ML19224D238
| ML19224D238 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 05/24/1979 |
| From: | Copeland J BAKER & BOTTS |
| To: | |
| References | |
| NUDOCS 7907110152 | |
| Download: ML19224D238 (27) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFE'lY AND LICENSING BOARD
_a the Matter of: S S
HOUSTON LIGHTING & POWER S COMPANY, THE CITY OF SAN S NRC DOCKET NOS. 50-498A ANONTIO, THE CITY OF S 50-499A AUSTIN, and CENTRAL POWER S AND LIGHT COMPANY S (South Texas Project S Unit Nos. 1 and 2) S TEXAS UTILITIES S GENERATING COMPANY, S ET AL S NRCDOCKETNOS.f50-445A (Comanche Peak Steam S 150-446A Electric Station, S Unit Nos. 1 and 2) S HOUSTON LIGHTING & POWER COMPANY'S ADDITIONAL ANSWERS TO THE NRC STAFF'S INITIAL INTERROGATORIES TO HOUSTON LIGHTING & POWER COMPANY On January 15, 1979, the NRC Staff (" S ta f f")
filed its Initial Interrogatories and Request for Produc-tion of Documents (" Initial Interrogatories") to Houston Lighting & Power Company (" Houston") . Houston filed its answers to the Staff's Initial Interrogatories on February 20, 1979, and thereafter on March 23, 1979, the Staff filed its Response to Motion for Protective Order and Motion to Compel Further Answers ( "Mo tio n " ) directed toward Houston.
On April 12, 1979, Houston filed its Response to the NRC q
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Staff's Response to Motion for Protective Order and Motion to Compel Further Answers (" Response"), in which Houston volunteered to provide additional answers tc certain of the Staff's Initial Interrogatories, as clarified or quali-fied by the language in the Staff's Motion of March 23, 1979. Houston therefore files these Additional Answers to the Staff's Initial Interrogatories.
As requested by the staff, Houston is repro-ducing the original Initial Interrogatory before its Additional Answers. Houston is also reproducing *he relc-vant portions of the Staff's Motion of March 23, 1979, that clarify or qualify the Initial Interrogatory before the Additional Answer to which it is responsive.
Innerrogatory No. 1(g)
Initial Interrogatory 1(a). List all consultants and/or expert wit-nesses (in-house or otherwise) who may be used in the captioned NRC proceeding.
(g). For each consultant and/Jr expert wit-ness listed in (a), list each person or entity contacted by ;he consultant or expert in the course of his duties (i) for the NRC proceeding, (ii) the District Court (Dallas) antitrust proceeding, and (iii) the Texas PUC proceeding.
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(Exclude support personnel, clerical personnel, the at-torneys of record for HL&P and/or TU.)
Staff's Motion It is unclear whether Houston is responding that Mr. Gerber has not contacted any persons or entities since July of 1977 or whether it objects to producing this infor-mation. If the answer is that Mr. Gerber has not had any con'4 'ts since July of 1977, HL&P should be ordered to say so. If Mr. Gerber has had such contacts, Staff respect-fully requests that the Board overrule Houston's objection that this Interrogatory calls for information beyond that required by Rule 705 of the Federal Rules of Evidence on the ground argued above, and compel Houston te list those persons and parties with which Mr. Gerber has had contact.
Additional Answer Mr. Gerber has not had contact with any person or entity since July of 1977 upon which contact he relied in forming his expert opinions.
Interrogatory No. 2 (d)
Initial Interrogatory 2 (a) . List and explain in detail all benefits, actual or perceived, which HL&P/TU consider pertinent to, and/or relate to the decision, policy or preference to remain in intrastate commerce.
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(d). Provide all documents directly addressing the substance of this interrogatory.
Staff's Motion Houston answers in response to 2 (c)- "none" .
Staff finds it inconceivable, that Houston, which has argued repeatedly that it has fully studied the benefits and detriments of interstate commerce, should have no documents which address the benefits and detriments of interstate interconnect;ons. Staff respectfully requests this Board to order Houston to search its files again and produce those documents addressing the subject.
Additional Answer In its motion the Staff has completely changed the question. The answer to the original question was and is none. The Staff now seeks documents relating to inter-state interconnections. Houston will produce or index all documents relating to engineering and/or commercial benefits and/or detriments o" direct or indirect inter-state interconnectinns. See also the documents identified in response to CP&L Interrogatory Nos. 4, 6 in the District Court case.
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Interrogatory No. 8 ( c_)
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Initial Interrogatory 8 (c) . Does TU/HL&P contend that interconnection
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with iate.rstate utility entities can be of no assistance in terms of offering greater flexibility to alleviate capacity shortages and excesses. Explain in detail.
Staff's Motion Eouston's answer is clearle .nsufficient. Staff asked in 8 (c) what potential benefits there might be to interstate operations for Houston in the form, e.c., of
" offering greater flexibility to alleviate capacity short-ages and excesses." It did not ask for Houston's com clusion as to the merits or clemeri'ts of interstate opera-tion. . . .
Additional Answer Houston agrees that theoretically there are benefits to electric utilities from interconnections with other electric utilities, at least up to a point. Some of those theoretical benefits are reserve sharing and power exchanges. However, ERCOT includes utilities with generating capacity of 30,000 Mw, and these benefits are already available to Houston within ERCOT. Houston ?ould evaluate further interconnections by considering whether any incremental benefits are available and then by weighing such incremental benefits against the cost and reliability detriments associated with the particular interconnection scheme under consideration. In its supplemental answer to Interrogatory No. 1 of the Department of Justice's
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first interrogatories to HLaP, Houston explained the kind of studies which must be done in order to address this question.
Interrogatory No. 10 (a ) - (c )
Initial Interrogatory 10 (a) . Does HL&P/TU contend that ERCOT is pres-ently an " optimal" site?
(b). Does HL&P/TU contend that ERCOT will in the future be an " optimal" size?
(c). If the answer to either subparts (a) or (b) above is "yes," then explain in detail the basis for such contentions.
Staff's Motion Staf f objects to Houston's reference in 10 (a)-
(c) to testimony (attached as Appendix B) which is unre-sponsive to the Staff's interrogatory. Mr. Simmons' cited testimony concerned the manageability of ERCOT in emergencies. Though "optimality" includes manageability, it also includes economic and other considerations. As to these, Mr. Simmons said nothing. . . .
Additional Answer Although it is impossible to establish one
" optimal size" for interconnected utilities, Houston be-lieves that ERCOT is presently in the range of an " optimal" size, in that ERCOT is large enough to utilize the largest
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generators that the state of the art has produccd, and ERCOT is large enough to achieve the benefits of coor-dination, such as economies of scale, without the detri-ments associated with the large eastern interconnected system. Houston is not aware of any projected advance in the state of the art that will change this answer in the foreseeable future. In terms of manageability, Houston believes that ERCOT is a manageable size for planning and management and will continue to be so in the future, particularly when compared to other intercon-nected systems in L United States.
Interrogatory No. 11 Initial Interrogatory 11 (a) . In what parts of its service area is HL&P/TU experiencing the greatest load growth? (" Parts" refers to geographic locations or portions of service areas.)
(b). List any other electric utilities which have transmission or distribution planned or in place in these areas.
(c). List any entities which have challenged HL&P/TU's right to serve these areas of rapid load growth.
Staff's Motion Houston's answer is completely unresponsive to the Staff's interrogatory. The question was which geographic 73 c,
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parts of Houston's cervice area are experiencing the greatest load growth. Whether Houston's service area is compact or not, there are communities within that service area which may be growing at a faster rate than cthers.
Staff asked Houston to list those communities in decending order of load growth.. Additionally, in each community . . _ . _ .
there may be different electric utility entities with facilities adjacent to HL&P's. Staff would ask Houston to list the electric utility entities for each of those respective communities.
Additional Answer (a) Houston's records do not contain sufficient information to allow Houston to list the communities within its service area in descending order of load growth. Load growth in Houstrn's ser7 ice area has been more or less uniform, although not identical in nature. For example, commercial load growth has been graatest within the city limits of Houston, Texas. Most of HL&P's industrial load growth occurs in the Bayport, Green 3 Bayou and Houston Ship Channel areas. The greatest residential load growth is occurring in the north and west parts of Houston's service area.
(b) Electric utilities in Texas may serve only customers within their certified service areas. Thus, the only electric utilities with transmission or districut!.on g
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3 planned or in place in Houston's service area would be utilities that shared dually certified areas with Houston.
Less than 1% of Houston's entire service area is dually certified, and none of the dually certified areas are in the higher growth areas identified above.
(c) No entity has challenged Houston's right to serve within its service area.
Interrogatory No. 13 (a)
Initial Interrogatory 13 (a ) . Does the study performed by Stagg Systems
[hereinaf ter referred to as the "Stagg Study"] for HL&P constitute a commitment by HL&P to share its lowest cost fuels with other systems under central economy dispatch?
Explain in detail. (Houston and TU answer required. )
Staff's Motion Staff objects to Houston's reference to testi-many (attached in " Appendix C") which is unresponsive to Staff's interrogatory. Mr. Simmons in that testimony spoke of increased coordination, not the sharing of lowest cost fuels. . . .
Additional Answer As represented by the Stagg Study, Houston sup-ports increased coordination and exchanges of power among the utilities in ERCOT in the future, including the con-cept of central economy dispatch where feasible. In fact, n
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Houston has formally suggested to the Texas PUC that a study of central dispatch within ERCOT be undertaken.
(See HL&P's Exhibit 206 in the District Court case. ) Once the study is completed the next step toward implementa-tion of central dispatch will no doubt involve contract negotiations, with ultimate approval by the PUC being the final step.
Interrogatory No. 15 Initial Interrogatory 15 (a) . List those transactions since 1965 in whic'1 TU/HL&P has provided third-party wheeling for other entities.
(b). List those occasions on which HL&P/TU has been asked orally or in writing, to provide third-party wheeling.
(c). List and explain in detail those oc-casions on which HL&P/TU has orally or in writing declined or otherwise not been able to wheel for others.
(d). Supply all documents which relate to subparts (b) and (c) of this interrogatory.
Staff's Motion Houston's answer to the interrogatory is incom-plete. Staff cites the deposition testimony of Paul R.
Cunningham, an official of TMPP, of July 1, 1977, at 13, in West Texas Utilities Co. v. Texas Electric Service Co.,
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in which Mr. Cunningham states that he met with Mr. D. E.
Simmons (of Houston) on or about June 15, 1. i, to discuss interconnection and wheeling. A complete response to this interrogatory by Houston should refer to these dis-cussions if they did in fact occur. Staff respectfully asks this Board to compel Houston to provide such docu-mants, and to describe and " explain in detail" its nego-tiations with TMPP regarding wheeling and interconnections.
Additional Answer Mr. Cunningham (of TMPA) did discuss with Mr.
Simmons (of HL&P) the possibility of connecting the future TMPA's Gibbons Creek Power Plant to the HL&P-TPL intercon-necting line. There was no discussion then or since about
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wheeling.
Interrocatory Nos. 16 and 17 Initial Interrocatories 16 (a) . State the amounts (in MW) of installed generation reserves required to meet HL&P/TU's planning criteria for each year from 1970-1978.
(b). State the amounts (in MW) of actual installed generation reserves on HL&P/TU's system for each of the years since 1970.
(c). Specify and explain the arrangements which were entered into to dispose of any excess.
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(d) . Quantify the amount of undisposed ex-cess for each of the years since 1970.
17 (a) . Detail the arrangements which TU/HL&P have entered into to dispose of any excess capacity for each of the years from 1978 until 1987.
03 ) . Quantify the expected amount of undis-posed excess capacity for each of the years from 1978 until 1987.
Staff's Motion HL&P's answers are unresponsive to Staff's interrogatories. The question asked what amount of generation would be required i# Houston were to meet its planning criteria, and the " excess" according to Houston's criteria. Houston should at a minimum be compelled to answer this question with the amounts of generation required to meet with planning criteria. Ftaff posits the same comments regarding HL&P's answer to Staff's Interrogatory No. 17--Houston should be ordered to detail its excess capacity in terms of its planning criteria.
Additional Answer For the period from 196G through 1976, Houston sought to maintain a reserve generating capacity margin of at least 15%. In 1977, Houston followed a policy of maintaining at least a 12% reserve margin. As of 1978, Houston has sought to maintain a 15% reserve margin.
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Houston plans generation so that its planned reserves exceed the margin, but Houston does not have an upper limit on the reserves that it plans. Thus, Houston does not consider that it has had or can expect excess generation reserves above its planning criteria. Also, Houston has not made and does not now contemplate making any arrangements to dispose of any generating capacity.
The amount of reserne margin actually maintained during the years 1960 through 1976 is:
Year % Reserve
- 1960 37.30 1961 53.50 1952 28.50 1963 19.40 1964 8.14 1965 11.12 1966 15.58 1967 17.30 1968 22.91 1969 18.69 1970 10.03 1971 19.16 1972 22.71 1973 18.88 1974 26.41 1975 31.40 1976 22.30 1977 17.60 1978 18.00
- Does not include interruptible demand.
Interrogatory No. 20 (a)
Initial Interrogatory
_~ 0 ( a ) . Regarding the 1968 interconnection study performed by TU, Gulf States Utilities, and HL&P, list r,
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the individuals who participated, their company affilia-tions, titles, and responsibilities tn producing this study.
Staff's Motion Houston's answer is incomplete in that it does not, as requested, list the " responsibilities" of each designated individual "in producing this study."
Additional Answer Houston is not aware of any particular respon-sibilities that the participants had, other than to rep-resent their respective utilities in the study.
Interrogatory No. 23 (a)
Initial Interrogatory 23 (al . Explain in detail the basis for HL&P's assertion in the Texas PUC's Docket # 14 proceeding that interconnection of SWPP and ERCOT would cost Texas con-sumers $1 billion.
Staff's Motion Staff objects to Houston's reference to testi-mony in other proceedings without page references, and to undesignated exhibits. . . . Houston should be directed to directly respond to this interrogatory.
Additional Answer Houston estimated the cost to Houston of an interconnection between ERCOT and SNPP based on the O )
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following assumptions: Houston is now approximately one-third the size of ERCOT, so that during an emergency, about 35% of a generation loss would be made up by Houston on its own system and about 65% of the loss would come from other ERCOT systems and feed over Houston's lines.
If ERCOT and SWPP were interconnected, Houston's genera-tion would be less than 5% of the system, and thus about 95% of any generation loss to Houston would flow over interconnected lines to Houston. The interconnection with SWPP wculd cause an increase of 50% in the flows on the interconnected lints to Houston, thus causing Houston's bulk power system to be utilized 50% more, which would require Houston to prov_de on a continuous basis Sv? more transmissicn capacity in order to maintain the levels of transmission reliability and flexibility in use as now exists on Houston's system. Furthermore, even if such transmission capacity were to be installed, reliability of ERCOT would be degraded if ERCOT and SWPP were inter-connected as suggested in Mode 4 because of the loss of the benefits of governing action now being achieved within ERCOT.
The replacement costs in 1976 dollars for the 345 KV circu 7 in Houston's service in 1986 is $179,000,000; and the cost of providing a 50% increase in this capacity would be S90,000,000 in 1976 dollars. This volume escalated
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annually represents about S180,000,000 in 1986 dollars.
Estimating the cost of the TU companies of providing a similar 50% increase in capacity in 1986, and combining that with Houston's outlay yields $400,000,000. To develop this figure to the year 1996, it is logical to predict a needed increase in the transmission systems of the same order of magnitude as the system load growth, or 35%. Applying this to the $400,000,000 costs in 1986 yields a cost of $540,000,000 in 1986 dollars which escalated to 7% gives a figure of $1,080,000,000 in 1996.
Thus, by the year 1996, the costs of augmenting Houston's and TU's transmission systems due to a Mode 4 interconnection could be as much as $1 billion.
Mr. Simmons is among those whc have knowledge of this analysis.
Interrogatory No. 26 Initial Interrogatory State the ' equivalent forced outage rates" as defined by the EEI Prime Movers Committee currently used by HL&P/TU for planning purpcses by estimated size of anits for:
- a. nuclear power plants beginning with Comanche Peak and South Texas, and continuing to future planned units on long-range projections.
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- b. lignite plants,
- c. coal plants.
- d. gas plants.
Staf f's Motion Houston answers Staff's Interrogatory No. 26 with tables which do not, as requested, distinguish be-tween coal and lignite. It should do so.
Additional Answer The outage rates used for coal and lignite units were the same.
Interrogatory No. 32 (a)
Initial Interrogatory 32 (a) . Does HL&P/TU contend that it had no knowledge that CSW and/or its subsidiaries contemplated the integration of the CSW system prior to 1974? Explain in detail.
Staff's Motion Houston's answer is unresponsive to Staff's interrogatory. The question is whether Houston kne' of Central's contemplation to integrate its subsidiaries, not simply what Central's officers allegedly told others.
Additional Answer Houston has no way of knowing what CSW contem-plates. Houston does know that in 1945 CSW represented s 7 ')
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t- :he SEC that it was going to interconnect its four operating coupanies, but this was never done. Further-more, Houston believes that CSW would not interconnect its four companies as of now if it could solve its legal problems at the SEC witt ,ut doing so, because the inter-connection it is proposing is far less economical for its subsidiaries than increased coordination within ERCOT and SWPP.
Interrogatory No. 3 3 (b)
Initial Interrogatory 3 3 (b) . Does EL&P/TU contend that there are no opportunities for bilateral exchanges and/or coordinated Service between any intrastate-ERCOT entities in any interstate entities. Explain.
Staff's Motion Staff contends that Interrogatory 33(b) is neither unduly hypothetical nor argumentative. Staff merely asked whether Houston, by adhering to its prefer-ence for an intrastate TIS, contends that there are no opportunities for transactions over interstate intercon-nections between ERCOT and non-ERCOT entities.
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interstate interconnections between ERCOT and non-ERCOT entities," Houston believes that theoretically the answer is yes, because any two interconnected utilities may have transactions over their interconnections if there is a reason. If by " opportunities for transactions" the Staff is inquiring about anything more than the theoreti-cal possibility, Houston itself is not contemplating transactions with non-ERCOT utilities and does not have sufficient knowledge to answer for other ERCOT utilities.
Houston believes that opportunities for bilateral ex-changes and/or coordinated services are as readily avall-able within ERCOT as outside of it.
Interrogatory No. 49 Initial Interrogatory 4 9 (a) . Does HL&P/TU employ any different system design criteria for developing bulk transmission and generation than is required by TIS?
(b). If so, please explain such different criteria.
Staff's Motion Houston's answer is unresponsive to Staff's request for a listing and explanation of the differences between TIS and HL&P system design criteria. Houston indicates that there are frequent differences, but fails
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to explain those differences. It should be ordered to do so.
Additional Answer Houston plans its transmission and generation to meet TIS' criteria. Houston's planning engineers have autnority, within budget limits, to apply more stringent requirements for individual transmission lines when so required in their judgment. No formal criteria exis t for applying more stringent criteria.
Respectfully submitted,
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. Grego C land /
ttorney for Houston Lighting
& Power Company OF COUNSEL:
SAKER & BOTTS 3000 One Shell Plaza Houston, Texas 77002 (713) 229-1234 LCWENSTEIN, NEWMAN, REIS & AXELRAD 1025 Connecticut Avenue, N.W.
Washington, D. C. 20036 (202) 862-8400 rs
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3 STATE OF TEXAS S S
COUNTY OF HARRIS S BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personallv appeared D. E. SUIMONS, who upon his oath stated that he has answered the forregoing Houston Lighting
& Power Company's Additional Answers to the NRC Staff's Initial Interrogatories in his capacity as Vice Presidert of Corporate Planning for Houston Lighting & Power Company, and all statements contained therein are true and correct.
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D. E. SIMMONS J SUBSCRIBED AND SWORN TO BEFORE ME by the said D. E. Simmons, on this 4 4/ E day of May, 1979.
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NQTARY PUBLIC in and for Harris County, TEXAS
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: S S
HOUSTON LIGHTING & POWER S NRC DOCKET NOS. 50-498A COMPANY, ET AL S 50-499A (South Texas Project, S Unit Nos. 1 and 2) S In the Matter of: S S
TEXAS UTILITIES S NRC DOCKET NOS. 50-445A GENERATING COMPANY, ET AL 5 50-446A (Comanche Peak Steam S Electric Station, S Unit Nos. 1 and 2) S AFFIRMATICN OF SERVICE This is to certify that a true and correct copy of the foregoing instrument has been served upon all counsel and persons listed on the attached Service List on this the JM& day of -/274u// , 1979.
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BAKER & BoTTs SERVICE LIST Marshall E. Miller, Esquire U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael L. Glaser, Esquire 1150 17th Street, N.U.
Washington, D. C. 20036 Sheldon J. Wolfe, Esquire L. S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Chase R. Stephens, Supervisor Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Jerome D. Saltzman, Chief Antitrust and Indemnity Group U. S. Nuclear Regulatory Commission Washington, D. C. 20555 J. Irion Worsham, Esquire Merlyn D. Sampels, Esquire Spencer C. Relyea, Esquire Worsham, Forsythe & Sampels 2001 Bryan Tower Suite 2500 Dallas, Texas 75201 Jon C. Wood, Esquire W. Roger Wilson, Esquire Matthews, Nowlin, Macfarlane
& Barrett 1500 Alamo National Building . , , ,
San Antonio, Texas 78205 j f; c' (,) ,
BAKE A & BoTTs Service List Page 2 R. Gordon Gooch, Esquire Steven R. Hunsicker, Esquire Baker & Botts 1701 Pennsjlvania Avenue, N.W.
Washington, D. C. 20006 Roy P. Lessey, Jr., Esquire Michael B. Blume, Esquire U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Roff Hardy Chairman and Chief Executive Officer Central Power and Light Company P. O. Box 2121 Corpus Christi, Texas 78403 G. K. Spruce, General Manager City Public Service Board P. O. Box 1771 San Antonio, Texas 78203 Perry G. Brittain, President Texas Utilities General Company 2001 Bryan Tower Dallas, Texas 75201 R. L. Hancock, Director City of Austin Electric Utility P. O. Box 1086 Austin, Texas 78767 G. W. Oprea, Jr.
Executive Vice President Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Richard D. Cudahy, Esquire -
Joseph Gallo, Esquire O Robert H. Loeffler, Esquire n Isham, Lincoln & Beale fi-y'
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1050 17th Street, N.W., Suite 701 Washington, D. C. 20036
BAKER & BoTTs Service List Page 3 Michael I. Miller, Esquire Richard E. Powell, Esquire David M. Stahl, Esquire Thomas G. Ryan, Esquire Isham, Lincoln & Beale One First National Plaza Chicago, Illinois 60603 Don R. Butler, Esquire Sneed, Vine, Wilkerson, .
Selman & Perry P. O. Box 1409 Austin, Texas 78767 Jerry L. Harris, Esquire R chard C. Balough, Esquire City of Austin P. O. Box 1088 Austin, Texas 78767 Joseph B. Knotts, Jr., Esquire Nicholas S. Reynolds, Esquire Debevoise & Liberman 1200 Seventeenth Street, N.W.
Washington, D. C. 20036 Don H. Davidson, City Manager City of Austin P. O. Box 1088 Austin, Texas 78767 Jay Galt, Esquire Looney, Nichols, Johnson & Hays 219 Couch Drive Oklahoma City, Oklahoma 73102 Knoland J. Plucknett Executive Director Committee on Power for the Southwest, Inc.
5541 East Skelly Drive ,,
Tulsa, Oklahoma 7J.135 f: 3 /,- r-L .;
BAKER & BoTTs Service List Page 4 John W. Davidson, Esquire Sawtelle, Goode, Davidson
& Tioilo 1100 San Antonio Savings Building San Antonio, Texas 78205 Douglas F. John, Esquire Akin, Gump, Haver & Feld 1100 Madison Office Building 1155 15th Street, N.W.
Washington, D. C. 20005 Ronald Clark, Esquire Frederick H. Parmenter, Esquire Judith Linda Harris, Psquire Energy Section Antitrust Division U. S. Department of Justice P. O. Box 14141 Washington, D. C. 20044 Morgan Hunter, Esquire Bill D. St. Clair, Esquire McGinnis, Lockridge & Kilgore Fifth Floor Texas State Bank Building 900 Congress Avenue Austin, Texas 78701 W. S. Robson, General Manager South Texas Electric Cooperative, Inc.
Route 6, Building 102 Victoria Regional Airport Victoria, Texas 77901 Robert C. McDiarmid, Esquire Robert A. Jablon, Esquire Spiegel & McDiarmid 2600 Virginia Avenue, N.W.
Washington, D. C. 20036
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BAKE A & BoTTS Service List Page 5 Kevin B. Pratt Texas Attorney General's Office P. O. Box 12548 Austin, Texas 78711 William H. Burchette, Esquire Frederick H. Ritts, Esquire Law Offices of Northcutt Ely Watergate 600 Building Washington, D. C. 20037 Tom . Gregg, Esquire P. O. Box Drawer 1032 San Angelo, Texas 76902 Leland F. Leatherman, Esquire McMath, Leatherman & Woods, P.A.
711 West Third Street Little Rock, Arkansas 72201 Paul W. Eaton, Jr., Esquire Hinkle, Cox, Eaton, Coffield
& Hensley 600 Henkle Building P. O. Box 10 Roswell, New Mexico 88201 J. A. Bouknight, Esquire William J. Franklin, Esquire Lowenstein, Newman, Reis
& Axelrad 1025 Connecticut Avenue, N.W.
Washington, D. C. 20036 3 7. '.) n s .s i. t...