ML19289D197

Initial Interrogatories to & First Request for Production of Documents by South Tx Electric Cooperative & Medina Electric Cooperative from Public Util Board of Brownsville,Tx. Certificate of Svc Encl

ML19289D197
Person / Time
Site:	South Texas
Issue date:	01/31/1979
From:	Poirier M SPIEGEL & MCDIARMID
To:
Shared Package
ML19289D196	List: ML19289D194 ML19289D197
References
NUDOCS 7902230204
Download: ML19289D197 (22)

Text

a

, UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION In the Matter of Houston Lighting & Power Company )

The City of San Antonio )

The City of Austin ) Docke t Nos. 50-498A Central Power & Light Company ) and 50-499A (South Tbxas Project, Units )

No. 1& No. 2) )

INITIAL INTERROGATORIES TO AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS BY THE SOUTH TEXAS ELECTRIC COOPERATIVE AND THE MEDINA ELECTRIC COOPERATIVE FROM THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE, TEXAS Pursuant to Sections 2. 74 0, 2.740(b) and 2.741 of the Nuclear Regulatory Commission's Rules of Practice under the Atomic Energy Act, the Public Utilities Board of the City of Brownsville , Texas ("Brownsville") hereby files initial interrogatories to and requests the production of documents by the South Tbxas Electric Cooperative and the Medina Electric Cooperative ("STEC/MEC").

I. GENERAL INSTRUCTIONS

1. Each interrogatory should be answered separately and fully in writing under oath or affirmation by the person (or persons) making it.

2. Each document produced in response to this request should be referenced with the number (s) of the relevant request and subsection, if any. Should any of the documents requested pursuant to this set of interrogatories and requests for document production have already been made available for Brownsville's inspection, it will be suf-ficient to note this fact and to provide the following in fo rmation : (1) document production number, if any; (2) 7902230aop

date, author, addressee (if any), persons receiving distribu-tion of such document or copies thereof; (3) a description of the nature of the document; and (4) the particular request and item number in response to which the document has pre-viously been produced.

3. Responses to interrogatories and requests for the production of documents shall be served upon tre following persons:

Robert C. McDiarmid , Esquire Robert A. Jablon, Esquire Marc R. Po irie r , Esquire Spiegel & Mc Diarmid 2600 Virginia Avenue, N. W.

Washing ton , D. C. 20037

4. Documents should be provided by STEC/MEC as they become available, but in any event no later than 30 days after the date of this request.

5. These interrogatories and requests for documents are of a continuing nature and require supplemental answers should STEC/MEC generate or obtain further pertinent infor-mation or documents between the time answers are filed and documents produced and the time of the evidentiary hearing.

II. DEFINITIONS A. " Documents" mean all writings and records of every type in the actual or constructive possession, control, or custody of STEC/MEC, its directors, officers, employees, con-sultants, or agents, including but not limited to contracts, memoranda, correspondence, reports, surveys, tabulations,

charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, log sheets, ledgers, transcripts, microfilm, computer printouts, vouchers, accounting state-ments, telegrams and telegraphic communications, engineering diagrams (including "one-line diagrams"), mechanical and electrical recordings, records of telephone communications, speeches and all other records, written, electrical, mecha-nical, or otherwise.

" Do c umen ts " shall also mean copies of documents, even though the originals thereof are not in the possession, custody, or control of STEC/MEC, and every copy of a document which contains handwritten or other notations, or which in any other manner does not duplicate the original, or any other copy furnished pursuant to this request.

B. " Communications" shall include, without limiting the generality of its meaning, all conversations between two or more persons either in person or by telephone, all state-ments, speeches, declarations and comments, and shall include documents as defined in II.A. above.

C. " Person" shall mean any natural person, company, association, firm, corporation, cooperative, rural electric cooperative, municipality, joint stock association, or any political subdivision, agency or instrumentality of the federal, state, or municipal governments, or a lawful asso-ciation of any of the foregoing, or any entity that produces, generates, transmits, distributes, purchases, sells, or fur-nishes electricity.

D. " Identify," when used with respect to documents, means that the type, author, recipient (s) of the Original, recipient (s) of copies, date, and subject of the document should be specified.

" Identify," when used with respect to communications, means that the type of communication, maker of the com-munication, persons communicated to, persons for whom the communication was intended, date and subject of the com-munication should be specified.

" Identify," when used with reference to any cor-poration, association, cooperative, or other legal entity, means to state the name and current address of said organiza-tion or entity; if the current address is unknown, provide the last known address.

" Identify," when used with respect to any person, means that the person's name, current business address (or current mailing address for persons now retired), current job title, and employer, should be specified. If the current address is unknown, please provide the last known address.

Where more than one request in this series asks for identification of a document, communication, legal entity, or person, in response to the second and subsequent requests, please provide the name of a corporation, legal entity or person, oy the date and author or maker of a document or communication, along with a reference to the response in which a full identification was provided.

E. " Representative" shall be understood to include, without limiting the generality of its meaning, any director, officer, employee, contractor, or consultant, of any person as defined in II.C., who at a particular formal or informal meeting, or in a particular document or communication, appears to participate in the meeting, or in the making of or the receipt of the document or communication, on behalf of or as agent for, said person. Whether or not a representative has actual authority as an agent of the person is irrelevant to his or her status as a representative.

F. " Rela ting to" or " relate" means consisting of, referring to, reflecting, or being in any way legally, logically or factually connected with. Requasts " relating to" a sub-ject or item should be understood to include possible or con-templated actions as to such subject or item. For example, a request for documents relating to interconnection plans would include documents relating to interconnection arrangements that have been considered but rejected.

G. " Electric utility" means a private corporation, cooperative, rural electric cooperative, municipality, joint stock association, or any political subdivision, agency or instrumentality of federal, state, or municipal governments, or a lawful association of any of the foregoing that owns, controls, or operates, or proposes or is studying the possi-bility of owning, controlling, or operating, facilities for the generation 2 transmission and/or distribution of electricity.

H. " Transmission services" shall mean the undertaking by a utility to transmit power and/or energy for any other electric utility, whether the power and/or energy is generated by the first utility or by any other electric util-ity. " Transmission services" shall also include the sale by a utility of transmission capacity without energy.

" Transmission services" include wheeling.

I. " Interconnection" shall mean the physical junction of the electric transmission systems of two or more electric utilities so that electricity may flow over the junction according to location of points of power generation and power usage, in the same manner as electricity flows over the lines of an individual electric system. A junction nor-mally maintained in an open position is considered an inter-connection. A j unction by which a lower voltage system is joined to a transmission line through a transformer is con-sidered an interconnection.

" Interconnected operation" between two or more electric utilities shall mean a method of operation in which electri-city flows over interconnections between the electric transmission and/or subtransmission systems of the electric utilities in the same manner as electricity flows along the lines of an individual electric system, whether or not such flow of electricity occurs pursuant to the terms of an inter-connection agreement. " Interconnected operation" includes all forms of interchange, including sales, purchases or exchange of energy or capacity, reserves sharing, firm power, emergency, maintenance, seasonal, economy exchange, spinning

reserves and any sin.ilar transactions.

" Interconnection agreement" shall mean an agreement governing the rates, metering, and other terms and conditions under which interconnected operation occurs.

J. " South Texas Electric Cooperative and Medina Electric Cooperative" or "STEC/MEC" shall mean the present entities and their predecessors. Where a request cannot be answered with respect to STEC/MEC as a whole, please respond separately for South Texas Electric Cooperative and for Medina Electric Cooperative.

K. " Central Power & Light Company" or "CP&L" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated or predecessor companies and any entities providing electric service at wholesale or retail, the pro-parties or assets of which have been acquired by CP&L.

L. " Houston Lighting & Power Company" or "HL&P" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by HL&P.

M. " Texas Power & Light Company" or "TP&L" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by TP&L.

N. " Dallas Power & Light Company" or "DP&L" shall be understood to include its parent, direct or indirect subsidiary

affiliated, or pre'ecessor companies and any entities pro-viding electric service at wholesale or retail, the prcper-ties or assets of which have been acquired by DP&L.

O. " Texas Electric Service Company" or "TESCO" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by TESCO.

P. " West Tbxas Utilities" or "WTU" shall be understood to include its parent, direct or indirect subsidiary, affil-iated, or predecessor companies and any entities providing electric service at wholesale or retail, the properties or assets of which have been acquired by WTU.

O. " Southwestern Electric Power Company" or "SWEPCO" shall be 'nderstood to include its parent, direct or indirect subsidiary, affiliated, or predecessor companies and any entities providing electric service at wholesale or retail, the properties or assets of which have been acquired by SWEPCO.

R. "Public Service Company of Oklahoma" cr "PSO" shall be understood to include its parent, direct or indirect sub-sidiary, affiliated, or predecessor companies and any enti-ties providing electric service at wholesale or retail, the properties or assets of which have been acquired by Public Service Company of Oklahoma.

S. " Central & South West Corporation" or "CSW" shall be understood to include its parent, direct or indirect subsidiary, affiliated, or predecessor companies and any entities pro-viding electric service at wholesale or retail, the proper-

ties or assets of which have been acquired by CSW.

T. " Texas Utilities" or "TU" shall mean Texas Utilities Generating Company, its parent, affiliated, direct or indirect subsidiary and all predecessor companies, including, but not limited to, Texas Utilities Company, Dallas Power &

Light Company, Texas Electric Service Company and Texas Power

& Light Company.

U. " South Tbxas Units" shall be understood to refer to the nuclear generating units for which applicants in the above-captioned proceeding hold construction permits from the Nuclear Regulatory Commission.

III. DOCUMENTS NO LONGER IN STEC/MEC'S POSSESSION, CUSTODY, OR CONTROL If any document otacrwise responsive to any request was, on or af ter December 19, 1370 (date of enactment of P. L.91-560), but is no longer in STEC/MEC's possession, or subject to STEC/MEC's control, or in existence, state whether (1) it is missing or lost, '2) has been destroyed, (3) has been trans-ferred voluntarily to others, or (4) has been otherwise disposed of. In each instance, explain the circumstances surrounding such disposition and identify the person (s) directing or authorizing its destruction or transfer, and the date(s) of such direction or authorization. Identify each such document by listing its author and addressee, type (e.g., letter, memorandum, telegram, chart, photograph, etc.), date, subject matter, whether the document (or copies) are still in existence, and if so, their present location (s)

and custodian (s).

IV. SCOPE OF PRODUCTION Each paragraph below, unless otherwise specified, refers to all documents made, sent, dated or received from January 1, 1965 to date, in STEC/MEC's possession, custody, or control, and to all communications of which STEC/MEC is aware made and/or received from January 1, 1965 to the pre-sent.

V. DOCUMENTS WITHHELD AS PRIVILEGED If any documents within any description set out below are withheld by reason of any assertion of privilege, iden-tify each such document by date, description, and type, iden-tify all persons preparing and/or receiving each document, and state the privilege asserted, and the reasons that, in STEC/MEC's opinion, justify the assertion of privilege as to each doc umen t .

VI. INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS

1. Please respond to the parts of interrogatory 1 separately for:

(i) Electric Reliability Council of Tbxas ("ERCOT")

(ii) Texas Interconnected System (" TIS")

(iii) South Tbxas Interconnected System ("STIS")

(a) Are STEC/MEC members of any of (i)-(iii)?

(b) Please describe each formal or informal application or inquiry by STEC/MEC relating to membership by STEC/MEC in any of (i)-(iii). Include the date of each inquiry or appli-cation, and the date and substance of each response by any

person to each inquiry or application. Please produce all documents related to each such inquiry or application. This request includes all formal and informal applications up to and including the application (if any) that resulted in STEC/MEC's membership in each of (i)-(iii) above.

(c) Describe the application procedure at the time STEC/MEC was admitted to membership in any of (i)-(iii) above. Describe the application procedures at any earlier time (s) that STEC/MEC inquired about or applied for mem-bership in any of (i)-(iii) above. Describe any difficulties STEC/MEC had at any time in becoming a member of any of (i)-

(iii) above.

(d) Has STEC/MEC ever attempted to initiate, influence, or change policies, procedures, or actions of any of (i)-

(iii) above of wich it was a member? Describe each such attempt, including the date of STEC/MEC's action (s) and the substance of each such action, and the date, fo rmat , and substance of each response by any person to each such attempt. Indicate whether each such attempt was successful.

Please produce all documents relating to each such attempt.

2. Please produce all documents relating to:

(a) membership in ERCOT by any electric utility other than STEC/MEC; (b) membership in TIS by any electric utility other than STEC/MEC; (c) membership in STIS by any electric utility other than STEC/MEC; (d) participation in South Texas by any electric uti-lity.

3. Please respond to question 3 if STEC/MEC is or ever has been a member of bRCOT.

(a) What is the purpose of ERCOT? Describe fully the functions of ERCOT, both formal and informal, with respect to the following areas:

(i) planning for construction of new generation facili-ties by any member electric utilities:

(ii) planning for construction of new transmission faci-lities by any member electric utilities; (iii) spinning reserves of any member electric utility; (iv) central dispatch among any or all member electric utilities; (v) fuel acquisition by any or all member electric utilities; (vi) interconnected operation by any or all member electric utilities.

(b) Describe fully the way in which STEC/MEC is effected by, or takes into account, the activities and/or decisions of ERCOT with respect to each of areas (i) through (vi) listed in (a) above.

(c) Produce all documents relating to (a) or (b) above.

4. Produce all documents relating to the purchase and/or sale of bulk power and/or energy by STEC/MEC. Exclude billing log data.

5. Please produce all documents relating to arrange-ments, both actual and contemplated, between STEC/MEC and any other electric utility, relating to capacity or energy

actually or potentially generated at the Falcon Dam, the Amistad Dam and/or any other hydroelectric generating faci-lity, including but not limited to the acquisition, use, scheduling, transmission, sale, purchase or firming of such power, whether provided by STEC/MEC or others.

6.(a) Please describe fully each use by STEC/MEC of transmission facilities owned jointly by STEC/MEC and other persons, and of transmission facilities owned entirely by others. This request includes both actual and potential uses.

(b) Has STEC/MEC ever had difficulty in obtaining access to transmission services provided by other persons, or to transmission facilities owned by other persons? Please describe fully each such instance of difficulty of access.

(c) Please describe each instance, actual or potential, of construction, by any person other than STEC/MEC or a person under STEC/MEC's control, of additional transmission facili-ties, or of increasing the capacity of existing transmission facilities owned in whole or in part by any person other than STEC/MEC, for the purpose of providing transmission services to STEC/MEC.

(d) Please provide all documents relating to any of (a)-(c) above. Exclude routine back-up engineering docu-ments, accounting documents, unimportant duplicates, and incidental documents that do not relate to policy of any per-son and do not have significance in terms of decisions affecting use of transmission facilities or capacity or construction of transmission facilities.

7. Tb the extent not otherwise provided or supplied in response to this interrogatory and data request, or to pre-vious related interrogatories and data requests, please pro-duce all documents relating to interconnection and/or inter-connected operation of STEC/MEC with any other electric utility.

Exclude routine billing and log data.

8. Please produce copies of all interconnection agreements entered into between STEC/MEC and any other party.

9.(a) Please produce all documents relating to par-ticipation, actual, planned or potential, or to establishing terms for any participation, by STEC/MEC in any generation facility.

(b) Please produce all documents relating to joint par-ticipatior., actual planned, or potential, or to establishing terms for any participation, by any other electric utility in any generation facility of which STEC/MEC is whole or part owner.

(c) Please produce all documents relating to joint par-ticipation by STEC/MEC and any other electric utility in any research, study or project relating to the use of geothermal, biomass, lignite or solar energy as an actual or potential source of electric ruwer.

10.(a) Please produce all documents relating to any attempt, whether actual or contemplated, by any person to acquire or to lease, either in whole or in part, the electric facilities of STEC/MEC or any other municipally or cooperatively owned and/or operated electric utility. The scope of this request is from January 1, 1957 to the present.

(b) Identify any communications of which STEC/MEC is aware by any person relating to any acquisition or lease attempt referred to in (a) above. Please provide all docu-ments relating to each such communication. If documents pro-duced fully identify and dascribe the substance of a par-ticular communication, no further response is required with respect to that particular communication.

11. Please produce rates of STEC/MEC for all classes of customers since January 1, 1970.

12. Has STEC/MIC ever received an offer of a special rate or individually designed rate for any form of power and/or energy purchase since January 1, 1957? Please produce all documents relating to each such offer or rate, or poten-tial offer or rate. Exclude routine billing documents from this request.

13. Please state all reasons STFC/MEC has considered for and against operating in interstate commerce. Please produce principal documents related to each such request.

14.(a) Please identify all fuel contracts in effect at any time from January 1, 1972 to the present. Please include expiration dates and renegotiation dates for all such contracts. Please produce all such contracts.

(b) Please provide the unit cost of power or energy purchased from any other electric utilities, by utility and by month, from January 1, 1972 to date. Please list cost of demand and energy separately. Please list separately or item-ire each type of power produced, e.g., firm power, economy power, scheduled maintenance power, etc.

(c) Please provide the average fuel cost in mills /kwh of self-generated energy by month from January 1972.

(d) Please provide the average unit price of energy by month from January 1972 to date. Exclude any demand fixed Costs.

(e) Please produce load duration curves by day and week for the winter and summer peak period for each yar from 1972 to date. Please include both actual load duration curves and those depicting projected load duration through 1990, if available, prepared from 1972 to date.

(f) Please produce projected mill rate dispatch tables from 1972 through 1990.

(g) Please produce copies of the FERC Form 423 or simi-lar reports from its inception to date. For periods from January 1972 to date for which a Form 423 is unavailable, please produce copies of any report or reports made to the Texas Public Utilities Commission or its predecessors that contain equiv'alent information.

(h) Please produce copies of the FERC Form 1 or similar reports from 1972 to the present. For any year within this period for which no Form 1 is available, please produce copies of any report or reports made to the Tbxas Public Utilities Commission or its predecessors that contain equiva-lent information; and in any event provide, from whatever source, information equivalent to that contained on the following FERC Form 1 schedules:

422-423 purchased power 424 interchange power 425 transmission by or for others 431 electric energy account; monthly peaks and output 432-441 generating plants 442-444 transmission line statistics; transmission added during the year 445 substations (i) Please produce copies of the FERC Form 12 or simi-lar reports from 1972 to the present. For any year within this period for which no Form 12 is available, please produce copies of any report or reports made to the Texas Public Utilities Commission or its predecessors that contain equiva-lent information; and in any event provide, from whatever source, information equivalent to that included on the following schedules of FERC Form 12:

1 capacity and output of system generating plants 2 system hydroelectric data 3 plant data - small plants 4 hydroelectric plant data 4-A pumped storage plant data 5 steam-electric, including nuclear, plant data 7 internal-combustion engine and gas-turbine plant data 8 itemized accounting of energy transfers

9 system energy accounting for the year 18 system maps and diagrams (j) Please provide load flow diagrams for the main transmission system from 1972 to date, including summer peak, winter peak, and a typical off-peak period.

15.(a) To the extent not produced or previously supplied in response to this interrogatory and data request, or to previous related interrogatories and data requests, please produce all documents relating to actual, potential, possible or contemplated competition between STEC/MEC and any other electric utility.

(b) Please identify all communications between any officer or representative of STEC/MEC and any other per-son, relating to competition as described in (a) above.

Please produce all documents related to each such com-munication. If documents produced in response to this interrogatory and data request, or to previous related interrogatories and data requests, fully identify and describe the substance of a particular communication, no further information is necessary with respect to that par-ticular communication.

16. Please furnish a copy of all STEC/MEC's responses to interrogatories and document requests submitted to S"."C/M EC in the instant proceeding by any other party, including all schedules, exhibits, appendices, attachments, and collections or compilations of documents.

17. Please update responses to hil interrogatories and data requests received by STEC/MEC in this proceeding or in any related proceeding (listed at pages 6-7 of the Special Prehearing Conference order of July 13, 1978 in the above-captioned proceeding), the discovery of which has been ordered to be treated as part of the discovery in this proceeding.

18. Please identify the persons who prepared or assisted in the preparation of STEC/MEC's response to each of the L'oregoing requests.

Respectfully submitted ,

OA (

Marc R. Poirier Attorney for the Public Utilities Board of the City of Brownsville, Texas Law Of fices of:

Spiegel & Mc Diarmid 2 600 Virginia Avenue , N. W.

Washington, D. C. 200374

UNITED STATES OF AMERICA

. BEFORE THE NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

Houston Lighting & Power Company ) Docke t No s . 50-498A The City of San Antonio ) and 50-499A The City of Austin )

Central Power & Light Company )

(South Texas Project, Unit Nos. )

1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that I have caused a copy of the foregoing INITIAL INTERROGATORIES TO AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS BY THE SOUTH TEXAS ELECTRIC COOPERATIVE AND THE MEDINA ELECTRIC COOPERATIVE FROM THE PUBLIC UTILITIES BOARD OF THE CITY OF BROWNSVILLE, TEXAS in the above-captioned proceeding to be served on the following by deposit in the United States mail, first class, postage prepaid, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission internal mail system, this 31st day of January, 1979.

• Marshall E. Miller, Chairman Joseph J. Saunders, Esquire Atomic Safety & Licensing Board Chief, Public Counsel &

Panel Legislative Section Nuclear Regulatory Commission Department of Justice Washington, D. C. 20555 P. O. Box 14141 Washington, D. C. 20044 Sheldon J. Wolfe, Esquire Atomic Safety & Licensing Board Joseph Gallo, Esquire Panel Richard D. Cudahy, Esquire Nuclear Regulatory Commin sion Robert H. Eceffler, Esquire Washing ton , D. C. 20555 Isham, Lincoln & Beale Suite 701 Michael L. Glaser, Esquire 1050 17th Street, N. W.

1150 17th Street, N. W. Washington, D. C. 20036 Was hing ton , D. C. 20036 John D. Whitler, Esquire Joseph Rutberg, Esquire Ronald Clark, Esquire Antitrust Counsel Department of Justice Counsel for NRC Staff P. O. Box 14141 Nuclear Regulatory Commission Washington, D. C. 20044 Washington, D. C. 20555 Joseph Knotts, Esquire Chase R. Stephens, Chie f Nicholas S. Reynold s , Esquire Docketing and Service Section Debevoise & Liberman Of fice of the Secretary 1200 17th Street, N. W.

Nuclear Regulatory Commission Washington, D. C. 20036 Washing ton , D. C. 20555

Douglas F. John, Esquire Josep? I. Wo rsham, Esquire Akin, Gump, Hauer & Feld Merlyn D. Sampels, Esquire 1100 Madison Office Building Worsham, Forsythe & Sampels 1155 15th Street, N. W. 2001 Bryan Tbwer, Suite 2500 Wa shing ton , D. C. 20024 Dallas , Texas 75201 R. Gordon Gooch, Esquire Spencer C. Relyea , Esquire John P. Mathis, Esquire Worsham, Forsythe & Sampels Baker & Bo tts 2001 Bryan Tbwer, Suite 2500 1701 Pennsylvania Avenue , N. W. Dallas , Texas 75201 Washington, D. C. 20006 R. L. Hancock, Director Robert Lowens te in , Esquire City of Austin Electric J. A. Bouknight , Jr. , Esquire Utility Department Lowenstein , Newman , Reis & P. O. Box 1088 Axelrad Austin, Texas 78767 10 25 Connecticut Avenue , N. W.

Washing ton , D. C. 20036 Jerry L. Harris, Esquire City Attorney William J. Franklin, Esquire City of Austin Lowenstein, Newman , Reis & P. O. Box 1088 Axelrad Austin, Texas 78767 1025 Connecticut Avenue, N. W.

Washing ton , D. C. 20036 Richard C. Balough, Esquire Assistant City Attorney Frederick H. Ritts, Esquire City of Austin Law Of fices of Northcutt Ely P. O. Box 1088 Watergate 600 Building Austin, Texas 78767 Washington, D. C. 20037 Dan H. David son Wheatley & Miller City Manager 1112 Watergate Office Building City of Austin 2600 Virginia Avenue , N. W. P. O. Box 1088 Wash ing ton , D. C. 20037 Austin , Texas 78767 Roff Hardy, Chairman and Chief Don R. Butler, Esquire Executive Officer Sneed, Vine, Wilkerson, Selman Central Power & Light Company & Perry P. O. Box 2121 P. O. Box 1409 Corpus Christi, Texas 78403 Austin, Texas 78767 G. K. Spruce , General Manger Morgan Hunter, Esquire City Public Service Board McGinnis, Ecchridge & Kilgore P. O. Box 1771 900 Congress Avenue San Antonio, Texas 78203 Austin, Tbxas 78701 Jon C. Wood, Esquire Kevin B. Pratt, Esquire W. Roger Wilson, Esquire Assistant Attorney General Matthews , Nowlin, Macfarlane P. O. Box 12548

& Barrett Capital Station 1500 Alamo National Building Austin, Tbxas 78711 San Antonio, Te xas 78205 Linda L. Aaker, Esquire Perry G. Erittain, President Assistant Attorney General Texas Utilities Generating P. O. Box 12548 20bS"O! yen Tbwer k$$kk$ hesak"78711 Dallas , Texas 75201

, L 3-E. W. Barnett, Esquire John E. Mathews, Jr., Esquire Charlec c- 3 rash, Jr., Esquire Mathews, Osborne, Eh rlich ,

Baker & Bo tts McNatt, Gobelman & Cobb 3000 One Chell Plaza 1500 American Heritage Life Bldg.

Houston, Texas 77002 Jacksonville, Florida 32202 J. Gregory Copeland , Esquire Robert E. Bathen Theodore F. Weiss, Jr., Esquire R. W. Beck & Associaces Baker & Botts P. O. Box 6817 3000 One Shell Plaza Orlando, Florida 82803

. Houston, Texas 77002

, Somervell County Public Library G. W. Oprea, Jr. P. O. Box 417 Executive Vice President Glen Rose , Texas 76403 Houston Lighting & Power Company P. O. Box 1700 Maynard Human, General bbnager Houston, Tbxas 77001 Western Farmers Electric Coop.

P. O. Box 429 W. S. Rob son , General Manager Anadarko, Oklahoma 73005 South Texas Electric Cooperative, Inc. James E. Monahan Route 6, Building 102 Executive Vice President and Victoria Regional Airport General manager Victoria, Texas 77901 Brazos Electric Power Coop. , Inc.

P. O. Box 6296 Michael I. Miller, Esquire Waco, Texas 76706 Richard E. Powell, Esquire Isham, Lincoln & Beale Judith Harris , Esquire One First National Plaza Department of Justice Chicago, Illinois 60603 P. O. Box 14141 Washington, D. C. 20044 David M. Stahl, Esquire Thomas G. Ryan, Esquire

• Jerome Saltzman, Chief Isham, Lincoln & Beale Antitrust & Indemnity Group One First National Plaza Nuclear Regulatory Commission Chicago, Illinois 60603 Washing ton ; D. C. 20555 Knoland J. Plucknett Executive Director Committee on Power for the Southwest, Inc.

5541 Skelly Drive Tulsa, Oklahoma 74135 Jay M. Gal t , Esquire Looney, Nichols, Johnson &

Hayes 219 Couch Drive Oklahoma City, Oklahoma 73101 Marc'R. Poirie r Attorney for the Public Utilities Board of the City of Brownsville, Texas