necessary for the proper discharge of its public duty.
See Article 1446c of Vernon's Annotated Texas Statutes; see also Rules 052.02.02.033 and 052.02.03.032 of the Texas Public Utility Commission's Rules.
TMPA has the authority to establish its own rates, independent of any regulatory agency, and its member cities are obligated by con-tract to establish rates sufficient, inter alia, to pay TMPA for its share of the Comanche Peak operating costs.
Accordingly, assuming the con-tinued establishment of rates in conformity with applicable statutes, regulations and contractual require-ments, each of the Applicants for Comanche Peak will continue to have the ability to pay its obligations on a timely basis, to pay a reasonable rate of return to its investors (if investor-owned), to borrow money at a reasonable rate, to maintain a good credit rating, and to maintain flex-ibility in the financial community and in obtaining capital.
Respect 1
s
- itted, i
\\f j Q
))b Nicholaj; S.
Feynolds v/
,lo L O W William A.
Horin DEBEVOISE & LIBERMAN 1200 Seventeenth Street, N.W.
Washington, D.C.
20036 (202)857-9817 October 15, 1981 Counsel for Applicants
e UNITED STATES OF AMERICA)
)
ss DISTRICT OF COLUMBIA
)
Homer C.
Schmidt, being duly sworn, deposes and saye-That he is Manager, Nuclear Services, Texas Utilities Services, Inc., and knows the contents of the foregoing Appli-cants' Supplemental Response to Interrogatory 3 of CASE's Fourth Set of Interrogatories ; that the same is true of his own knowledge except as to matters therein stated on infor-mation and belief, and as to that, he believes them to be true.
J' T
SWORN to and subscribed before me on this 15th day of October, 1981 aJ-w llnW Notary Public My Commission Expires:
My, Commission Expires October 14, 1983
~
~.--
,a.
,,-,-.e
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
~
TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 COMPANY, _e t _a l.
)
50-446 (Comanche Peak Steam Electric )
(Application for Station, Units 1 and 2)
)
Operating Licenses)
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing "Appli-cants' Supplemental Response to Interrogatory 3 of CASE's Fourth Set of Interrogatories" in the above-captioned matter were served upon the following persons by deposit in the United States mail, first class postage prepaid this 15th day of October, 1981:
Marshall E.
Miller, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Marjorie Ulman Rothschild, Esq.
Dr. Kenneth A. McCollom Office of the Executive Dean, Division of Engineering, Legal Director Architecture and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C.
20555 Dr. Richard Cole, Member David J.
Preister, Esq.
Atomic Safety and Licensing Assistant Attorney General Board Environmental Protection U.S. Nuclear Regulatory Division Commission P.O.
Box 12548 Washington, D.C.
20555 Capitol Station Austin, Texas 78711 Chairman, Atomic Safety and Licensing Board Panel Betty B.
Brink U.S. Nuclear Regulatory CFUR Commission 7600 Anglin Drive Washington, D.C.
20555 Fort Worth, Texas 76119
)
+
e
.. Arch C.
McColl, III, Esq.
Mr. Chase R.
Stephens 701 Commerce Street Docketing & Service Branch Suite 302 U.S. Nuclear Regulatory Dallas, Texas 75202 Commission Washington, D.C.
20555 Jeffery L.
Hart, Esq.
4021 Prescott Avenue Marshall Gilmore, Esq.
Dallas, Texas 75219 1060 West Pipeline Road Hurst, Ts::as 76053
- Mrs. Juanita Ellis President, CASE 1426 South Polk Street Dallas, Texas 75224 William A. Horin cc:
Homer C.
Schmidt I
Spencer C.
Relyea, Esq.
4
- Overnight Delivery
,