ML19350C758
| ML19350C758 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/17/1981 |
| From: | Ellis J Citizens Association for Sound Energy |
| To: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| Shared Package | |
| ML19350C759 | List: |
| References | |
| NUDOCS 8104060669 | |
| Download: ML19350C758 (12) | |
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UNITED STATES OF AMERICA k 4190l h S) NUCLEAR RIGUIATORY COMMISS]ON s, M 1, C".ce kQ.&lmicf the mEFORE TEE ATWIC SAFFfY AED UCENSIE 30ARD
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N, _. & In the Matter of l ,
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l Docket Bos. 50 APFLICATICE OF TEIA8 IffILITIES l c) oEnERAT:Es C m FAsr, ET AL. FOR AN l aidg $[f'
; p OPERATIED LICEBE FOR C(3dABCIE PEAK STEAM EI2CTRIC STATION l
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UNITS fl AED $2 (CPBIB) , {*. i
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CASE'S FIFTH SET OF IFfERROGATORIES Q* TO APPLICAETS AMD IEQUESTS TO PRODUCE g/ CQtBS NOli CASE (Citizens Association for Sound Energy), hereinafter referred to as CASE, Intervonor herein, and files' this, its Fifth Set of Interrogatories to Applicants and Requezts to Produce. Pureuant to 10 CFR 2.7kOb and 2 741, please answer the following interroga-tories in the manner set forth herewith. Each interrogatory should be answered fully in writing, under cath or affirmation, and include all pertinent informa.
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tion knoen to Applicants, their officers, directors or employees as well as any pertinent information known to their advisors or counsel. Each request to produce
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applies to pertinent documents which are in the nossession, custody or control of APplicants, their officers, directors or emp)Jyees as well as their advisors or counsel. Answer each interrogatory in the order in which it is asked, numbered
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to correspond to the ntamber of the interrogatory; do not ecubine answers. Please identify the person providing each answer or response. These interrogatories and requests to produce shall be continuing in nature. Thus, may time Applicaats obtain inforestion which renders any previous response
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incorrect or induates that a response was incorrect vben made, Applicants should supplement their previous response to the apprcpriate interrogatory
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or request to produce. Applicants should also supplement their responses as
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necessary with respect to identification of each person expected to be called et the hearing as an expert witness, the subject matter of his or her testimony, and the substance of that testimony. The term " documents" shall include any writings, drawings, graphs, charts, photographs, reports, studies, and other data capilations frce which infcmation can be obtained. We request that at G date or dates to be agreed upon by mutual consent, Applicants make available for inspection and copying all documents which CASE has specifically repeated cr subject to the requests set forth below. All interrogatories which do act request documents should be answered pursu-st to 10 CFR 2 7kOb(b). ' CASE'S IFTERROGATORIES AND REQUESTS M PRODUCE
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Ccntentien 25 The require =ents of the Atc=ic Energy Act, as a ended,10 CFR 50 57(a)(L) and 10 CFR SC, Appendix C, have not been =et in that the Applicant is act financially qualified to operate the preposed facility.
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Questiens 1 thrcugh 10. Ansver CASE Questions.1 through 10 ca pages 3 through 11 attached. (These are the same questicas regarding financial infor=atica which
- were asked by the GC Staff in its March 1961 letter to R. J. Gary .-- see CASE Attach =ent A to this pleading.) -
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If the infor=ation is not presently available, it is not necessary for Applicants ; to so advise CASE. It vill be satisfactory for Applicants to send us the infer =a- 1 tien requested at the same ti=e they answer the IGC Staff's March 1981 requests, j unless there are objections to any of the questions, i~n which case we request tha,. the usual time frs=e be ec= plied with under 3C Rules (10 CFR 2 7L0b(b) and 2,.7L1(d)1 The date of the IGC Staff'a request was not clear en CASE's copy; hcVever, we received cur ecpy en 3/14/61. ae therefore vould expect an answer to be filed not later than
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April 13,1981.
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REQUEST FOR FitiAf4CIAL If4FORMATI0ti CASE QUESTION NO.
- 1. a. Indicate the estimated annual cost by year to operate each unit of the subject facility for the first seven full years of' each unit's commercial operation. The types of costs included in the estinates should be indicated and include (bu't not necessarily be limited to) operation and maintenance expense (with fuel costs shown separately), depreciation, taxes and a reasonable return on investment. (Enclosed is a form which
- should be used for each year of the seven year period.)
4, Indicate the projecttd plant capacity factor (in percent) for each unit dtring each of the seven years. Previce separate estimates using 50 percent and 60 percent plant capacity factors.
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- b. Indicate the unit price per kWh experienced by each applicant on system-wide sales of electric power to all custcmers for the most recent 12-month period.
- 2. Indicate the estimated costs of permanently shutting down each unit
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of the facility, stating what is included in such costs, the assumptiens
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- CASE PAGE.3
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made in estimating the costs, tne type of shutdown contemplated, and the intended source of fundi to cover these costs.
- 3. Provide an estimate of the annual cost to maintain each unit of the
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shutdown facility in a safe condition. Indicate what is, included in the estimate, assumptions made in estimating costs, and the
intended source of funds to cover these costs. 4 If the facility is jointly-owned provide copies of the joint participation
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agreement setting forth the procedures by which the applicants will share operating expenses and dscom .sioning costs. The following financial inforration is re ed for each investor-owned participant:
- 5. Provide copies of the prospectus for the tc t rgcent security issue +
. -and cocies of the most recent SEC, Form 10-K d50-0. Provide copies of the preliminary prospectus for any i ' ding s,ecurity issue. Submit copies of the Annual Report to Stecks.v.ders each year as required by 10 CFR 50.71(b).
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- 6. Describe aspects of its regulatory environment including, but not necessarily limited to, the following: prescribed treatment of allowance for funds used during construction; rate base (original cost,-fair value, other); accounting for deferred income taxes and CASE PAGE 15
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l ! investmenttaxcredits;fueladIusthentclausesineffectorcroposed; historical, partially projected, or fully projected test year. l
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- 7. Describe the nature and amount of its most recent rate relief action (s). In addition, indicate the nature and amount of any
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l pending rate relief action (i). Use the attached fonn to provide ! - this information.
- Provide copies of the submitted, financially i
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related testimony and exhibits of the staff and company in the most.
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recent rate relief action or pending action. Furnish copies of the , hearing examirer's report and recommendation, and final opinion l last issued viith respect to eacn participant, including all financially related exhibits referred to therein. i !
- 8. Complete the enclosed form entitled, " Financial Statistics," for the most recent twelve-month period and for the , previous three w
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calendar years. .
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1.a . ATTACHMENT FOR ITEM NO.
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E5ill',ATED AfiNUAL COST OF OPERATING NUCIEAR GEtiERATIfiG UNIT: FOR THE CALENDAR YEAR 19__ (thousands of dollars) Ooeration and maintenance expenses - huclear ocwer ceneration t ' hs: lear fuel expense (plant factor i)........~...$ __ Other operating expenses . . . . . . . . . . . . . . . . . . . . . Maintenance expenses . . . . . ..'. . . . . . .. ......... ......... Total nuclear power generation . . . . Transmission expenses. . . . . . . . . . . . . . . . . . . . . . . .
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Administrative and ceneral expenses
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Property and liability insurance . . . . . . . . . . . . . . . . . Other A.&G. expenses . . . . . . . . . . . . . . . . . . . . . . . ' Total A.&G. expenses . . . . . . . . . . . . . . . . . . . .
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TOTAL 0&M EXPENSES . . . . . . . . . . . . . . . . . . . . . Depre:iation expens e . . . . . . . . . . . . . . . . . . . . . . . . . Taxes other than incere taxes Property taxes . . . . . . . . . . . . . . . . . . . . . . . . . . . Other. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '
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Total taxes other than income taxes. . . . .. . . . . .
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Income taxes - Federai . . . . . . . . . . . . . . . . . . . . . . . . I n come ta xe s - o t he r . . . . . . . . . . . . . . . . . . . . . . . . .
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Deferred income taxes - net ..................... l l l Investment tax credit adjustments - net. . . . .. . . . ........ Return (rate of return: %) . . . . . . . .' . . . . . . . . . .
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TOTAL ANNUAL COST OF OPERATION
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ATTACK:Er.T F07. It!" :... RATE DEVE!.0T".ENTS
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Ele:tric Gas Steam Grante:: Test year utilized
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Annual at unt of revenue increase requested- *
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Cate petition filed , Annual a cunt of revenue increase. allowed-
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Percent in:rease in revenues allcwed Cate of final order Effe:tive date - Rate base finding (000's) Constru:tien work in progress includen in Rate base (000's) Rate of return on rate base authcrized Rate of return en ec=en equity authorized
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Revenue Effect (CCO's)
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A.: ant re:eived in year granted A=cnt re:eived in subsequent year (If not available, annualize amounts received in year granted)
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Test year utilized -
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t A=unt (r.00's )
- Per:ent increese Date petitien filed i Date by which decisica cust be issued Rate of return on rate base requested Rate of return en co=en equity requested A::unt of rate base requested -
A=unt of construction work in progress requested for inclusion in rate base
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- ATTACH" Crit FOR ITE" 140. A FifiAt;CI A'. STATISTICS
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12 n:nths' ended (dollars in millions)
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Earnings available to comon equity Average co=en equity Rate of return on average comon equity limes total interest earned before FIT: Gross income (both including and excluding
- AFDC) + current and deferred FIT + total .
interest charges + amortization of debt discount and expense , Times long-term interest earned before FIT: Grcss income (both including and excluding AFDC) + current and deferred FIT + long-term interest charges + amortization of der,'; discount and expense . knd atings (end of period) Standard and Poor's Y.cody's _ Times interest and preferred dividends earned after FIT: Gross income (both including and excluding AFDC) + total interest charges + amortization of debt discount and expense + preferred dividends.
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AFljDC , Net income af ter preferred dividends -
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Market price of comon .
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Book value of comon Market-book ratio (end of period)* Earnings avail for comon less AFDC + depreciation and amortization, deferred taxes, and invest. tax credit adjust.- . deferred. . Co con dividends Ratio Short-term debt Bank loans '. Cwcercia1 paper Capitalization (Amount & Percent) Leng-term debt Preferred stock , Comen equity , CASE PAGE 8
- If subsidiary company, use parent's. data.
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l b CASE QUESTION 9 -- When ansveric.3, refer to ansvers as 9-1., 9-2., etc. The following financial information is required for each nunicipal applicant:
- 1. Describe the nature, amount, ratings and success of each municipal
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applicant's most recent revenue and general cbligatich bond sales. Indicate the current tota) outstanding indebtedness in each category a for each entity.
- 2. Provide copies of the offic.ial statement for the most recent bond
. issue. Provide copies of the preliminary staterent for any pending security issue. -
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- 3. Provide copies of the most recent annual financial report and the most recent interim financial state ents. Centinue to submit copies of the annual financial report for each year thereafter as
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required by 10 CFR 50.71(b). .
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- 4. Is each particoant's ;ercentage evner hip share in the facility equal to its percentage entitlement in the electrical capacity and output cf the plant? If not, explain the difference (s) and any resultant effect on any participant's . obligation to provide its share of operating costs.
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- 5. Describe the rate-setting authority of each municipal applicant and how tkat authority may be used to ensure the satisfaction of financial CASE PAGE 9
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obligations related to operating costs and eventual shutdown cess of the facility. Describe any restrictions on such rate-setting authority and how this may affect the applicant's ability to satisfy its obligations to the project. Desc-ibe the nature and amount i
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each municipal applicant's ,rpost recent rate relief action and tte anticipated' effect on reven0es. Indicate th'e nature and amount c' any pending ' rate relief action (s).
- 6. If a trembership organi:ation is participating in the joint ownerzus, explain the contractual arrangement ceeng the . members that assurs
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that funds will be available to r9eet the entity's obligations tn the project. Provide copies of the poer sales contract.
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- 7. Describe the applicant's plan for finan:ing its share of the cost of cventual shut down of the facility and t.ainte, nance in a safe ,
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shutdown ondition. .
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CASE QUESTION 10 -- When answering, refer to answers as 10-1., 10-2., etc. j The following financial inforr.ation is required for each ecoperative ;
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applicant:
- l. Is each partic pant's percentage ownership share in the facility i
equal to its percentage entitlement in the electrical capacity and output of the plant? li . Tot, explain the difference (s) and any resultant effect on any participant's obligation to provide,its share of operating costs.
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- 2. Describe the rate-setting authority and rate covenants of the co-operatives and' how that authority will be used to ensure the satisfaction of financial cbligations in relation to operation and eventual shutdcEn of the facility. .
- 3. Describe the nature and amount of the cdoperative's rOst recent l
rate relief action (s) and its anticipated effect on net margins. 1 In addition, indicate the nature and ammant of any pending rate relief action (s). ,
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- 4. If membership cooperatives are involved, explain the, contractual arrangements between the cooperative and its members that'.will l
provide funds for operation and eventual shutdcwn of the facilityi Provide representative ccpies of such contracts.
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- 5. Provide copies of the latest annual and interim financial statements.
Also provide 1 copies of similar statements for the corresponding , periods enced in the previous year. Continuetosubmitchpiesof the annual financial statements each year as,' required by 10 CFR
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I Re's pSctfully sub:nitted,
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. ( ' 1 2: w E f N 1J ps.)JuanitaEllis, President i CASE (CITIZENS ASSOCIATION FOR SOUND ENERGY) Ik26 S. Polk , Dallas, Texas 75224 21k/946-9446 ,
21k/941-12n, work,part-time,usually
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Tuesdayc and Fridays only
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3/17/81
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