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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20127L9181993-01-26026 January 1993 NRC Staff Reply to Cfur Request for Publication of Proposed Action Re Licensing of Unit 2.* Cfur Request That Notice Re Licensing of Unit 2 Be Published Permitting Parties to Request Hearings Should Be Denied 1999-06-18
[Table view] Category:TRANSCRIPTS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
[Table view] Category:DEPOSITIONS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl 1996-07-19
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. ARIZONA PUBLIC SERVICE COMPANY
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FPC DOCKET No. E-8624 PREPARED TESTIMONY OF ROBERT M. GROSS, JR.
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1Q PLEASE STATE YOUR NAME AND ADDRESS.
2 3 A. My name in Robert M. Gross, Jr. My business address is 1000 4 Crescent Avenue, N.E., Atlanta, Georgia 30309.
5 6 Q. WilAT IS YOUR EDUCATIONAL BACRGROUND?
7 8 A. I graduated from Georgia Institute of Technology in 1965, receiving the degree of Bachelor of Industrial Engineering. I also attended 9
10 Georgia State University cnd in 1971 received the degree of Master 11 of Business Administration, majoring in finance.
12 13 Q. PLEASE STATE YOUR PROFESSIONAL EXPERIENCE.
14 15 A. I have been employed by Southern Engineering Company of Georgia for 16 approximately eight years. During this time I have been involved 17 in the preparation of cost of service studies'of investor-owned 18 utilitics, rural electric cooperatives and municipal systems and 19 have participated in wholesale rate and retail electric consulting 20 assignments in 23 states. I am a registered professional engineer 21 in the Statc. of Georgia.
22 23 Q. 11 AVE YOU EVER TESTIFIED IN OTl!ER COMMISSION PROCEEDIGGS?
24
\ 25 A. Yes, I have testified as a rate expert and cost of service witness 26 before the State Commissions of Rentucky, Indiana, Michigan, Vermont 27 and Virginia. I have also testified before the Federal Power Commis-28 sion in proceedings involving the Mississippi Power Company, FPC 29 Docket No. E-7625; Central Vermont Public Service Corporation, FPC 30 Docket No. E-7685; Appalachian Power Company, FPC, Docket No. E-7775; 31 Duke Power Company, FPC Docket No. E-7994; Gulf States Utilitics 32 Company, FPC Docket No. E-8121; and Gulf Power Company, FPC Docket No.
33 E-8911; and Appalachian Power Company, FPC Docket No. E-9101.
34 35 Q. BY WIl0M IS SOUTlIERN ENGINEERING COMPANY RETAINED IN TilIS PROCEEDING?
36 37 A. By Arizona Electric Power Cooperative, Inc. (AEPCO) and Papago Tribal 38 Utility Authority (PTU).
39 40 Q. WlIAT WAS YOUR PERSONAL ASSIGNMENT IN Tills PROCEEDING?
41 42 A. I was to determine whether Arizona Public Service Company's (APSC) 43 proposed corre.cted revised fuel adjustment clause for service to 44 AEPCO and PTU is proper. I was also to determine the reasonableness 45 of APSC's allowance for working capital as a component of rate base.
46 I was also to determine whether certain revenue and expense items 47 are proper, just and reasoncule as developed by APSC. I was to 48 furnish my determinations to Witness Chayavadhanangkur. ,
49 s 50 T9092602 Es ts J
, 1 Q. WILL YOU PLEASE SU:0!ARIZE THE RESULTS OF YOUR STUDIES.
' 2 3 A. .Yes, my studies show the following:
4 pg 5 (1) ASPC's proposed corrected revised fuel adjustment clause, 6 when applied along with the contract demand, energy, local e 7 facilities and transmissior. charges to AEPCO's and PTU's 8 monthly demand and energy usage in the test period, re-9 sults in excessive revenues charged these customers.
10 11 (2) APSC's proposed corrected revised fuel adjustment clause 12 is deficient in the following ways:
'( 13 14 (a) The failure to include nucicar fuel in the fuel cost 15 determination; and 16 17 (b) The use of average resale losses to adjust sales at 18 the transmission resale level.
19 20 (3) APSC's proposed corrected revised fuel adjustment clause 21 applicabic to AEPCO and PTU should be altered in order to 22 separately adjust for change in the cost of fuel used in 23 base load units and for changes in the cost of fuel used 24 in intermediate and peak load units, as determined by
/ 25 Witness Chayavadhanangkur.
\
26 27 (4) APSC improperly included in its rate base provisions for 28 compensating cash balance requirements as a component of 29 its working capital requirements.
30 31 (5) APSC improperly increased its operating expenses by:
32 33 (a) Normalizing wage increases and the corresponding in-34 crence in FICA payroll taxes; and 35 36 (b) Normalizing increases in property taxes.
L 37 38 Q. MR. CROSS, PLEASE DESCRIDE APSC'S PROPOSED CORRECTED REVISED FUEL 39 ADJUSTMENT CIAUSE.
40 41 A. APSC proposes to adjust the base monthly energy charge by the following:
42
, 43 CORRECTED REVISED FUEL CLAUSE 44 45 Plus r minus 0.0001 cents per kWh billed during the billing month 46 for each 0.0G01 cents per kWh by uhich the fuel cost per kWh for 47 that month exceeds or is less than the base fuel cost of 0.1822 cents 48 per kWh multiplied by the ratio of fossil fuel generation kWh to 49 deliverad kWh of the billing month, as termined by the formula:
, 50 s
t J
9 1 100 Fm - .1822 Cn1
= Adjustment in cents per kWh 2 Gm Dm 3
4 Where:
5 6 Fm = Expense to Company during the billing month of fossil fuel 7 (excluding fuel consumed for Company's specific deliveries
- 8 for which fuel costs can be determined) consumed in electric 9 generating plants owned by Company and/or supplying energy 10 to Company. (Fm to be expressed la Dollars.)
11 12 The fuel expense included in Fm shall. include no items other 13 than those allowable in Account 151 of the Federal Power 14 Commission's Uniform System of Accounts for Public Utilitics 15 and Licensees. ,
16 17 Cm = Met fossil fueled generation input to Company's system from 18 . units uhose fuel costs are included in Fm. (Gm to be ex-19 pressed in kilowatt hours.) Intent of this definition is 20 to match Gm kWh with Fm dollars.
21 22 Da = Total kUh input to Company's system for unaccounted for 23 lossce, Company use and delivered kWh, exclusive of those 24 specific delivered kWh* for uhich fuel costs were excluded 25 in Fm and Gm, all multiplied by 1 minus resale loss factor.
( 26 The resale loss fact,or is to be expressed in decimal form 27 and will be estimated when not available in the normal 28 course of business.
29 30
- Specific deliveries arc intended to include _all kWh (and 31 associated fuel expenses) out of Company's system for all 32 Interchange (including economy, deviation from schedule and 33 banked energy) plus deliveries for which the rate is tied to 34 fuel costs of specific plants or units.
35 36 Billing under this clause will preliminarily be based on the 37 billing months' sales multiplied by the adjustment factor 38 determined from a preceding month (not greater than three 39 nonths preceding the billing month). The billing thus 40 determined will be corrected to the adjustment factor de-41 termined from the billing month. Such correction vill be 42 made not later than three months after the preliminary billing.
, 43 44 This fuel clause calculates the adjustment per kWh from the c/kWh cost 45 of fossil fuel generation in the current month less the base fuel cost 46 of 0.1822c/kWh multiplied by a factor to adjust for the generation mix 47 and for resale losses. The base cost of fuel of 0.1822c/kWh is the 48 unit cost of fossil fuel generation for calendar year 1969 less the 49 then existing fuel adjustment level. Fuel expenses include the fossil 50 fuel expenses credited to Account 151.
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} 1 Q. MR. GROSS, IIAVE YOU FOR:7.D AN OPINION AS TO Tile CORRECTNESS OF APSC'S 2 PROPOSED CORRECTED REVISED FUEL ADJUSTMENT CLAUSE TO REPRESENT ONLY 3 TilF VARIATION IN CURRENT FUEL COST FROM BASE FUEL COST?
4 5 A. Yes. I will answer this question only in terms of the operation of 6 this fuel adjustment clause as a formula. The corrected revised
( 7 fuel adjustment clause proposed by APSC is an " efficiency type" ,
8 clause sluce it adjusts for changes in fuel cost per kilowatt.-hour 9 from the base period. I agree with the use of this method of deter-10 mination because it takes into account changes in system heat rate, 11 thereby passing on to the customer the effects of changes in generating 12 efficiency. I therefore have no objection to this portion of the basic
{ 13 formula as would be used in determining the fuel adjustment factor for 14 the typical resale customer purchasing all of its power requirements 15 from APSC. I do, however, disagree with APSC's application of this 16 formula, specifically in relation to their definitions of the variables 17 Fm, Gm and Dm.
18
- 19 In defining Fm, the current monthly fuel expenses, APSC has used 20 only fossil fuel costs, those allowed in Account 151, in collecting 21 charges for its fuel cost adjustment calculation. This does not con-22 form with FPC Order No. 517 which defines fuel cost as both fossil and 23 nuclear fuel cost. 1 an aware that APSC does not at present have 24 nuclear generating facilitics; it does however, have such facilitics '
25 scheduled, and presently purchases power from utilities that do have
( 26 nuclear generating facilities, ny including nuclear fuel expenses in
.i 27 the fuel cost determination, tlie definition of Gm, which is the current
, 28 monthly generation, should also be altered to include nuclear genera-29 tion.
30 31 In defining Da as the total kWh input to Company's system, ASPC 32 has made an adjustmc.it to correct for resale losses. This adjustment 33 is designed to properly apportion losses between retail and resale 34 customers. On the same basis, the resale losses should be properly 35 apportioned among the different 1cycls of resale customers, namely 36 transmission, subtransmission, distribution and other. The trans-37 mission resale customers, for which APSC experiences lower losses 38 than the subtransmission and distribution resale customers, should
. 39 not have to pay for losses incurred to deliver energy at the sub-40 transmission and distribution resale levels. Therefore, when 41 applying this corrected revised fuel adjustment clause to trans-42 mission resale customers, Da or the total kUh input to Company's
, 43 system should only be adjusted for losses at the transmission Icvel.
44 The proper level of losses recognizing deliverics to the transmission 45 resale customer is shown on Exhibit (HPil-12) , Statement M, Page 33 46 to be 4.3782%. This is compared with an overall wholesale class loss
! 47 factor of 5.8552%. Since AEpCO and PTU take service respectively at
! 48 115 kV and 230 kV, the smaller loss factor accurately reficcts l 49 operating conditions and does not burden these high voltage wholesale
! 50 customers with the cost of higher losses associated with distribution
' ( facilitics.
1 ASPC's proposed corrected revised fuel adjustment clause, with 2 my above mentioned changes included, vill conform with FPC Order No.
3 517 and be an acceptable fuel adjustment clause for the typical re-4 sale customer; such customer being one thit purchases all its power 5 requirements from the company.
6 7 Q. MR. GROSS, HAVE YOU FOPSED AN OPINION CONCERMING THE FOR'l OF AN 8 ACCEPTABLE FUEL ADJUSTMENT CLAUSE FOR AEPCO AND PTU?
9 10 A. Yes. An acceptabic fuel clause for AEPCO and PTU is shown in Exhibit 11 (RMG-1). This fuel adjustment clause makes two changes to APSC's 12 proposed corrected revised fuel adjustment clause.
13 14 Firstly, this clause differentiates between customers using 15 primarily base load facilities and customers whose load is responsibic 16 for the peak load. Thus, this fuel adjustment clause calculates an 17 adjustment f actor treighted toward changes in the cost of fuel consumed 18 in base load units. Its seen in Exhibit (RMG-1), the formula used 19 to calculate the adjustrent factor has two components; one to calcu-20 late the change in the cost of fuel consumed in base load units and 21 one to calculate the change in the cost of fuel consumed in all other 22 units. The adjustnent factor in weighted toward changes in the cost 23 of fuel consumed in base load unitr by the factor R uhich is the ratio 24 of the actual kilouatt--hours generated in the base load units to the norral kilowatt-hours generated in the same units. Secondly, this 25 26 fuel adjustment clause assigns,to AEPCO and PTU only the actual loss 27 incurred in serving them.
28 29 Thi.s fuel clause vill properly adjust for the changes in those 30 fuel expenses associated uith the energy purchased by AEPCO and PTU, 31 base load enci gy, rather than the change in total fuel expense.
32 .
33 Q. MR. GROSS, DO YOU AGREE ULTH APSC'S DEVELOPMENT OF 1TS UORKING CAPITAL 34 REQUIREMEMfS?
35 36 A. No. APSC overstated its working capital requirements and therefore 37 its rate base by the inclusion of $12,260,000 in average bank balances 38 as a component of its cash needs. This Commission has historically 39 and consistantly disallowed such balances. See the follouing Cou-40 mission cruers: Michipan-Wisconsin Pipeline Company,13 FPC 326 at 41 365 (1954), Panhandle Eastern Pipeline company vs. FPC, 235 FPC 2D606, 611 (1956), _ Knoxville Utilities Board, et al. Vs. East Tennessee 42 43 Natural Gas Company,, 35 FPC 534, 553, 554, (1966), Union Electric 44 [ompany, 47 FPC 144, (1972). In explaining Statement F, the schedule of wrhing capital, Mr. Forsberg in his direct testimony of fers no 45 46 justification or explanation for the inclusion of average cash l lance 47 requirements. Therefore, based on Cont.nission precedents and since 43 APSC does not justify their inclusion, average cash balances must '
49 be deleted from APSC's rate base for cost of service determination q 50 purposes.
. - . . = . - - . - ._. _
f k 1Q MR. GROSS, AS S110HN ON EXIIIBIT _ _(PJD-2), ENTITLED " ARIZONA -
[ 2 PUBLIC SERVICE COMPANY -- DELETION OF CERTAIN OPEPdTION AND 3 MAINTENANCE EXPENSE NOR'IALIZATION ADJUSTMENTS MADE BY APSC --
4 4 YEAR ENDED JU'IE 30, 1974", APSC UAS INCREASED ITS OPERATING 5 EXI'ENSES TO NDPJIALIZE FOR WACE AND SAIARY ISCREASES, AND IN-I 6 CREASES IN PAYROLL TAXES AND PROPERTY TAXES. DO YOU AGREE L 7 WITl! THESE ADJUSTMENTS?
8 9A No. APSC increased its operating expenses by $1,019,000 to 10 normalize vage increases in the test period and by $56,000 to j 11 correspondingly normalize increases in FICA payroll taxes asso-12 ciated uith the wage increases. As also shown, APSC increases
{
9 13 operating expenses by $1,840,000 to normalize increases in pro-f 14 pcrty taxes due to the increase in assessed value, uhich ucre
! 15 effective beginning in 1974. These normalization adjustments I 16 should not be alloucd.
! 17 18 Q HR. CROSS, Wily SIIOULD Tile NOPl!ALIZATION OF WAGE AND SAIARY 9 19 INCREASES AND PAYROLL TAX INCREASES NOT BE ALIRTED?
20 i 21 A The adjustment to normalize uage and salary increases and the l 22 related adjustment for increased FICA payroll taxes should be j 23 deleted from APSC's cost of service because the long-tera trend
! 24 of wage and salary costs per kilouatt-hour sold by APSC has i' / 25 remained reintively constant cuen though wages and salaries have 26 been increasing. Exhibit (RMG-3), entitled " Arizona Public 27 Service Company -- Analysis of salaries and Wages -- 1965 - 1974",
- 28 shous on Line 24 the total operation and maintenance expense 1 29 associated with vages and salaries, expressed in mills per kilo-i 30 watt-hour , has only experienced an average annual increase of -
31 0.64% for the ten-year period. Tne uage and salary costs per 32 kilovatt-hour sold was 2.2410 mills in 1965 compared to 2.3669 33 mills in 1974, uith both increasing and decreasing costs per 34 kilouatt-hour experienced during the ten-year period. Therefore, 4 35 APSC has experienced over the last ten years relatively constant
! 36 wage and salary costs per hilouatt-hour sold. Furthermore, Coltm:n j 37 (1), Line 1 of this Exhibit shous the energy sold by APSC has 38 increased at an annual compound rate of 8.98Z. The rate of in-1 39 creases in energy sold exceeded the rate of increases in unge 40 and salary. In my opinion the revenues co11ceted from energy l 41 sold vill more than offset the wage and salary increases, j 42 therefore APSC's uage and salary and FICA payroll tax adjust-
! 43 ments should not be.alloued.
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, 44 45 Q MR. CROSS, WlIY S110ULD TIIE NORMALIZATION OF PROPERTY TAX INCREASES 46 NOT BE ALLOWED? .
47 48 A As shown in Exhibit (RMG-4), the uholesale power supply contracts of AEPCO and PTU, the base monthly local facilitics charge and the
- 49 50 base monthly demand charge to AEPCO and PTU are subject to adjustments.
- k. 1 These adjustments are intended, among other things, to reflect 2 the ef fect on APSC's cost of service of changes in applicabic 3 state and federal income tax rates and property tax rates and/or 4 assessment ratios. In other vords, the rates charged to and the 5
revenues received from these customers are automatically in-6 creased to adjust for increases in sue.h items. narring a onc
, 7 raonth laf; in applying these adjustments, which has a rai.nimal s effect, the revenues and expenses of AEPCO and PTU are automa-9 tically matched via these adjustments. There fore , in determining 10 the cost to serve AEPCO and PIU for ratemaking purposes, the same 11 criterion ci matching revenues with expenses should be relied 12 upon to dicallou the normalizing adjust::. cut for property tax 13 increases inade by APSC. Thus, APSC should not be allowed to 14 normalize these expenses unicas, and to the extent that, they 13 exceed the increased revenues it vill realize during a normalized I f, test period for such items under the automatic adjustment clauses in its rholesale pouer supply contracts Therefore, I have excluded 17 18 the additional expense APSC creates by normali:iation of property
, 19 tax increases.
20 21 22 23 24
/ 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50
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