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{{#Wiki_filter:.r s,GlQ n>November 26, 1979
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                          >                                             November 26, 1979 h*
<.NUCLEAR REGULATORY COMMISSION
a
-''BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S HOUSTON LIGHTING & POWER COMPANY S Docket No. 50-466 S (Allens Creek Nuclear Generating S Station, Unit 1)
          . ~l'.     ,,
S HOUSTON LIGHTING & POWER COMPANY'S RESPONSE TO TEX PIRG'S FIFTH SET OF INTERROGATORIES 3 INTERROGATORY NO. 1.
      ,, *     , , 7..s
At page 5.1-16 of the Environmental Report for ACNGS, Applicant states: "Upon consideration of mean and maximum (delta] T's and the probable rate of temperature decrease likely to result from plant or makeup water pumping shut down, no mortality of Brazos River fish is expected as a result of shutdown." Respond to the following which relate to this statement and the question of the effects of cold shutdown on biota:
  . , . ~ .t '
a.Does Applicant believe this statement applies to fish in the cooling pond during winter shutdown?
                          ,s
b.If (a) is yes, what are mean and maximum changes of temperature and the probable rate of temperature decrease during winter shutdown for both the cooling pond and the Brazos River, as used in asserting this conclusion?
      <.                                  UNITED STATES OF AMERICA
c.If (a) is no, what is the estimate of fish mortality in the cooling pond?
  -                                      NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of                         S S
[At a minimum, respond for a winter shutdown circumstance].
HOUSTON LIGHTING & POWER COMPANY         S     Docket No. 50-466 S
d.Provide the parameters for rates of temperature change which will produce mortality for indigenous and stocked game fish utilized in the above-cited conclusion in the ER.
(Allens Creek Nuclear Generating       S Station, Unit 1)                         S HOUSTON LIGHTING & POWER COMPANY'S RESPONSE TO TEX PIRG'S FIFTH SET OF INTERROGATORIES 3
e.Did the definition of fish mortality utilized in the ER analysis include delayed deaths due to reduced resistance to disease or predators resulting from the temperature change?
INTERROGATORY NO. 1. At page 5.1-16 of the Environmental Report for ACNGS, Applicant states: "Upon consideration of mean and maximum (delta] T's and the probable rate of temperature decrease likely to result from plant or makeup water pumping shut down, no mortality of Brazos River fish is expected as a result of shutdown." Respond to the following which relate to this statement and the question of the effects of cold shutdown on biota:
If so, explain how it is included in the analysis.
: a. Does Applicant believe this statement applies to fish in the cooling pond during winter shutdown?
1595 279 b'6 7912170 (g.  
: b. If (a) is yes, what are mean and maximum changes of temperature and the probable rate of temperature decrease during winter shutdown for both the cooling pond and the Brazos River, as used in asserting this conclusion?
,.f.Does this analysis of temperature decrease assume or account for any interactions between temperature change and chemical additions to the water (such as chlorine) as the interaction may affect fish survival rates?
: c. If (a) is no, what is the estimate of fish mortality in the cooling pond? [At a minimum, respond for a winter shutdown circumstance].
If so, explain the assumptions.
: d. Provide the parameters for rates of temperature change which will produce mortality for indigenous and stocked game fish utilized in the above-cited conclusion in the ER.
If not, explain the reasons for not accounting for such interactions.
: e. Did the definition of fish mortality utilized in the ER analysis include delayed deaths due to reduced resistance to disease or predators resulting from the temperature change? If so, explain how it is included in the analysis.
ANSWER: 1(a).As stated in the ACNGS Environmental Report Supplement, the Applicant believes shutdowns will not cause direct mortality to aquatic organisms because of the gradual change in temperature of the waters in the cooling lake in reaching ambient conditions.
1595 279 b'6 (g. 7912170
1(b).Applicant has not made the calculation requested by this interrogatory.
: f. Does this analysis of temperature decrease assume or account for any interactions between temperature change and chemical additions to the water (such as chlorine) as the interaction may affect fish survival rates? If so, explain the assumptions. If not, explain the reasons for not accounting for such interactions.
The Applicant has calcu-l'ated the maximum rate of change of lake water temperature with time (0.19'F/hr.) and the time required to reach 1.5'F above ambient temperature (25 days) for the cooling lake during shutdown in winter.
ANSWER:
This information was already provided to TexPirg in reference number 69 made available for inspection in response to TexPirg's First Request for Production of Documents from Houston Lighting & Power Company.The Applicant has not calculated mean and maximum changes in temperature and the probable rate of temperature decrease for the Brazos River during shutdown.
1(a). As stated in the ACNGS Environmental Report Supplement, the Applicant believes shutdowns will not cause direct mortality to aquatic organisms because of the gradual change in temperature of the waters in the cooling lake in reaching ambient conditions.
1(c).See response to Interrogatory No.1(a) .
1(b). Applicant has not made the calculation requested by this interrogatory. The Applicant has calcu-l'ated the maximum rate of change of lake water temperature with time (0.19'F/hr.) and the time required to reach 1.5'F above ambient temperature (25 days) for the cooling lake during shutdown in winter. This information was already provided to TexPirg in reference number 69 made available for inspection in response to TexPirg's First Request for Production of Documents from Houston Lighting & Power Company.
1(d).The referenced statement on page 5.1-16 of the ACNGS Environmental Report was not made utilizing any specific rate of temperature change which would produce fish mortality since expected maximum rates of temperature changes are so low.
The Applicant has not calculated mean and maximum changes in temperature and the probable rate of temperature decrease for the Brazos River during shutdown.
1(e).No.1(f).No interactions between temperature change and chemical additions to the water as they may affect fish survival were assumed.
1(c). See response to Interrogatory No.1(a) .
The Applicant is not aware of any documented evidence that indicates that temperature changes, as expected in the Allens Creek cooling lake, and the addition of chemicals, as planned at Allens Creek, would somehow interact to significantly affect fish survival in a lake such as the Allens Creek cooling lake.
1(d). The referenced statement on page 5.1-16 of the ACNGS Environmental Report was not made utilizing any specific rate of temperature change which would produce fish mortality since expected maximum rates of temperature changes are so low.
1595 280  
1(e). No.
, , INTERROGATORY NO.
1(f). No interactions between temperature change and chemical additions to the water as they may affect fish survival were assumed. The Applicant is not aware of any documented evidence that indicates that temperature changes, as expected in the Allens Creek cooling lake, and the addition of chemicals, as planned at Allens Creek, would somehow interact to significantly affect fish survival in a lake such as the Allens Creek cooling lake.
2.Since system electrical load for HL&P is higher in summer than winter, is it correct to assume that refueling will occur in the winter for ACNGS?
1595 280 INTERROGATORY NO. 2. Since system electrical load for HL&P is higher in summer than winter, is it correct to assume that refueling will occur in the winter for ACNGS? How long will such refueling last? And have the months preferred for refueling been selected? If so, what is the month preferred for refueling of the reactor?
How long will such refueling last?
ANSWER:
And have the months preferred for refueling been selected?
: 2. Applicant presently expects to refuel the ACNGS annually. Refueling is expected to last six to eight weeks. A preferred month or time of year for refueling has not been selected.
If so, what is the month preferred for refueling of the reactor?
INTERROGATORY NO. 3. In response to #1 of TexPirg's fourth set of interrogatories, HL&P stated that the information requested which relates to barging of the reactor vessel is contained in response to Hinderstein's interrogatories.
ANSWER: 2.Applicant presently expects to refuel the ACNGS annually.
However, the cited Hinderstein interrogatories' responses did not contain a reference to the tons per inch emersion factor for the barge. In computing or calculating whether the barge loaded with the reactor vessel would be able to navigate the San Bernard River, was the tons per inch emersion factor determined for the particular barge?
Refueling is expected to last six to eight weeks.A preferred month or time of year for refueling has not been selected.
ANSWER:
INTERROGATORY NO. 3.
: 3. Yes.
In response to #1 of TexPirg's fourth set of interrogatories, HL&P stated that the information requested which relates to barging of the reactor vessel is contained in response to Hinderstein's interrogatories.
INTERRCGATORY NO. 4. If response to #3 is yes, state what that figure (tons per inch emersion factor) is. Is that an assumed figure, and if so, what is the basis of the assumption?
However, the cited Hinderstein interrogatories' responses did not contain a reference to the tons per inch emersion factor for the barge.
In computing or calculating whether the barge loaded with the reactor vessel would be able to navigate the San Bernard River, was the tons per inch emersion factor determined for the particular barge?
ANSWER: 3.Yes.INTERRCGATORY NO.
4.If response to #3 is yes, state what that figure (tons per inch emersion factor) is.
Is that an assumed figure, and if so, what is the basis of the assumption?
[i.e., is the figure " assumed" based upon some average or calculation for most barges, or is it based upon a specific barge that has been selected already?]
[i.e., is the figure " assumed" based upon some average or calculation for most barges, or is it based upon a specific barge that has been selected already?]
ANSWER: 4.19.51 (long tons), based on the design parameters of the "Loveland" class steel deck cargo barge.
ANSWER:
: 4. 19.51 (long tons), based on the design parameters of the "Loveland" class steel deck cargo barge.
This information was provided in the report referenced in response to TexPirg's prior interrogatories.
This information was provided in the report referenced in response to TexPirg's prior interrogatories.
.INTERROGATORY NO.
INTERROGATORY NO. 5. If a negative response is given to #3, state or explain the technique HL&P uses to prove what the barge will meet the draft characteristics assumed and stated in the response to Hinderstein's interrogatory.
5.If a negative response is given to #3, state or explain the technique HL&P uses to prove what the barge will meet the draft characteristics assumed and stated in the response to Hinderstein's interrogatory.
ANSWER:
ANSWER: 5.Not applicable.
: 5. Not applicable.                   1595 281 INTERROGATORY NO. 6. Gulf Coast Waste Disposal Authority has proposed a refuse-to-energy facility utilizing Houston's trash. Houston City Council, in studying that proposal, has stated that they would like to receive proposals from other sources, too. Has EL&P considered making such a proposal to city council? Does EL&P plan to propose a refuse-to-energy facility to the city council? Please state what documents or memoranda in EL&P's possession relate to such consideration   -
1595 281  
or proposals.
,.INTERROGATORY NO. 6.
ANSWER:
Gulf Coast Waste Disposal Authority has proposed a refuse-to-energy facility utilizing Houston's trash.Houston City Council, in studying that proposal, has stated that they would like to receive proposals from other sources, too.
: 6. EL&P has made no such proposal and has no plans to make any such proposal. Documents related to such proposals are available for inspection at Applicant's Energy Development Complex.
Has EL&P considered making such a proposal to city council?
INTERROGATORY NO. 7. Does EL&P plan to purchase steam or electricity from the GCWDA refuse burning facility mentioned in #6 above? Has HL&P heen contacted regarding the purchase of such energy? Please state what documents or memoranda in EL&P's possession relace to such purchases or contacts.
Does EL&P plan to propose a refuse-to-energy facility to the city council?
ANSWER:
Please state what documents or memoranda in EL&P's possession relate to such consideration or proposals.
: 7. EL&P was contacted about the GCWDA facility, but EL&P has no plans to purchace steam or electricity from the facility. Documents relevant to this matter are avail-able for inspection at Applicant's Energy Development Complex.
-ANSWER: 6.EL&P has made no such proposal and has no plans to make any such proposal.
INTERROGATORY NO. 8. Has HL&P ever considered constructing a nuclear power plant in a foreign country, such as Mexico? If so, provide the following information:
Documents related to such proposals are available for inspection at Applicant's Energy Development Complex.
: a. To what stage of planning did such a proposal go, or is at right now?
INTERROGATORY NO. 7.
: b. Was the consideration given for the purpose of replacing the Allens Creek Unit 1 or 2 with a foreign-sited facility?
Does EL&P plan to purchase steam or electricity from the GCWDA refuse burning facility mentioned in #6 above?
: c. Was a site selected in the foreign nation, and if so, where is that site?
Has HL&P heen contacted regarding the purchase of such energy?
: d. If the proposal was serious enough to receive consideration by HL&P, why was the possibility of a Mexico site excluded from the Teknekron Site Study?
Please state what documents or memoranda in EL&P's possession relace to such purchases or contacts.
ANSWER:
ANSWER: 7.EL&P was contacted about the GCWDA facility, but EL&P has no plans to purchace steam or electricity from the facility.
: 8. No.                             1595 282
Documents relevant to this matter are avail-able for inspection at Applicant's Energy Development Complex.
_4_
INTERROGATORY NO.
 
8.Has HL&P ever considered constructing a nuclear power plant in a foreign country, such as Mexico?
INTERROGATORY NO. 9.       Has EL&P discussed waste-to-energy production related to supplying the needs of Greenway Plaza?
If so, provide the following information:
a.To what stage of planning did such a proposal go, or is at right now?
b.Was the consideration given for the purpose of replacing the Allens Creek Unit 1 or 2 with a foreign-sited facility?c.Was a site selected in the foreign nation, and if so, where is that site?
d.If the proposal was serious enough to receive consideration by HL&P, why was the possibility of a Mexico site excluded from the Teknekron Site Study?
ANSWER: 1595 282 8.No._4_  
..INTERROGATORY NO.
9.Has EL&P discussed waste-to-energy production related to supplying the needs of Greenway Plaza?
If so, explain the nature and outcome of those discussions.
If so, explain the nature and outcome of those discussions.
Please list all documents and memoranda relating to such discussions, and make such material available for inspection.
Please list all documents and memoranda relating to such discussions, and make such material available for inspection.
ANSWER: , 9.EL&P was contacted regarding this proposal but has no present plans to participate in the project.
ANSWER:                                                   ,
: 9. EL&P was contacted regarding this proposal but has no present plans to participate in the project.
Documents related to this proposal are available for inspec-tion at Applicant's Energy Development Complex.
Documents related to this proposal are available for inspec-tion at Applicant's Energy Development Complex.
INTERROGATORY NO. 10.
INTERROGATORY NO. 10.     The following questions relate to the Applicant's electrical demand forecasting model described on
The following questions relate to the Applicant's electrical demand forecasting model described on
: p. S.8-6 of the Final Supp. FES.
: p. S.8-6 of the Final Supp. FES.
a.Regarding the industrial demand model (after first five years), what variable, if any, explicitly accounts for industrial size?
: a. Regarding the industrial demand model (after first five years), what variable, if any, explicitly accounts for industrial size? In particular, is " dollar of value added per unit output", " energy intensiveness per dollar added per unit output", or " employment" utilized to measu;e industrial size (production)?
In particular, is " dollar of value added per unit output", " energy intensiveness per dollar added per unit output", or " employment" utilized to measu;e industrial size (production)?
: b. Regarding the commercial demand model, what variable, if any, explicitly accounts for the size of the commercial user? Is "ficor space" explicitly accounted for?
b.Regarding the commercial demand model, what variable, if any, explicitly accounts for the size of the commercial user?
: c. Is the forecasting model better described as "enumerative (engineering)" or "econometric" in concept?
Is "ficor space" explicitly accounted for?
: d. Does the model differentiate end uses for the electricity and energy consumption within each user class (e.g., space heating, refrigeration, food freezing, etc.)?
c.Is the forecasting model better described as"enumerative (engineering)" or "econometric" in concept?
d.Does the model differentiate end uses for the electricity and energy consumption within each user class (e.g., space heating, refrigeration, food freezing, etc.)?
Please list each end use accounted for by user class (residential, commercial and industrial).
Please list each end use accounted for by user class (residential, commercial and industrial).
e.S.8-6 of the FS-FES notes that the model makes assumptions as to multi-family and single family composition.
: e. S.8-6 of the FS-FES notes that the model makes assumptions as to multi-family and single family composition.
Are similarly separate assumptions made with respect to mobile homes?
Are similarly separate assumptions made with respect to mobile homes? Generally, do individually metered multi-family housing units use less electricity per capita than single family detached units?
Generally, do individually metered multi-family housing units use less electricity per capita than single family detached units?
: f. Does HL&P's model establish sub-categories of types of commercial users? What are those sub-categories?
f.Does HL&P's model establish sub-categories of types of commercial users?
_3_
What are those sub-categories?
1595 283
1595 283_3_
 
9 g.Stata which of following are explicitl1 included as an independent variable in the forecasting model, and note if the variable is used only with respect to forecasting one or two user classes:
9
population; household size and number; housing by type; industry by type and size; commercial building by type and size; gross product of service area; sales; employment; interest rates; income; price and income elasticities of demand, by customer class and by end use; applicance/ equipment data; energy efficiencies; thermal integrity of structures; fuel prices; cross elasticities of demand, by customer class, by end use for alternative forms of energy; meterology; rate structure.
: g. Stata which of following are explicitl1 included as an independent variable in the forecasting model, and note if the variable is used only with respect to forecasting one or two user classes: population; household size and number; housing by type; industry by type and size; commercial building by type and size; gross product of service area; sales; employment; interest rates; income; price and income elasticities of demand, by customer class and by end use; applicance/ equipment data; energy efficiencies; thermal integrity of structures; fuel prices; cross elasticities of demand, by customer class, by end use for alternative forms of energy; meterology; rate structure.
h.What additional independent variables, if any, are included in the demand model?
: h. What additional independent variables, if any, are included in the demand model?
1.What is the assumed increase in the price of electricity through 1987 as used in this model?
: 1. What is the assumed increase in the price of electricity through 1987 as used in this model? Has HL&P revised the figure for price of electricity since the FS-FES was published? If so, what is the revised figure?
Has HL&P revised the figure for price of electricity since the FS-FES was published?
: j. Does the electricity price figure (s) stated in (i) include the effects of most recent projections of price escalation at South Texas Project and ACNGS? Does the price forecast assume that Construction-Work-in-Progress will be allowed by the PUC this year, next year, and/or any following years?
If so, what is the revised figure?
k<   Assuming all other variables constant, what is the effect of a one percent increase in electricity prices on the demand for electricity?
j.Does the electricity price figure (s) stated in (i) include the effects of most recent projections of price escalation at South Texas Project and ACNGS?
ANSWER:
Does the price forecast assume that Construction-Work-in-Progress will be allowed by the PUC this year, next year, and/or any following years?
: 10. Applicant objects to this interrogatory on the grounds that all of the information requested relates to Applicant's projections regarding future demand for elec-tricity. As such, the interrogatory relates to Applicant's need for power analysis, which is not an issue in this proceeding. The ASLB has previously ruled that TexPirg Contention 7, related to energy conservation, does not include the whole issue of need for power by Applicant's system.   (Orders of Sept. 26 and Nov. 7, 1979).
k<Assuming all other variables constant, what is the effect of a one percent increase in electricity prices on the demand for electricity?
INTERROGATORY NO. 11. EL&P personnel have stated that an analytic program called "Progen" is used in determining the production expansion planning required to meet forecasted demand. With regard to the "Progen" model, respond to the following:
ANSWER: 10.Applicant objects to this interrogatory on the grounds that all of the information requested relates to Applicant's projections regarding future demand for elec-tricity.As such, the interrogatory relates to Applicant's need for power analysis, which is not an issue in this proceeding.
1595 284
The ASLB has previously ruled that TexPirg Contention 7, related to energy conservation, does not include the whole issue of need for power by Applicant's system.(Orders of Sept. 26 and Nov.
: a. Does the model consider environmental factors?
7, 1979).INTERROGATORY NO. 11.
EL&P personnel have stated that an analytic program called "Progen" is used in determining the production expansion planning required to meet forecasted demand.With regard to the "Progen" model, respond to the following:
1595 284  
..a.Does the model consider environmental factors?
If so, does it operationalize environmental factors as planning constraints, additional costs in construction or operation of mitigation methods, or in swnming " social costs"?
If so, does it operationalize environmental factors as planning constraints, additional costs in construction or operation of mitigation methods, or in swnming " social costs"?
b.Does the model consider or account for the geographic siting of production facilities?
: b. Does the model consider or account for the geographic siting of production facilities?
Does the model consider the costs of transmission c.facilities associated with production facilities?
: c. Does the model consider the costs of transmission facilities associated with production facilities?
d.Is the reserve margin figure entered as a predetermined figure in this program, or does the model itself determine the appropriate reserve margin?
: d. Is the reserve margin figure entered as a predetermined figure in this program, or does the model itself determine the appropriate reserve margin?
ANSWER: 11.PROGEN is a probabilistic simulation of generation model used in fuel forecasting.
ANSWER:
PROGEN is not used in determining capital cost, environmental cost, or generation planning.
: 11. PROGEN is a probabilistic simulation of generation model used in fuel forecasting.     PROGEN is not used in determining capital cost, environmental cost, or generation planning. Therefore, the questions posed are not applicable.
Therefore, the questions posed are not applicable.
INTERROGATORY NO. 12. List and produce any studies within the possession of Applicant relating to the effects of interconnection on EL&P, the State of Texas, and/or the region.
INTERROGATORY NO. 12.
ANSWER:
List and produce any studies within the possession of Applicant relating to the effects of interconnection on EL&P, the State of Texas, and/or the region.ANSWER: 12.The studies requested are listed or otherwise referred to in the interrogatories requested in Interrogatory No. 18 herein; the interrogatories and record in West Texas Utilities Co., et al. v. Texas Electric Service Co., et al., 40 F.Supp. 798 (N . D . Tex. 1979); the record in In the Matter of the Emergency Hearing on Intrastate and Interstate Service of Texas Interconnected System, TPUC Docket No. 14; and in the record in In the Matter of Central and South West Corporation, et al., SEC Admin. Proc. File No. 3-4951, all of which are available for inspection and copying in the offices of counsel for Applicant.
: 12. The studies requested are listed or otherwise referred to in the interrogatories requested in Interrogatory No. 18 herein; the interrogatories and record in West Texas Utilities Co., et al. v. Texas Electric Service Co., et al.,
Applicant does object to the production of documents or studies which are the subject of protective orders in In the Matter of Houston Lighting
40 F.Supp. 798 (N . D . Tex. 1979); the record in In the Matter of the Emergency Hearing on Intrastate and Interstate Service of Texas Interconnected System, TPUC Docket No. 14; and in the record in In the Matter of Central and South West Corporation, et al., SEC Admin. Proc. File No. 3-4951, all of which are available for inspection and copying in the offices of counsel for Applicant. Applicant does object to the production of documents or studies which are the subject of protective orders in In the Matter of Houston Lighting
& Power Company, et al. (South Texas Project, Units 1 and 2), NRC Docket Nos. 50-498A, 50-499A).
      & Power Company, et al. (South Texas Project, Units 1 and 2), NRC Docket Nos. 50-498A, 50-499A).
1595 285-7-_
1595 285
..INTERROGATORY NO. 13.
 
In testimony before the Texas Public Utility Comminsion, Mr. D. D. Jordan stated that HL&P has decided to increase its targeted reserve margin.
INTERROGATORY NO. 13.     In testimony before the Texas Public Utility Comminsion, Mr. D. D. Jordan stated that HL&P has decided to increase its targeted reserve margin. What are the reasons for increasing the targeted reserve margin?
What are the reasons for increasing the targeted reserve margin?
ANSWER:
ANSWER: 13.The reasons are set forth at pages 10 and 11 of Mr. Jordan's testimony, which papers are attached hereto as Exhibit A.
: 13. The reasons are set forth at pages 10 and 11 of Mr. Jordan's testimony, which papers are attached hereto as Exhibit A.
INTERROGATORY NO. 14.
INTERROGATORY NO. 14. When taking into account likely purchases of power revealed by EL&P in Turner /Oprea testimony at the PUC, will HL&P have a reserve margin of 27-28% by 1988 or 19897   If not, what will be the correct figure?
When taking into account likely purchases of power revealed by EL&P in Turner /Oprea testimony at the PUC, will HL&P have a reserve margin of 27-28% by 1988 or 19897 If not, what will be the correct figure?
ANSWER:
ANSWER: 14.Taking into account all of the assumptions in Mr. Turner's testimony, and assuming the Allens Creek Nuclear Generating Station comes on line by the peak of 1987, reserve margins for the years 1987, 1988, and 1989 will be 26.2%, 27.2%, and 22.9%, respectively.
: 14. Taking into account all of the assumptions in Mr. Turner's testimony, and assuming the Allens Creek Nuclear Generating Station comes on line by the peak of 1987, reserve margins for the years 1987, 1988, and 1989 will be 26.2%, 27.2%, and 22.9%, respectively.
INTERROGATORY NO. 15.
INTERROGATORY NO. 15. Accounting for likely purchases of power, will HL&P have a reserve margin in excess of 30%
Accounting for likely purchases of power, will HL&P have a reserve margin in excess of 30%
before 1990?
before 1990?
ANSWER: 15.Accounting for likely purchases of power, EL&P does not anticipate a reserve margin in excess of 30%
ANSWER:
: 15. Accounting for likely purchases of power, EL&P does not anticipate a reserve margin in excess of 30%
before 1990.
before 1990.
INTERROGATORY NO. 16.
INTERROGATORY NO. 16. Does the present interconnection between Texas Utilities Company and EL&P enable Applicant to utilize TU's capacity on a fulltime, as well as emergency basis? Describe the nature of any obstacles to such usage.
Does the present interconnection between Texas Utilities Company and EL&P enable Applicant to utilize TU's capacity on a fulltime, as well as emergency basis?Describe the nature of any obstacles to such usage.
ANSWER:
ANSWER: 16.No.Applicant presumes that the obstacle is that TU needs its existing capacity to serve the some 1,400,000 customers of its subsidiaries Texas Power & Light Company, Texas Electric Service Company and Dallas Power and Light Company.1595 286_,_
: 16. No. Applicant presumes that the obstacle is that TU needs its existing capacity to serve the some 1,400,000 customers of its subsidiaries Texas Power & Light Company, Texas Electric Service Company and Dallas Power and Light Company.
..INTERROGATORY NO. 17.
1595 286
Is HL&P attempting to purchase a power plant from Texas Utilities Company?
 
Is the purchase for a permanent ownership?
INTERROGATORY NO. 17.       Is HL&P attempting to purchase a power plant from Texas Utilities Company? Is the purchase for a permanent ownership? If not, how long would HL&P own the facility?
If not, how long would HL&P own the facility?
ANSWER:
ANSWER: 17.EL&P is engaged in current negotiations with TU regarding the purchase of a power plant in the early stages of construction.
: 17. EL&P is engaged in current negotiations with TU regarding the purchase of a power plant in the early stages of construction. No final agreement has been reached on the terms of the contract.
No final agreement has been reached on the terms of the contract.
INTERROGATORY NO. 18.     Produce and make available responses by HL&P to interrogatories relating to interconnection filed by parties to the South Texas Project antitrust hearing.
INTERROGATORY NO. 18.
ANSWER:                                           ,
Produce and make available responses by HL&P to interrogatories relating to interconnection filed by parties to the South Texas Project antitrust hearing.
: 18. The interrogatory answers are available for inspection and copying in the offices of counsel "or Applicant.
ANSWER: , 18.The interrogatory answers are available for inspection and copying in the offices of counsel "or Applicant.
INTERROGATORY NO. 19. Regarding the failure of the STP auxiliary mechanical building to meet specifications, what was the date:
INTERROGATORY NO. 19.
: a. That the building's frame and foundation were completed?
Regarding the failure of the STP auxiliary mechanical building to meet specifications, what was the date:
: b. That HL&P QA Division first discovered the failure?
a.That the building's frame and foundation were completed?
: c. That HL&P reported the deficiency to the NRC?
b.That HL&P QA Division first discovered the failure?c.That HL&P reported the deficiency to the NRC?
ANSWER:
ANSWER: 19(a).The final concrete pour on the foundation of the Unit 2 mechanical-electrical auxiliary building was completed on August 13, 1979.
19(a). The final concrete pour on the foundation of the Unit 2 mechanical-electrical auxiliary building was completed on August 13, 1979.     The building frame has not been completed.
The building frame has not been completed.
19 (b) . EL&P Quality Assurance Department was notified by Brown & Root of the error on September 11, 1978.
19 (b) .EL&P Quality Assurance Department was notified by Brown & Root of the error on September 11, 1978.
19 (c) . EL&P notified the NRC Office of Inspection and Enforcement, Region IV, of the error on September 15, 1978.
19 (c) .EL&P notified the NRC Office of Inspection and Enforcement, Region IV, of the error on September 15, 1978.
1595 287 INTERROGATORY NO. 20. What caused the auxiliary mechanical building to be built one foot too short?
1595 287  
ANSWER:
.INTERROGATORY NO. 20.
: 20. Due to a survey calculation error, the basemat of the Unit 2 Mechanical-Electrical Auxiliary Building was constructed one foot short on the east side of the building.
What caused the auxiliary mechanical building to be built one foot too short?
The error occurred because, instead of using the north-south containment / reactor centerline as the reference as had been intended, the building was laid out in the field using the dimensions relative to column line R.1 in the Fuel Handling Building. Column line R.1 in the Fuel Handling Building is offset one foot to the west of the containment / reactor centerline, thus resulting in the east edge of the Mechanical-Electrical Auxiliary Building being laid out one foot short of the design.
ANSWER: 20.Due to a survey calculation error, the basemat of the Unit 2 Mechanical-Electrical Auxiliary Building was constructed one foot short on the east side of the building.
INTERROGATORY NO. 21. Regarding the failure of the STP gantry crane to meet bid specifications relating to tornado force winds, what was the date:
The error occurred because, instead of using the north-south containment / reactor centerline as the reference as had been intended, the building was laid out in the field using the dimensions relative to column line R.1 in the Fuel Handling Building.Column line R.1 in the Fuel Handling Building is offset one foot to the west of the containment / reactor centerline, thus resulting in the east edge of the Mechanical-Electrical Auxiliary Building being laid out one foot short of the design.
: a. That the gantry crane was installed in place?
INTERROGATORY NO. 21.
: b. That EL&P's QA Division first discovered the deficiency?
Regarding the failure of the STP gantry crane to meet bid specifications relating to tornado force winds, what was the date:
: c. That Brown & Root's QA Division first reported the deficiency?
a.That the gantry crane was installed in place?
: d. That the deficiency was first reported to the NRC?
b.That EL&P's QA Division first discovered the deficiency?
ANSWER:
c.That Brown & Root's QA Division first reported the deficiency?
21(a). The ECW gantry crane has been delivered to the site but has not been installed.
d.That the deficiency was first reported to the NRC?ANSWER: 21(a).The ECW gantry crane has been delivered to the site but has not been installed.
21(b). EL&P Quality Assurance Department was notified by Brown & Root of the deficiency on May 15, 1979.
21(b).EL&P Quality Assurance Department was notified by Brown & Root of the deficiency on May 15, 1979.
21(c). The deficiency wa's reported by Brown &
21(c).The deficiency wa's reported by Brown &
Root Quality Assurance Division on May 15, 1979.
Root Quality Assurance Division on May 15, 1979.
21(d).The deficiency was reported to the NRC Office of I&E, Region IV, on May 16, 1979.
21(d). The deficiency was reported to the NRC Office of I&E, Region IV, on May 16, 1979.
1595 288 4..INTERROGATORY NO. 22.
1595 288 4
Who or what division, department or contractor was responsible for drawing up the bid specifica-tion for the STP gantry crane?
INTERROGATORY NO. 22. Who or what division, department or contractor was responsible for drawing up the bid specifica-tion for the STP gantry crane?
ANSWER: 22.Brown & Root Mechanical Discipline of the Power Division prepared the bid specification for the ECW gantry crane.
ANSWER:
INTERROGATORY NO. 23.
: 22. Brown & Root Mechanical Discipline of the Power Division prepared the bid specification for the ECW gantry crane.
How was the bid specification error made (re:#22 above) ?
INTERROGATORY NO. 23. How was the bid specification error made (re: #22 above) ?     -
-ANSWER: 23.The cause of the error is explained in complete detail in the report attached as Exhibit B hereto.
ANSWER:
INTERROGATORY NO. 24.
: 23. The cause of the error is explained in complete detail in the report attached as Exhibit B hereto.
Did any department or division of HL&P review the bid specification on tne gantry crane prior to its transmittal to the subcontractor?
INTERROGATORY NO. 24. Did any department or division of HL&P review the bid specification on tne gantry crane prior to its transmittal to the subcontractor? What department or division af HL&P received a copy of the bid specifications prior to transmittal to the subcontractor?
What department or division af HL&P received a copy of the bid specifications prior to transmittal to the subcontractor?
ANSWER:
ANSWER: 24.The bid specification was reveiwed by HL&P Mechanial Engineering and Quality Assurance Departments prior to transmittal to the subcontractor.
: 24. The bid specification was reveiwed by HL&P Mechanial Engineering and Quality Assurance Departments prior to transmittal to the subcontractor. The bid specifi-cation was received by HL&P Civil Engineering, Operations, Construction, Nuclear Engineering, Electrical Engineering, and Purchasing Departments prior to transmittal to the subcontractor.
The bid specifi-cation was received by HL&P Civil Engineering, Operations, Construction, Nuclear Engineering, Electrical Engineering, and Purchasing Departments prior to transmittal to the subcontractor.
INTERROGATORY NO. 25. Mr. D. D. Jordan testified before the Texas PUC that HL&P believed the engineering work at STP was 60% complete at the time of the issuance of a construction permit, but in fact it was only about 10% complete. On what basis did EL&P assume the engineering work to be 60% complete at the tbme of the construction permit issuance? When and how did EL&P learn that the work was, in fact, only 10%
INTERROGATORY NO. 25.
complete?
Mr. D. D. Jordan testified before the Texas PUC that HL&P believed the engineering work at STP was 60% complete at the time of the issuance of a construction permit, but in fact it was only about 10% complete.
ANSWER:
On what basis did EL&P assume the engineering work to be 60% complete at the tbme of the construction permit issuance?
: 25. Assumptions made by HL&P concerning the status of engineering work prior to issuance of the con-struction permit were based on Brown & Root reports issued shortly before receipt of the construction permit. The recognition of discrepancies was an evolving process. The
When and how did EL&P learn that the work was, in fact, only 10%
_11_          1595 289
complete?ANSWER: 25.Assumptions made by HL&P concerning the status of engineering work prior to issuance of the con-struction permit were based on Brown & Root reports issued shortly before receipt of the construction permit.
 
The recognition of discrepancies was an evolving process. The 1595 289_11_
discrepancies in the status of engineering described by Mr.
, discrepancies in the status of engineering described by Mr.
Jordan's testimony were derived from an intensive project management controls audit that took place over several months in 1978.
Jordan's testimony were derived from an intensive project management controls audit that took place over several months in 1978.
INTERROGATORY NO. 26.
INTERROGATORY NO. 26. Did HL&P have any method or manner of independently verifying the completeness of Brown & Root's engineering work at STP prior to issuance of a construction permit?   If so, what was that method?   How does EL&P verify the completeness of Ebasco's engineering work in this pro-ceeding?
Did HL&P have any method or manner of independently verifying the completeness of Brown & Root's engineering work at STP prior to issuance of a construction permit?If so, what was that method?
ANSWER:
How does EL&P verify the completeness of Ebasco's engineering work in this pro-ceeding?ANSWER: 26.HL&P did not independently verify the complete-ness of Brown & Root's engineering work at STP prior to issuance of the construction permit.
: 26. HL&P did not independently verify the complete-ness of Brown & Root's engineering work at STP prior to issuance of the construction permit. To determine the status of engineering on the Allens Creek project, HL&P independently employs a method known as the " Earned Value Technique". By this method, the scope of the Allens Creek engineering effort is broken down into individual work elements. Each element is budgeted engineering man-days to complete the particular effort. As work progresses, the budgeted man-days are compared monthly with the actual man-days expended to indicate the performance of the engineering effort. The cumulative effort is also compared monthly.
To determine the status of engineering on the Allens Creek project, HL&P independently employs a method known as the " Earned Value Technique".
INTERROGATORY NO. 27. What percentage of the engineering work has been completed on Allens Creek Nuclear Generating Station?
By this method, the scope of the Allens Creek engineering effort is broken down into individual work elements.Each element is budgeted engineering man-days to complete the particular effort.
ANSWER:
As work progresses, the budgeted man-days are compared monthly with the actual man-days expended to indicate the performance of the engineering effort.The cumulative effort is also compared monthly.
: 27. As of October 1, 1979, HL&P determined that 47.9% of engineering for the Allens Creek project has been completed.
INTERROGATORY NO. 27.
INTERROGATORY NO. 28. Does EL&P have on-site QA personnel at STP?
What percentage of the engineering work has been completed on Allens Creek Nuclear Generating Station?ANSWER: 27.As of October 1, 1979, HL&P determined that 47.9% of engineering for the Allens Creek project has been completed.
ANSWER:
INTERROGATORY NO. 28.
Yes.
Does EL&P have on-site QA personnel at STP?ANSWER: Yes.INTERROGATORY NO. 29.
INTERROGATORY NO. 29. List each presently operable natural gas generating station along with its normally expected lifetime, its date of firs'. year operation, its MWe capacity, and its date of expected phase-out under the Industrial Fuel Use Act.
List each presently operable natural gas generating station along with its normally expected lifetime, its date of firs'. year operation, its MWe capacity, and its date of expected phase-out under the Industrial Fuel Use Act.1595 290_12_
_12_            1595 290
.ANSWER:..Normal In Service Capacity Date of Unit Lif etime (Yrs)
 
Date (MW)Phasecut*DW7 40-45 1955 167 1995 HOCI 40-45 1943 44 1995 HOC 2 40-45 1947 44 1995 HOC 3 40-45 1950 77 1995 HOC 4 40-45 1951 77 1995 HOC GT1 25 1967-68 14 1995 HOC GT2 25 1967-68 14 1995 HOC GT3 25 1967-68 14 1995 HOC GT4 25 1967-68 14 1995 HOC GT5 25 1967-68 14 1995 HOC GT6 25 1967-68 14 1995 GB1 40-45 1949 70 1995 GB2 40-45 1949 70 1995 GB3 40-45 1953 112 1995 GB4 40-45 1953 112 1995 GB5 40-45 1973 398**GB73 25 1976 56 1995 GB74 25 1976 56 1995 GB81 25 1976 64 1995 GB82 25 1976 64 1995 GB83 25 1976 64 1995 GB84 25'1976 64 1995 WEB 1 40-45 1954 109 1995 WEB 2 40-45 1954 109 1995 WEB 3 40-45 1965 375 1995 WEB GT1 25 1967-68 14 1995 SRB 1 40-45 1958 174**SRB 2 40-45 1956 174**SRB 3 40-45 1959 230**SRB 4 40-45 1960 230**SRB GT1 25 1967-68 27 1993 SRB GT2 25 1967-68 14 1995 THW1 40-45 1958 71 1995 THW2 40-45 1960 229 1995 THWCC 40-45 1974 474*****TWH51 25 1975 60 1995 THW52 25 1975 60 1995 THW53 25 1975 60 1995 THW54 25 1975 60 1995 THW55 25 1975 60 1995 THW56 25 1975 60 1995 THW GT1 25 1967-68 14 1995-13-1595 291  
ANSWER: ..
..Normal In Service Capacity Date of Unit Lifetime (Yrs)
Normal       In Service Capacity     Date of Unit     Lif etime (Yrs)   Date     (MW)       Phasecut*
Date (MW)Phasecut*WAPl 40-45 1958 169 1995 WAP2 40-45 1958 174 1995 WAP3 40-45 1961 278 1995 WAP4 40-45 1968 555 1995 WAP GT1 25 1967-68 14 1995 PHP1 40-45 1966 441 1995 PHRi 40-45 1967 441 1995 PHR3 40-45 1968 565 1995 PER4 40-45 1973 750**PHR GT1 25 1967-68 14 1995**CBl 40-45 1970 750 CB2 40-45 1972 750**CB3 40-45 1974 750**These dates are based on PPIFA regulations now in
DW7           40-45           1955     167         1995 HOCI         40-45           1943       44         1995 HOC 2         40-45           1947       44         1995 HOC 3         40-45           1950       77         1995 HOC 4         40-45           1951       77         1995 HOC GT1         25         1967-68       14         1995 HOC GT2         25         1967-68       14         1995 HOC GT3         25         1967-68       14         1995 HOC GT4         25         1967-68       14         1995 HOC GT5         25         1967-68       14         1995 HOC GT6         25         1967-68       14         1995 GB1           40-45         1949       70         1995 GB2           40-45         1949       70         1995 GB3           40-45         1953     112         1995 GB4           40-45         1953     112         1995 40-45         1973     398           **
*preliminary form and dates may change depending the outcome of final regulations.
GB5 GB73           25           1976       56         1995 GB74           25           1976       56         1995 GB81           25           1976       64         1995 GB82           25           1976       64         1995 GB83           25           1976       64         1995 GB84           25'           1976       64         1995 WEB 1         40-45         1954     109         1995 WEB 2         40-45         1954     109         1995 WEB 3         40-45         1965     375         1995 WEB GT1         25         1967-68       14         1995 40-45         1958     174           **
**Convert to oil use in 1990.
SRB 1 SRB 2         40-45         1956     174           **
Includes eight 45 MW gas turbines.
SRB 3         40-45         1959     230           **
***INTERROGATORY NO. 30.
SRB 4         40-45         1960     230           **
Produce a copy of GE Topical report NEDO 10466 (including revisions) entitled " Power Generation Control Complex Design Criteria and Safety Evaluation." ANSWER: 30.This document is available for inspection at Applicant's Energy Development Complex.
SRB GT1         25       1967-68       27         1993 SRB GT2         25       1967-68       14         1995 THW1         40-45         1958       71         1995 THW2         40-45         1960     229         1995 THWCC         40-45         1974     474***       **
INTERROGATORY NO. 31.
TWH51           25           1975       60         1995 THW52           25           1975     60         1995 THW53           25           1975       60         1995 THW54           25           1975     60         1995 THW55           25           1975       60         1995 THW56           25           1975       60         1995 THW GT1         25         1967-68       14         1995 1595 291
Produce any graphic depictions, drawings, or photographs of the control room design and power generation control complex (either for ACNGS or GE standard design).
 
ANSWER: 31.This information is available for inspection at Applicant's Energy Development Complex.
Normal         In Service     Capacity     Date of Unit       Lifetime (Yrs)       Date         (MW)       Phasecut*
1595 292.
WAPl             40-45           1958         169         1995 WAP2             40-45           1958         174           1995 WAP3             40-45           1961         278           1995 WAP4             40-45           1968         555           1995 WAP GT1           25           1967-68           14           1995 PHP1             40-45           1966         441           1995 PHRi             40-45           1967         441           1995 PHR3             40-45           1968         565           1995 750            **
.t Respectfully submitted,.C , , .JA?!O' } C$' '%!
PER4             40-45           1973 PHR GT1           25           1967-68         14           1995 750            **
OF COUNSEL:
CBl             40-45           1970 750           **
J.. Gregory Copeland p.ThomasBiddle,Jr.
CB2             40-45           1972 750           **
BAKER & BOTTS Charles G. Thrash, Jr.
CB3             40-45           1974
3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 770C2 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W.
* These dates are based on PPIFA regulations now in preliminary form and dates may change depending the outcome of final regulations.
1025 Connecticut Ave., N.W.
    **   Convert to oil use in 1990.
Washington, C. C.20036 Washington, D. C.
    ***  Includes eight 45 MW gas turbines.
20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1595 293  
INTERROGATORY NO. 30. Produce a copy of GE Topical report NEDO 10466 (including revisions) entitled " Power Generation Control Complex Design Criteria and Safety Evaluation."
.-.STATE OF TEXAS S S COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared W. F. McGuire, who upon his oath stated that he has answered Interrogatory Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, and 29 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Principal Engineer of the Environmental Protection Department for Houston Lighting
ANSWER:
& Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.. - - ." McGuire..SUBSCRIBED AND SWORN TO BEFORE ME by the said W.F. McGuire, on this 2fpA day of M M m . , 1979.
: 30. This document is available for inspection at Applicant's Energy Development Complex.
\7 Notar'y Public in and for' Harris County, Texas ANGELA NICHOLS SMITH Notary Public in Harris County, Texas My Commissron Dpires C2f$MA 1% l@O
INTERROGATORY NO. 31. Produce any graphic depictions, drawings, or photographs of the control room design and power generation control complex (either for ACNGS or GE standard design).
#1595 294  
ANSWER:
-.STATE OF TEXAS S S COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Jon G. White, who upon his oath stated that he has answered Interrogatory Nos. 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 30, and 31 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Supervising Engineer for Houston Lighting &
: 31. This information is available for inspection at Applicant's Energy Development Complex.
1595 292 t
Respectfully submitted,
                                      ,          .C
                                  , . JA?!O' } C$' '%!
OF COUNSEL:                 J.. Gregory Copeland p.ThomasBiddle,Jr.
BAKER & BOTTS               Charles G. Thrash, Jr.
3000 One Shell Plaza       3000 One Shell Plaza Houston, Texas 770C2       Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS,   Jack R. Newman AXELRAD & TOLL           Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.
Washington, C. C. 20036     Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1595 293 STATE       OF TEXAS   S S
COUNTY OF HARRIS       S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared W. F. McGuire, who upon his oath stated that he has answered Interrogatory Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, and 29 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Principal Engineer of the Environmental Protection Department for Houston Lighting
    & Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.
                                      .. McGuire SUBSCRIBED AND SWORN TO BEFORE ME by the said W. F. McGuire, on this 2fpA day of M M m . , 1979.
                                                \
7 Notar'y Public in and for' Harris County, Texas ANGELA NICHOLS SMITH Notary Public in Harris County, Texas My Commissron Dpires C2f$MA           1% l@O 1595 294
 
STATE OF   TEXAS   S S
COUNTY OF HARRIS     S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Jon G. White, who upon his oath stated that he has answered Interrogatory Nos. 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 30, and 31 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Supervising Engineer for Houston Lighting &
Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.
Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.
hl.$Jon G. White' L Jon G. White, on this c964 day of 40t.svH'MA.)y the said SUBSCRIBED AND SWORN TO BEFORE ME b , 1979.$dtary Public in and for Harris County, Texas
hl.$
>1595 295 O EXHIBIT A 1595 296 l'.\( .l _( il..I facilities.
Jon G. White' L
2 Q.MR. JORDAN, DOES THE LEVuu OF CAPACITY RESERVES AFFECT THE 3 CONSTRUCTION PROGRAS1?
SUBSCRIBED AND SWORN TO BEFORE ME b Jon G. White, on this c964 day of 40t.svH'MA.)y ,the said 1979.
4 A.IIL&P has always sogght to maintain a level of reserves S which will allow us to continue to provide reliable service 6 under unexpected adverse circumstances.
                                    $dtary Public in and for Harris County, Texas 1595 295
The conditiops of 7 the past have been such that the Company's policy of
 
, I 8 maintaining a 15% target reserve margin was adequate to l 1 0 ensure a reliable supply of electricity for its customers.
O EXHIBIT A 1595 296
l-: 10 As stated previously, our system was basically a gas based
 
, 11 system and such generating units are relatively more
l'.\( .l _     ( il I           facilities.
'12 reliable than are alternative fuel units.
2     Q. MR. JORDAN, DOES THE LEVuu OF CAPACITY RESERVES AFFECT THE 3           CONSTRUCTION PROGRAS1?
Additionally, 13 the gas fuel was readily available and inexpensive.
4     A. IIL&P has always sogght to maintain a level of reserves S           which will allow us to continue to provide reliable service 6           under unexpected adverse circumstances.                     The conditiops of 7           the past have been such that the Company's policy of I
14 However, the movement away from total dependence on
8           maintaining a 15% target reserve margin was adequate to                             l 1
<15 gas units may dictate a change in the target level of i i 16 reserves.Non-gas units such as coal, lignite and nuclear 17 are not as reliable because of the increased complexity and 18 design involved.
0           ensure a reliable supply of electricity for its customers.                           l 10         As stated previously, our system was basically a gas based                           ,
These units are also large in. order to 19 realize economies of scale and represent sizable shares of 20 our generating capacity.
11         system and such generating units are relatively more 12       reliable than are alternative fuel units.                       Additionally, 13         the gas fuel was readily available and inexpensive.
Interruptions in fuel avail-21 ability due to transportation or production dif ficulties 22 may also lessen system reliability.
14               However, the movement away from total dependence on 15       gas units may dictate a change in the target level of                                 i i
All these consider-
16       reserves. Non-gas units such as coal, lignite and nuclear 17       are not as reliable because of the increased complexity and 18       design involved.         These units are also large in. order to 19         realize economies of scale and represent sizable shares of 20       our generating capacity.           Interruptions in fuel avail-21         ability due to transportation or production dif ficulties 22       may also lessen system reliability.                     All these consider-23         ations may require us to maintain a higher percentage of 24         reserves in the future.
-23 ations may require us to maintain a higher percentage of 24 reserves in the future.
25               The target level of reserves is also influenced by 26         the uncertainty of the expected load growth in the service 27         area. Even thounh our cresent forecast indicates a                           ,
25 The target level of reserves is also influenced by 26 the uncertainty of the expected load growth in the service 27 area.Even thounh our cresent forecast indicates a
28       reduction in the projected load grosth from our historical IlOllSTON 1.l(.IITIN(; & l'Oh! R ros!I' \NY 1595 297     -
, 28 reduction in the projected load grosth from our historical
                          =-         .: -                     _ . _ _ _
_.IlOllSTON 1.l(.IITIN(; & l'Oh! R ros!I' \NY 1595 297-___=-.: -_. _ _ _
 
PM ;1._ . l l of 16 ..-_ _ . . . . . . . .
PM ;1._ . l l   of     16 ..
..-...I pattern, we anticipate that our installed capacity reserves
I       pattern, we anticipate that our installed capacity reserves
/2 will be 18.7%, 14% and 13.8% in 1980 through 1982, 3 respectively, based on our current construction program and 4 demand forecast.
  / 2       will be 18.7%, 14% and 13.8% in 1980 through 1982, 3       respectively, based on our current construction program and 4       demand forecast. These reserve percentages are expressed d
These reserve percentages are expressed d 5 in terms of the yearly peak load requirements.
5       in terms of the yearly peak load requirements.                     Even as 6       costly as our construction program is, we still are f511ing 7     somewhat short of our desired minimum reserve margin in 8       1981 through 1982.
Even as 6 costly as our construction program is, we still are f511ing
9   Q. Wi!AT PLANS DOES HL&P HAVE TO DEAL WITH THESE SHORTFALLS IN                         ,
'7 somewhat short of our desired minimum reserve margin in 8 1981 through 1982.
10     GENERATING CAPACITY?
9 Q.Wi!AT PLANS DOES HL&P HAVE TO DEAL WITH THESE SHORTFALLS IN
11 A. We have previously executed a contract with the City of 12   Austin Municipal Electric System which provides that the 13     City will make available to HL&P 500 MW of capacity during 14   both 1980 and 1981. Negotiations are presently under way                           j
, 10 GENERATING CAPACITY?
  ~
11 A.We have previously executed a contract with the City of 12 Austin Municipal Electric System which provides that the 13 City will make available to HL&P 500 MW of capacity during 14 both 1980 and 1981.
15   with potential suppliers to provide additional supplemental 16   power to HL&P through 1985.       Additionally, evaluations are 17   being made to determine the feasibility and desirability of 18     installing short-lead-time capacity in 1982 or 1983.
Negotiations are presently under way j~15 with potential suppliers to provide additional supplemental 16 power to HL&P through 1985.
19             OTHER EFFORTS TO PROVIDE RELIABLE SERVICE 20 Q. !!R. JORDAN, HAS HL&P IMPLE!!ENTED OTHER PROGRAllS DhSIGNED TO 21     PROVIDE RELIABLE CUSTOMER SERVICE?
Additionally, evaluations are 17 being made to determine the feasibility and desirability of 18 installing short-lead-time capacity in 1982 or 1983.
22 A. Yes. We have recently undergone a reorganization in the 23     customer service area and we have also embarked upon a 24     program to improve energy conservation.
19 OTHER EFFORTS TO PROVIDE RELIABLE SERVICE 20 Q.!!R. JORDAN, HAS HL&P IMPLE!!ENTED OTHER PROGRAllS DhSIGNED TO 21 PROVIDE RELIABLE CUSTOMER SERVICE?
25 Q. PLEASE DESCRIBE THE PURPOSE OF YOUR REORGANIZATION AND THE 26     EFFECTS IT HAS HAD ON SERVICE.                                           ,
22 A.Yes.We have recently undergone a reorganization in the 23 customer service area and we have also embarked upon a 24 program to improve energy conservation.
27 A. The purpose of the reoraanization was to enable us to 28     respond more quickly and positively to customer HOUSTON LIGilTING & POWER CoslPANY                 l595 298
25 Q.PLEASE DESCRIBE THE PURPOSE OF YOUR REORGANIZATION AND THE 26 EFFECTS IT HAS HAD ON SERVICE.
 
,.27 A.The purpose of the reoraanization was to enable us to 28 respond more quickly and positively to customer l595 298 HOUSTON LIGilTING & POWER CoslPANY O EXHIBIT B 1595 299  
O EXHIBIT B 1595 299
....Houston A'\.ComJany_October 9, 1979 Electric Tower RO Box M ST-HL-AE-381
 
---g h Texas N SFN: V-0100 i''Director, Region IV Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76102
A     \
Houston ComJany October 9, 1979 Electric Tower
      ---            RO Box M                                           ST-HL-AE-381
  ' '        i g     h Texas N                                           SFN: V-0100 Director, Region IV Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76102


==Dear Sir:==
==Dear Sir:==
South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Final Report on the Essential Cooling Water Intake Structure Gantry Crane On May 16, 1979, Houston Lighting & Power Company reported to your office the failure to properly include the effects of tornado This wind loadings on the essential cooling water gantry crane.
South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Final Report on the Essential Cooling Water Intake Structure Gantry Crane On May 16, 1979, Houston Lighting & Power Company reported to your office the failure to properly include the effects of tornado This wind loadings on the essential cooling water gantry crane.
transmittal provides a final written report as required by 10 CFR 50.55(e).Very truly yours, A 7 2. a.'l-E. A. Turner Vice President Power Plant Construction
transmittal provides a final written report as required by 10 CFR 50.55(e).
& Technical Services LRJ:bf Attachment 1595 J00.DUPLICATE DOCUMENT Entire document previously entered into system under:
Very truly yours, A       7
7 ANO... .q No. of pages:
: 2. a.'l-E. A. Turner Vice President Power Plant Construction
/}}
                                                                      & Technical Services LRJ:bf Attachment 1595 J00 DUPLICATE DOCUMENT Entire document previously entered into system under:
ANO q   7 No. of pages:           /}}

Latest revision as of 04:59, 2 February 2020

Response to Fifth Set of Interrogatories.Answers Interrogatories 1-31.Certificate of Svc Encl
ML19211A110
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 11/26/1979
From: Copeland J
BAKER & BOTTS, HOUSTON LIGHTING & POWER CO.
To:
TEXAS PUBLIC INTEREST RESEARCH GROUP
References
NUDOCS 7912170046
Download: ML19211A110 (20)


Text

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- NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S S

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

(Allens Creek Nuclear Generating S Station, Unit 1) S HOUSTON LIGHTING & POWER COMPANY'S RESPONSE TO TEX PIRG'S FIFTH SET OF INTERROGATORIES 3

INTERROGATORY NO. 1. At page 5.1-16 of the Environmental Report for ACNGS, Applicant states: "Upon consideration of mean and maximum (delta] T's and the probable rate of temperature decrease likely to result from plant or makeup water pumping shut down, no mortality of Brazos River fish is expected as a result of shutdown." Respond to the following which relate to this statement and the question of the effects of cold shutdown on biota:

a. Does Applicant believe this statement applies to fish in the cooling pond during winter shutdown?
b. If (a) is yes, what are mean and maximum changes of temperature and the probable rate of temperature decrease during winter shutdown for both the cooling pond and the Brazos River, as used in asserting this conclusion?
c. If (a) is no, what is the estimate of fish mortality in the cooling pond? [At a minimum, respond for a winter shutdown circumstance].
d. Provide the parameters for rates of temperature change which will produce mortality for indigenous and stocked game fish utilized in the above-cited conclusion in the ER.
e. Did the definition of fish mortality utilized in the ER analysis include delayed deaths due to reduced resistance to disease or predators resulting from the temperature change? If so, explain how it is included in the analysis.

1595 279 b'6 (g. 7912170

f. Does this analysis of temperature decrease assume or account for any interactions between temperature change and chemical additions to the water (such as chlorine) as the interaction may affect fish survival rates? If so, explain the assumptions. If not, explain the reasons for not accounting for such interactions.

ANSWER:

1(a). As stated in the ACNGS Environmental Report Supplement, the Applicant believes shutdowns will not cause direct mortality to aquatic organisms because of the gradual change in temperature of the waters in the cooling lake in reaching ambient conditions.

1(b). Applicant has not made the calculation requested by this interrogatory. The Applicant has calcu-l'ated the maximum rate of change of lake water temperature with time (0.19'F/hr.) and the time required to reach 1.5'F above ambient temperature (25 days) for the cooling lake during shutdown in winter. This information was already provided to TexPirg in reference number 69 made available for inspection in response to TexPirg's First Request for Production of Documents from Houston Lighting & Power Company.

The Applicant has not calculated mean and maximum changes in temperature and the probable rate of temperature decrease for the Brazos River during shutdown.

1(c). See response to Interrogatory No.1(a) .

1(d). The referenced statement on page 5.1-16 of the ACNGS Environmental Report was not made utilizing any specific rate of temperature change which would produce fish mortality since expected maximum rates of temperature changes are so low.

1(e). No.

1(f). No interactions between temperature change and chemical additions to the water as they may affect fish survival were assumed. The Applicant is not aware of any documented evidence that indicates that temperature changes, as expected in the Allens Creek cooling lake, and the addition of chemicals, as planned at Allens Creek, would somehow interact to significantly affect fish survival in a lake such as the Allens Creek cooling lake.

1595 280 INTERROGATORY NO. 2. Since system electrical load for HL&P is higher in summer than winter, is it correct to assume that refueling will occur in the winter for ACNGS? How long will such refueling last? And have the months preferred for refueling been selected? If so, what is the month preferred for refueling of the reactor?

ANSWER:

2. Applicant presently expects to refuel the ACNGS annually. Refueling is expected to last six to eight weeks. A preferred month or time of year for refueling has not been selected.

INTERROGATORY NO. 3. In response to #1 of TexPirg's fourth set of interrogatories, HL&P stated that the information requested which relates to barging of the reactor vessel is contained in response to Hinderstein's interrogatories.

However, the cited Hinderstein interrogatories' responses did not contain a reference to the tons per inch emersion factor for the barge. In computing or calculating whether the barge loaded with the reactor vessel would be able to navigate the San Bernard River, was the tons per inch emersion factor determined for the particular barge?

ANSWER:

3. Yes.

INTERRCGATORY NO. 4. If response to #3 is yes, state what that figure (tons per inch emersion factor) is. Is that an assumed figure, and if so, what is the basis of the assumption?

[i.e., is the figure " assumed" based upon some average or calculation for most barges, or is it based upon a specific barge that has been selected already?]

ANSWER:

4. 19.51 (long tons), based on the design parameters of the "Loveland" class steel deck cargo barge.

This information was provided in the report referenced in response to TexPirg's prior interrogatories.

INTERROGATORY NO. 5. If a negative response is given to #3, state or explain the technique HL&P uses to prove what the barge will meet the draft characteristics assumed and stated in the response to Hinderstein's interrogatory.

ANSWER:

5. Not applicable. 1595 281 INTERROGATORY NO. 6. Gulf Coast Waste Disposal Authority has proposed a refuse-to-energy facility utilizing Houston's trash. Houston City Council, in studying that proposal, has stated that they would like to receive proposals from other sources, too. Has EL&P considered making such a proposal to city council? Does EL&P plan to propose a refuse-to-energy facility to the city council? Please state what documents or memoranda in EL&P's possession relate to such consideration -

or proposals.

ANSWER:

6. EL&P has made no such proposal and has no plans to make any such proposal. Documents related to such proposals are available for inspection at Applicant's Energy Development Complex.

INTERROGATORY NO. 7. Does EL&P plan to purchase steam or electricity from the GCWDA refuse burning facility mentioned in #6 above? Has HL&P heen contacted regarding the purchase of such energy? Please state what documents or memoranda in EL&P's possession relace to such purchases or contacts.

ANSWER:

7. EL&P was contacted about the GCWDA facility, but EL&P has no plans to purchace steam or electricity from the facility. Documents relevant to this matter are avail-able for inspection at Applicant's Energy Development Complex.

INTERROGATORY NO. 8. Has HL&P ever considered constructing a nuclear power plant in a foreign country, such as Mexico? If so, provide the following information:

a. To what stage of planning did such a proposal go, or is at right now?
b. Was the consideration given for the purpose of replacing the Allens Creek Unit 1 or 2 with a foreign-sited facility?
c. Was a site selected in the foreign nation, and if so, where is that site?
d. If the proposal was serious enough to receive consideration by HL&P, why was the possibility of a Mexico site excluded from the Teknekron Site Study?

ANSWER:

8. No. 1595 282

_4_

INTERROGATORY NO. 9. Has EL&P discussed waste-to-energy production related to supplying the needs of Greenway Plaza?

If so, explain the nature and outcome of those discussions.

Please list all documents and memoranda relating to such discussions, and make such material available for inspection.

ANSWER: ,

9. EL&P was contacted regarding this proposal but has no present plans to participate in the project.

Documents related to this proposal are available for inspec-tion at Applicant's Energy Development Complex.

INTERROGATORY NO. 10. The following questions relate to the Applicant's electrical demand forecasting model described on

p. S.8-6 of the Final Supp. FES.
a. Regarding the industrial demand model (after first five years), what variable, if any, explicitly accounts for industrial size? In particular, is " dollar of value added per unit output", " energy intensiveness per dollar added per unit output", or " employment" utilized to measu;e industrial size (production)?
b. Regarding the commercial demand model, what variable, if any, explicitly accounts for the size of the commercial user? Is "ficor space" explicitly accounted for?
c. Is the forecasting model better described as "enumerative (engineering)" or "econometric" in concept?
d. Does the model differentiate end uses for the electricity and energy consumption within each user class (e.g., space heating, refrigeration, food freezing, etc.)?

Please list each end use accounted for by user class (residential, commercial and industrial).

e. S.8-6 of the FS-FES notes that the model makes assumptions as to multi-family and single family composition.

Are similarly separate assumptions made with respect to mobile homes? Generally, do individually metered multi-family housing units use less electricity per capita than single family detached units?

f. Does HL&P's model establish sub-categories of types of commercial users? What are those sub-categories?

_3_

1595 283

9

g. Stata which of following are explicitl1 included as an independent variable in the forecasting model, and note if the variable is used only with respect to forecasting one or two user classes: population; household size and number; housing by type; industry by type and size; commercial building by type and size; gross product of service area; sales; employment; interest rates; income; price and income elasticities of demand, by customer class and by end use; applicance/ equipment data; energy efficiencies; thermal integrity of structures; fuel prices; cross elasticities of demand, by customer class, by end use for alternative forms of energy; meterology; rate structure.
h. What additional independent variables, if any, are included in the demand model?
1. What is the assumed increase in the price of electricity through 1987 as used in this model? Has HL&P revised the figure for price of electricity since the FS-FES was published? If so, what is the revised figure?
j. Does the electricity price figure (s) stated in (i) include the effects of most recent projections of price escalation at South Texas Project and ACNGS? Does the price forecast assume that Construction-Work-in-Progress will be allowed by the PUC this year, next year, and/or any following years?

k< Assuming all other variables constant, what is the effect of a one percent increase in electricity prices on the demand for electricity?

ANSWER:

10. Applicant objects to this interrogatory on the grounds that all of the information requested relates to Applicant's projections regarding future demand for elec-tricity. As such, the interrogatory relates to Applicant's need for power analysis, which is not an issue in this proceeding. The ASLB has previously ruled that TexPirg Contention 7, related to energy conservation, does not include the whole issue of need for power by Applicant's system. (Orders of Sept. 26 and Nov. 7, 1979).

INTERROGATORY NO. 11. EL&P personnel have stated that an analytic program called "Progen" is used in determining the production expansion planning required to meet forecasted demand. With regard to the "Progen" model, respond to the following:

1595 284

a. Does the model consider environmental factors?

If so, does it operationalize environmental factors as planning constraints, additional costs in construction or operation of mitigation methods, or in swnming " social costs"?

b. Does the model consider or account for the geographic siting of production facilities?
c. Does the model consider the costs of transmission facilities associated with production facilities?
d. Is the reserve margin figure entered as a predetermined figure in this program, or does the model itself determine the appropriate reserve margin?

ANSWER:

11. PROGEN is a probabilistic simulation of generation model used in fuel forecasting. PROGEN is not used in determining capital cost, environmental cost, or generation planning. Therefore, the questions posed are not applicable.

INTERROGATORY NO. 12. List and produce any studies within the possession of Applicant relating to the effects of interconnection on EL&P, the State of Texas, and/or the region.

ANSWER:

12. The studies requested are listed or otherwise referred to in the interrogatories requested in Interrogatory No. 18 herein; the interrogatories and record in West Texas Utilities Co., et al. v. Texas Electric Service Co., et al.,

40 F.Supp. 798 (N . D . Tex. 1979); the record in In the Matter of the Emergency Hearing on Intrastate and Interstate Service of Texas Interconnected System, TPUC Docket No. 14; and in the record in In the Matter of Central and South West Corporation, et al., SEC Admin. Proc. File No. 3-4951, all of which are available for inspection and copying in the offices of counsel for Applicant. Applicant does object to the production of documents or studies which are the subject of protective orders in In the Matter of Houston Lighting

& Power Company, et al. (South Texas Project, Units 1 and 2), NRC Docket Nos. 50-498A, 50-499A).

1595 285

INTERROGATORY NO. 13. In testimony before the Texas Public Utility Comminsion, Mr. D. D. Jordan stated that HL&P has decided to increase its targeted reserve margin. What are the reasons for increasing the targeted reserve margin?

ANSWER:

13. The reasons are set forth at pages 10 and 11 of Mr. Jordan's testimony, which papers are attached hereto as Exhibit A.

INTERROGATORY NO. 14. When taking into account likely purchases of power revealed by EL&P in Turner /Oprea testimony at the PUC, will HL&P have a reserve margin of 27-28% by 1988 or 19897 If not, what will be the correct figure?

ANSWER:

14. Taking into account all of the assumptions in Mr. Turner's testimony, and assuming the Allens Creek Nuclear Generating Station comes on line by the peak of 1987, reserve margins for the years 1987, 1988, and 1989 will be 26.2%, 27.2%, and 22.9%, respectively.

INTERROGATORY NO. 15. Accounting for likely purchases of power, will HL&P have a reserve margin in excess of 30%

before 1990?

ANSWER:

15. Accounting for likely purchases of power, EL&P does not anticipate a reserve margin in excess of 30%

before 1990.

INTERROGATORY NO. 16. Does the present interconnection between Texas Utilities Company and EL&P enable Applicant to utilize TU's capacity on a fulltime, as well as emergency basis? Describe the nature of any obstacles to such usage.

ANSWER:

16. No. Applicant presumes that the obstacle is that TU needs its existing capacity to serve the some 1,400,000 customers of its subsidiaries Texas Power & Light Company, Texas Electric Service Company and Dallas Power and Light Company.

1595 286

INTERROGATORY NO. 17. Is HL&P attempting to purchase a power plant from Texas Utilities Company? Is the purchase for a permanent ownership? If not, how long would HL&P own the facility?

ANSWER:

17. EL&P is engaged in current negotiations with TU regarding the purchase of a power plant in the early stages of construction. No final agreement has been reached on the terms of the contract.

INTERROGATORY NO. 18. Produce and make available responses by HL&P to interrogatories relating to interconnection filed by parties to the South Texas Project antitrust hearing.

ANSWER: ,

18. The interrogatory answers are available for inspection and copying in the offices of counsel "or Applicant.

INTERROGATORY NO. 19. Regarding the failure of the STP auxiliary mechanical building to meet specifications, what was the date:

a. That the building's frame and foundation were completed?
b. That HL&P QA Division first discovered the failure?
c. That HL&P reported the deficiency to the NRC?

ANSWER:

19(a). The final concrete pour on the foundation of the Unit 2 mechanical-electrical auxiliary building was completed on August 13, 1979. The building frame has not been completed.

19 (b) . EL&P Quality Assurance Department was notified by Brown & Root of the error on September 11, 1978.

19 (c) . EL&P notified the NRC Office of Inspection and Enforcement, Region IV, of the error on September 15, 1978.

1595 287 INTERROGATORY NO. 20. What caused the auxiliary mechanical building to be built one foot too short?

ANSWER:

20. Due to a survey calculation error, the basemat of the Unit 2 Mechanical-Electrical Auxiliary Building was constructed one foot short on the east side of the building.

The error occurred because, instead of using the north-south containment / reactor centerline as the reference as had been intended, the building was laid out in the field using the dimensions relative to column line R.1 in the Fuel Handling Building. Column line R.1 in the Fuel Handling Building is offset one foot to the west of the containment / reactor centerline, thus resulting in the east edge of the Mechanical-Electrical Auxiliary Building being laid out one foot short of the design.

INTERROGATORY NO. 21. Regarding the failure of the STP gantry crane to meet bid specifications relating to tornado force winds, what was the date:

a. That the gantry crane was installed in place?
b. That EL&P's QA Division first discovered the deficiency?
c. That Brown & Root's QA Division first reported the deficiency?
d. That the deficiency was first reported to the NRC?

ANSWER:

21(a). The ECW gantry crane has been delivered to the site but has not been installed.

21(b). EL&P Quality Assurance Department was notified by Brown & Root of the deficiency on May 15, 1979.

21(c). The deficiency wa's reported by Brown &

Root Quality Assurance Division on May 15, 1979.

21(d). The deficiency was reported to the NRC Office of I&E, Region IV, on May 16, 1979.

1595 288 4

INTERROGATORY NO. 22. Who or what division, department or contractor was responsible for drawing up the bid specifica-tion for the STP gantry crane?

ANSWER:

22. Brown & Root Mechanical Discipline of the Power Division prepared the bid specification for the ECW gantry crane.

INTERROGATORY NO. 23. How was the bid specification error made (re: #22 above) ? -

ANSWER:

23. The cause of the error is explained in complete detail in the report attached as Exhibit B hereto.

INTERROGATORY NO. 24. Did any department or division of HL&P review the bid specification on tne gantry crane prior to its transmittal to the subcontractor? What department or division af HL&P received a copy of the bid specifications prior to transmittal to the subcontractor?

ANSWER:

24. The bid specification was reveiwed by HL&P Mechanial Engineering and Quality Assurance Departments prior to transmittal to the subcontractor. The bid specifi-cation was received by HL&P Civil Engineering, Operations, Construction, Nuclear Engineering, Electrical Engineering, and Purchasing Departments prior to transmittal to the subcontractor.

INTERROGATORY NO. 25. Mr. D. D. Jordan testified before the Texas PUC that HL&P believed the engineering work at STP was 60% complete at the time of the issuance of a construction permit, but in fact it was only about 10% complete. On what basis did EL&P assume the engineering work to be 60% complete at the tbme of the construction permit issuance? When and how did EL&P learn that the work was, in fact, only 10%

complete?

ANSWER:

25. Assumptions made by HL&P concerning the status of engineering work prior to issuance of the con-struction permit were based on Brown & Root reports issued shortly before receipt of the construction permit. The recognition of discrepancies was an evolving process. The

_11_ 1595 289

discrepancies in the status of engineering described by Mr.

Jordan's testimony were derived from an intensive project management controls audit that took place over several months in 1978.

INTERROGATORY NO. 26. Did HL&P have any method or manner of independently verifying the completeness of Brown & Root's engineering work at STP prior to issuance of a construction permit? If so, what was that method? How does EL&P verify the completeness of Ebasco's engineering work in this pro-ceeding?

ANSWER:

26. HL&P did not independently verify the complete-ness of Brown & Root's engineering work at STP prior to issuance of the construction permit. To determine the status of engineering on the Allens Creek project, HL&P independently employs a method known as the " Earned Value Technique". By this method, the scope of the Allens Creek engineering effort is broken down into individual work elements. Each element is budgeted engineering man-days to complete the particular effort. As work progresses, the budgeted man-days are compared monthly with the actual man-days expended to indicate the performance of the engineering effort. The cumulative effort is also compared monthly.

INTERROGATORY NO. 27. What percentage of the engineering work has been completed on Allens Creek Nuclear Generating Station?

ANSWER:

27. As of October 1, 1979, HL&P determined that 47.9% of engineering for the Allens Creek project has been completed.

INTERROGATORY NO. 28. Does EL&P have on-site QA personnel at STP?

ANSWER:

Yes.

INTERROGATORY NO. 29. List each presently operable natural gas generating station along with its normally expected lifetime, its date of firs'. year operation, its MWe capacity, and its date of expected phase-out under the Industrial Fuel Use Act.

_12_ 1595 290

ANSWER: ..

Normal In Service Capacity Date of Unit Lif etime (Yrs) Date (MW) Phasecut*

DW7 40-45 1955 167 1995 HOCI 40-45 1943 44 1995 HOC 2 40-45 1947 44 1995 HOC 3 40-45 1950 77 1995 HOC 4 40-45 1951 77 1995 HOC GT1 25 1967-68 14 1995 HOC GT2 25 1967-68 14 1995 HOC GT3 25 1967-68 14 1995 HOC GT4 25 1967-68 14 1995 HOC GT5 25 1967-68 14 1995 HOC GT6 25 1967-68 14 1995 GB1 40-45 1949 70 1995 GB2 40-45 1949 70 1995 GB3 40-45 1953 112 1995 GB4 40-45 1953 112 1995 40-45 1973 398 **

GB5 GB73 25 1976 56 1995 GB74 25 1976 56 1995 GB81 25 1976 64 1995 GB82 25 1976 64 1995 GB83 25 1976 64 1995 GB84 25' 1976 64 1995 WEB 1 40-45 1954 109 1995 WEB 2 40-45 1954 109 1995 WEB 3 40-45 1965 375 1995 WEB GT1 25 1967-68 14 1995 40-45 1958 174 **

SRB 1 SRB 2 40-45 1956 174 **

SRB 3 40-45 1959 230 **

SRB 4 40-45 1960 230 **

SRB GT1 25 1967-68 27 1993 SRB GT2 25 1967-68 14 1995 THW1 40-45 1958 71 1995 THW2 40-45 1960 229 1995 THWCC 40-45 1974 474*** **

TWH51 25 1975 60 1995 THW52 25 1975 60 1995 THW53 25 1975 60 1995 THW54 25 1975 60 1995 THW55 25 1975 60 1995 THW56 25 1975 60 1995 THW GT1 25 1967-68 14 1995 1595 291

Normal In Service Capacity Date of Unit Lifetime (Yrs) Date (MW) Phasecut*

WAPl 40-45 1958 169 1995 WAP2 40-45 1958 174 1995 WAP3 40-45 1961 278 1995 WAP4 40-45 1968 555 1995 WAP GT1 25 1967-68 14 1995 PHP1 40-45 1966 441 1995 PHRi 40-45 1967 441 1995 PHR3 40-45 1968 565 1995 750 **

PER4 40-45 1973 PHR GT1 25 1967-68 14 1995 750 **

CBl 40-45 1970 750 **

CB2 40-45 1972 750 **

CB3 40-45 1974

  • These dates are based on PPIFA regulations now in preliminary form and dates may change depending the outcome of final regulations.
    • Convert to oil use in 1990.
      • Includes eight 45 MW gas turbines.

INTERROGATORY NO. 30. Produce a copy of GE Topical report NEDO 10466 (including revisions) entitled " Power Generation Control Complex Design Criteria and Safety Evaluation."

ANSWER:

30. This document is available for inspection at Applicant's Energy Development Complex.

INTERROGATORY NO. 31. Produce any graphic depictions, drawings, or photographs of the control room design and power generation control complex (either for ACNGS or GE standard design).

ANSWER:

31. This information is available for inspection at Applicant's Energy Development Complex.

1595 292 t

Respectfully submitted,

, .C

, . JA?!O' } C$' '%!

OF COUNSEL: J.. Gregory Copeland p.ThomasBiddle,Jr.

BAKER & BOTTS Charles G. Thrash, Jr.

3000 One Shell Plaza 3000 One Shell Plaza Houston, Texas 770C2 Houston, Texas 77002 LOWENSTEIN, NEWMAN, REIS, Jack R. Newman AXELRAD & TOLL Robert H. Culp 1025 Connecticut Ave., N.W. 1025 Connecticut Ave., N.W.

Washington, C. C. 20036 Washington, D. C. 20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY 1595 293 STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared W. F. McGuire, who upon his oath stated that he has answered Interrogatory Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, and 29 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Principal Engineer of the Environmental Protection Department for Houston Lighting

& Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

.. McGuire SUBSCRIBED AND SWORN TO BEFORE ME by the said W. F. McGuire, on this 2fpA day of M M m . , 1979.

\

7 Notar'y Public in and for' Harris County, Texas ANGELA NICHOLS SMITH Notary Public in Harris County, Texas My Commissron Dpires C2f$MA 1% l@O 1595 294

STATE OF TEXAS S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Jon G. White, who upon his oath stated that he has answered Interrogatory Nos. 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 30, and 31 to TexPirg's Fifth Set of Interrogatories to Houston Lighting & Power Company in his capacity as Supervising Engineer for Houston Lighting &

Power Company, and all statements contained therein are true and correct to the best of his knowledge and belief.

hl.$

Jon G. White' L

SUBSCRIBED AND SWORN TO BEFORE ME b Jon G. White, on this c964 day of 40t.svH'MA.)y ,the said 1979.

$dtary Public in and for Harris County, Texas 1595 295

O EXHIBIT A 1595 296

l'.\( .l _ ( il I facilities.

2 Q. MR. JORDAN, DOES THE LEVuu OF CAPACITY RESERVES AFFECT THE 3 CONSTRUCTION PROGRAS1?

4 A. IIL&P has always sogght to maintain a level of reserves S which will allow us to continue to provide reliable service 6 under unexpected adverse circumstances. The conditiops of 7 the past have been such that the Company's policy of I

8 maintaining a 15% target reserve margin was adequate to l 1

0 ensure a reliable supply of electricity for its customers. l 10 As stated previously, our system was basically a gas based ,

11 system and such generating units are relatively more 12 reliable than are alternative fuel units. Additionally, 13 the gas fuel was readily available and inexpensive.

14 However, the movement away from total dependence on 15 gas units may dictate a change in the target level of i i

16 reserves. Non-gas units such as coal, lignite and nuclear 17 are not as reliable because of the increased complexity and 18 design involved. These units are also large in. order to 19 realize economies of scale and represent sizable shares of 20 our generating capacity. Interruptions in fuel avail-21 ability due to transportation or production dif ficulties 22 may also lessen system reliability. All these consider-23 ations may require us to maintain a higher percentage of 24 reserves in the future.

25 The target level of reserves is also influenced by 26 the uncertainty of the expected load growth in the service 27 area. Even thounh our cresent forecast indicates a ,

28 reduction in the projected load grosth from our historical IlOllSTON 1.l(.IITIN(; & l'Oh! R ros!I' \NY 1595 297 -

=- .: - _ . _ _ _

PM ;1._ . l l of 16 ..

I pattern, we anticipate that our installed capacity reserves

/ 2 will be 18.7%, 14% and 13.8% in 1980 through 1982, 3 respectively, based on our current construction program and 4 demand forecast. These reserve percentages are expressed d

5 in terms of the yearly peak load requirements. Even as 6 costly as our construction program is, we still are f511ing 7 somewhat short of our desired minimum reserve margin in 8 1981 through 1982.

9 Q. Wi!AT PLANS DOES HL&P HAVE TO DEAL WITH THESE SHORTFALLS IN ,

10 GENERATING CAPACITY?

11 A. We have previously executed a contract with the City of 12 Austin Municipal Electric System which provides that the 13 City will make available to HL&P 500 MW of capacity during 14 both 1980 and 1981. Negotiations are presently under way j

~

15 with potential suppliers to provide additional supplemental 16 power to HL&P through 1985. Additionally, evaluations are 17 being made to determine the feasibility and desirability of 18 installing short-lead-time capacity in 1982 or 1983.

19 OTHER EFFORTS TO PROVIDE RELIABLE SERVICE 20 Q.  !!R. JORDAN, HAS HL&P IMPLE!!ENTED OTHER PROGRAllS DhSIGNED TO 21 PROVIDE RELIABLE CUSTOMER SERVICE?

22 A. Yes. We have recently undergone a reorganization in the 23 customer service area and we have also embarked upon a 24 program to improve energy conservation.

25 Q. PLEASE DESCRIBE THE PURPOSE OF YOUR REORGANIZATION AND THE 26 EFFECTS IT HAS HAD ON SERVICE. ,

27 A. The purpose of the reoraanization was to enable us to 28 respond more quickly and positively to customer HOUSTON LIGilTING & POWER CoslPANY l595 298

O EXHIBIT B 1595 299

A \

Houston ComJany October 9, 1979 Electric Tower

--- RO Box M ST-HL-AE-381

' ' i g h Texas N SFN: V-0100 Director, Region IV Office of Inspection and Enforcement 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76102

Dear Sir:

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Final Report on the Essential Cooling Water Intake Structure Gantry Crane On May 16, 1979, Houston Lighting & Power Company reported to your office the failure to properly include the effects of tornado This wind loadings on the essential cooling water gantry crane.

transmittal provides a final written report as required by 10 CFR 50.55(e).

Very truly yours, A 7

2. a.'l-E. A. Turner Vice President Power Plant Construction

& Technical Services LRJ:bf Attachment 1595 J00 DUPLICATE DOCUMENT Entire document previously entered into system under:

ANO q 7 No. of pages: /