ML19312D783

Second Set of Addl Responses to DOJ 781130 Interrogatories, Per ASLB 780621 Prehearing Conference Directive.Includes Info Re Stagg Sys 791217 Study of Economic Evaluation of Expansion Plans Re Alternative Generation.Affidavit Encl

ML19312D783
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	02/27/1980
From:	Franklin W BAKER & BOTTS, HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	JUSTICE, DEPT. OF
Shared Package
ML19312D784	List: ML19312D783 ML19312D787 ML19312D791 ML19312D798
References
NUDOCS 8003250328
Download: ML19312D783 (4)

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@ N DOCKL"TED UNITED STATES OF AMERICA h UWRC 2 FEB 2 7192 > b NUCLEAR REGULATORY ~ COMMISSION --

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BEFORE TIIE ATOMIC SAFETY'AND LICENSING BOARD g Branch b 9 In the Matter of ) o> cn

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l!OUSTON LIGIITING & POWER ~ COMPANY ) Docket Nos. 50-498A etLa1. )- 50-499A

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(South Texas Project, Units 1 )

and 2) )

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TEXAS UTILITIES GENERATING COMPANY ) Docket Nos. 50-445A

) 50-446A (Comancho Peak Steam Electric )

Station, Units l' and 2) )

IIOUSTON LIGilTING & POWER COMPANY'S SECOND SET OF ADDITIONAL RESPONSES TO T!!E DEPARTMENT OF JUSTICE'S PIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS The Department of Justico (" Department") _ served its First Set of Interrogatories and Requests for Production of Documents to llouston Lighting and Power Company ("11ouston") and Texas Utilition Companies on November 30, 1978. IIouston filed its Objections and Answers on January 11, 1979, and filed Additional Responses on April 27, 1979. Pursuant to the directivo of the Boardfat the Juno 21, 1978 Prehearing Conference, and pursuant to General Instruction.2 of the Department's discovery requests,

-11ouston hereby supplements .its prior responses.

Interrogatory No. 4 1

.. In order of 'their relative importance, doncribe the .under- l lying 'policios or bases upon which IIL&P and TU justify their

.rofusal.to. engage in the interstate transmission or reception

~of clectrical power-or energy or to be interconnected with any other Electric.. Utility engaged in~ interstate commerce;' provide j any documents whlch-state or describe these policies or bases.  !

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s: Supplementary Answer to Interrogatory No. 4 The December 17, 1979 study entitled " Economic Evaluation of Alternative Generation Expansion Plans.for Electric Relia-bility Counc'il of Texas and Southwest Power Pool", which was performed for Houston by Stagg Systems, Inc., supplements

. houston's prior response. Houston believes that the Department has already.been furnished a copy of this report.

'Interrogatorv .~. 6 State in current dollar amounts what cost, if any, would

~be borne by HL&P and TU if ERCOT were interconnected with the Southwest Power Pool. Had these costs, if any, been calculated prior to the opening of any interconnections'on or about May 4, 1976? State'all' assumptions, underlying these calculations, who made such assumptions, the basis for such assumptions, when the calculations were made, and whether these calculations were undertaken for any purpose other than to use in this or related litigation. Provide all studies, drafts, working papers, etc.

relating to the calculations of any such costs.

Supplementary Answer to Interrogatory No. 6 See Supplementary Answer to Interrogatory No. 4, supra.

Interrogatory No. 9 (a) Identify each and every occasion, if any, upon which HL&P and/or TU communicated with West Texas Utilities Company or Central Power & Light Company the subject of possible inter-state operation by WTU or CP&L, giving the date(s) of any such ,

communication (s), the surrounding circumstances, the indidivual(s) . l so communicating, .the recipients of any such communication (s) I and the response (s) , if'any, of those recipients. (b) Provide all documents which relate to the response to~this interrogatory. l Supplementary Answer to Interrogatory No. 9 I The order of Administrative Law Judge Daniel M. Head in the proceeding Central Power and Light Company, FERC Docket No.

~EL79-8 (October 31, 1979), supplements Houston's prior response.

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A copy of the order is attached hereto as " Attachment A."

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Respectfull f ..l submitted,

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- . William J. Frafiklin Attorney-for Houston' Lighting.

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&, Power Company LOFjCOUNSEL: ,

' BAKER'& BOTTS 3000 One Shell Plaza

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- Houston', ; -Te:<as 1 77002 7

,LOWEN' STEIN, NEWMAN, REIS, AXELRAD.^&JTOLL

' 1025 Connecticut Avenue, N~.W.

._ Washing ton , .- D . C. 20036 -

~ Dated: .. February 27, 1980-v

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. STATE OF TEXAS _S S

COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY,' on'this day personally appeared ~D. E. SIMMONS, who upon his oath stated

. that he has answered the : foregoing Houston Lighting & Power

- Company's Second Set of Additional Responses to the Department of^ Justice's First Set of Interrogatories and Requests for Production of Documents in his capacity as Vice President-Engineering and Transmission and Distribution for Houston Lighting & Power Company, and all statements contained therein are true and correct.

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D. E. SIMMONSV SUBSCRIBED AND SWORN TO BEFORE ME by the said D. E.-Simmons, on this g)h E day of February, 1980.

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" MOT'si PUBLIC in and for Harr2s County, T E X A S

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