ML20147E372
| ML20147E372 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1978 |
| From: | Evans D, Goldberg J, Vogler B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| PROJECT-564M NUDOCS 7812210057 | |
| Download: ML20147E372 (11) | |
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. s UNITED STATES OF AMERICA %CfC
/L f NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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PACIFIC GAS AND ELECTRIC ) NRC Docket No. P-564A COMPANY ) '
(Stanislaus Nuclear Project, ) ,
Unit No.1) )
NRC STAFF'S FIRST SET OF SUPPLEMENTAL , ,.
INTERR0GATORIES PROPOUNDED TO PG&E The NRC Staff hereby propounds the following interrogatories to Applicant Pacific Gas and Electric Company pursuant to 10 C.F.R. 52.740b.
A. INSTRUCTIONS
- 1. Answer the following interrogatories separately (by parts) , -
and fully in writing under oath or affirmation. If any interrogatory or part thereof is objected to, state separately (by part) and fully the objection and the reasons therefor.
- 2. If any questions arise concerning the meanin5 or interpretation .,
of any words or phrases contained herein, or concerning the substance of information sought or the manner of complaince, please contact Counsel for the NRC Staff immediately so that we may clarify the matter. -
The Staff is ready to cooperate with PG&E in expeditiously obtaining '.
this information with the minimum burden on PG&E.
3 Counsel for PG&E represented to the Staff in our meeting in San Francisco on November 14-15, 1978, that PG&E would furnish the -
Staff and Intervenors with the information sought by paragraph 17 of the .
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January 18, 1978, Order Concerning Production of Documents. That ,g information, as well as other information, is requested by Interrogatory qS1221 0 A - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _
1 infra. It is certainly not our intent to receive the same infor-mation more than once. We therefore intend that the paragraph 17 information be furnished as part of PG&E's response to these interrog-atories, y
- 4. At the November 14-15th meeting, PG&E refused to separately .
provide the information requested by paragraphs 20 and 28 of the Document Production Order. These interrogatories solicit that and other information.
B. DEFINITIONS
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- l. " Retail service area" means that area within the exterior geographic boundaries of the several areas electrically served.at retail by PG&E.
- 2. " Wholesale service area" means that area within the exterior geographic boundaries of the several areas electrically served at wholesale by PG&E.
- 3. " Service area" means that area within the exterior geographic boundaries of the several areas electrically served at either retail or wholesale or l
both by PG&E.
- 4. " Reserves for PG&E's own, or native, load" means, at the time or for the period in question, the sum of (1) the net capacity output actually 1
available from each generating unit owned or contractually committed to PG&E, plus (2) all generating capacity made available to PG&E from other l electric utilities, less (3) the sum of (1) the demand placed upon PG&E by its retail and wholesale customers (deducting any credits for capacity not used in calculating (2) above given any curtomer or system),plus (ii) PG&E's capacity obligations to others, plus (iii) PG&E's transmission and distri-bution losses, plus (iv) unaccounted for capacity.
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C. . INTERROGATORIES
- 1. State, det,cribe, or show by rppropriately drawing, marking, and labelling on PG&E's map number 52532 (PG&E discovery document number LRT 568674), or its equivalent, the following: j f
(a) (1) The boundary of PG&E's retail service area;
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(b) PG&E's transmission a1d sub-transmission lines with Yoltage identification of all trar.; mission lines between 69 kv and 500 ky, [
including all d.c transmission lines and their voltages; (c) The location of all of PG&E's generating stations, plants, and units, identifying each by name, number, primary fuel type, and size (net and gross capacity);
(d) PG&E's planned transmission lines 115 kv and above, identi-fying the expected year of operation and operating voltage of each trans- .
mission line (These transmission lines should be shown up to and including i
PG&E's best estimate of the year when the Stanislaus Nuclear Units are expected to begin operation);
(e) The location of PG&E's planned generation stations, plants and unit additions, identifying each by name, number, expected primary fuel type, and size (net and gross capacity); _
(f) The identity of all other electric utilities operating or i
serving, at wholesale or retail, wholly or partially, within PG&E's service araa boundary or within 100 miles of PG&E's service area boundary, and for each (except for Southern California Edison Company and Los Angeles Department of Water and Power) identify:
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l (1) the boundary of its service area; .
(ii) the location of its generating stations, plants, and units in California, stating each by name, number, primary fuel l 1
J type, and size (net and gross capacity);
(iii) its transmission and subtransmission lines in California with voltage identification of all transmission lines between 69 ky and 500 kv; and
.(g) The location of all of PG&E's interconnections, connections, and delivery points, with each and every other electric utility.
- 2. (a ) State PG&E's definition, understanding, or use, of the term " control area". If PG&E has no definition, understanding, or use, of the term " control area", so state. If PG&E has no definition, under-standing, or use, of the term " control area", then the following definition will be applicable to succeeding interrogatories:
" Control area" means all or part of PG&E's owned, leased, or operated electric generating and transmission facilities, or a com-bination of these facilities with such facilities of one or more other companies operated under common generation control.
1] Adapted from appendix definitions 1 and 7 of the Seven Parties Agreement, pages' 17 and 18.
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I (b) State PG&E's definition, understanding, or use, of the term " spinning reserves". If PG&E has no definition, understanding or use, of the term " spinning reserves, so state.
(c) State PG&E's definition, understanding, or use, of the term " standby reserves" . If PG&E has no definition, understanding ,
or use, of the term " standby reserves", so state.
(d) State PG&E's definition, understanding, or use, of the l term "on-line reserves". If PG&E has no definition, understanding or use, of the term "on-line reserves", so state.
(e) State PG&E's definition, understanding, or use, of the term " load dropping ability". If PG&E has no definition, understanding
, or use, of the term " load dropping ability", so state.
(f) State PG&E's definition, understanding, or use, of the 't term " operating reserves". If PG&E has no definition, understanding or use, of the term " operating reserves", so state.
(g) State whether or not PG&E has used or does use any other ,
type of reserves other than those specified above in parts (b) through (f),
and whether or not PG&E has used or does use any type of reserves defined, understood, known, or used, by PG&E with any name, label or designation, other than those specified above in parts (b) through (f) above. Identi fy each such type and for each type identified, state PG&E's definition, understanding, or use.
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- 3. For each of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the day on which PG&E's control area annual peak load occurred for each year beginning in 1973 to the l present, inclusive, separately state:
(a) The total control area load;
'(b) The capacity contribution of PG&E to supplying this load; (c) The identification and capacity contribution of each gener-ating unit wholly owned by PG&E to supplying this load;
-(d) The individual capacity contribution of each and every other electric utility to supplying this load; ,
(e) The amount and source of PG&E's reserve capacity in each of the following categories:
(i) Total reserves available for the control area,
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identifying each generating unit contributing to the total reserves by name, owner and amount of contribution; if PG&E c1himsany reserve capacity not identified with a particular generating units, so state the amount and source of such reserves; (ii) Reserves for PG&E's own, or native, load; (ift) Spinning reserves for the control area; (iv) The portion of reserves for PG&E's own, or nat;ve, load which is spinning reserves; (v) Standby reserves for the control area; ;
(vi) On-line reserves for the control area; (vii) Operating reserves for the control area; 6.. .
l (viii) Load dropping ability for the control area; i (ix) Reserves available from other electric utilities by type, amount, and supplier; (x) Any other reserves, identified in answer to interrog- J 1
atory 2(g) above, used by PG&E, by type, amount, and supplier, (f) The megawatt flow on each transmission tie into or out of the control area, denoting direction of flow; (g) The amount of capacity sold to others, denoting each amount and each purchaser; (h) The amount of capacity purchased from others, denoting !
each amount and each seller; (1) The amount of capacity exchanged with others,. denoting each amount and each party; ,
(j) The amount of capacity put into or taken out of any capacity banks, denoting each transaction and each party.
- 4. For each of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the day on which PG&E's control araa annual minimum load occurred for each year beginning in 1973 to the present, inclusive, separately state the same information requested in parts (a) through (j) of interrogatory 3 above.
S. State on a monthly or annual (or otherwise maintained) basis,
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whichever the company utilizes, from the present time to the most future date projected, the most recent PG&E reserve projections for each of the h categories listed below:
(a) Total reserves available, for the control area; i
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l (b) Reserves for PG&E's own, or native, load; (c) Spir. sing reserves for the control area; l (d) The portion of reserves for PG&E's own, or native, load which is spinning reserves; (e) Standby reserves for the control area; (f) On-line reserves for the control area; j (g) Operating reserves for the control area; (h) Load dropping ability for the control area; ;
(1) Reserves available from other electric utilities by I type, amount, and supplier; (j) Any other reserves identified in answer to interrogatory 2(g) above, used by PG&E, by type, amount, and supplier.
- 6. State,from the present time to the most future date projected, the most recent PG&E projections of expected power (of each and every type or name known to PG&E) purchases, sales, and exchanges, (including all banki.ng and reserve arrangements), denoting for each the parties, dates r of transactions, and expected capacity and/or energy involved.
- 7. Identify each and every capacity and/or energy bank account maintained by PG&E with or for any other electric utility, and for each separately state, from 1973 to the present, inclusive, the monthly (or otherwise maintained) balance of all capacity and/or energy.
'8 (a) State the projected and/or the expected power flows on all segments of the entire transmission system (115 kv and above) in PG&E's control area at the time of the control area annual peak load for the years ,
when each of the units of the Diablo Canyon and Stanislaus Nuclear Plants are
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expected to begin operation and for the years when the first units of the Mendocino and San Joaquin Nuclear Plants had been expected to begin operation. [
(b) for each such projected and/or expected power flow, identify each generating unit of 100_ MW capacity or greater which was projected .
and/or expected to contribute to such power flow and state the projected and/or expected power output of each such generating unit.
9.(a) State the projected and/or the expected power flows on all segments of the entire transmission system (115 kv and above) in PG&E's control area at the time of the control area annual minimum load for the .
years when each of the units of the Diablo Canyon and Stanislaus Nuclear Plants are expected to begin operation and for the years when the first units of the Mendocino and San Joaquin Nuclear Plants had been expected to begin operation.
(b) For each such projected and/or expected power flow identify each generating unit of 100 MW capacity or greater which was projected and/or expected to contribute to such power flow and state the projected l and/or expected power output of each such generating unit.
t Res ectfully submitted,
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Jfck R. Goldberg munsel for NRC Staff
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t f f W y David J. Eyans Cou el for NRC Staff
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Dated at Bethesde, Maryland Nv4%. W6 f thj.s 15th day of December Benjar31'n H. Vogler e/ s 19/8. Assistant Chief Antitrust Counsel t
UNITED STATES OF AMERICA
-NUCLEAR REGULATORY COMMISSTON BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In-the Matter of )
1 PACIFIC GAS AND ELECTRIC ) NRC Docket No. P-564A COMPANY )
(Stanislaus Nuclear Project, ) -
Unit No. 1) )
CERTIFICATE OF SERVICE .
I hereby certif) that copies of NRC STAFF'S FIRST SET OF SUPPLEMENTAL INTERR0GATORIES PROPOUNDED TO PG&E in the above-captioned pioceeding have been served on the following by deposit in the United States mail, first '
class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of December 1978.
Marshall E. Miller, Esq., Chairman George Spiegel, Esq.
Atomic Safety and Licensing Board Robert C. McDiarmid, Esq.
U.S. Nuclear Regulatory Commission Daniel I. Davidson, Esq.
Washington, D.C. .20555
- Sandra J. Strebel, Esq.
Peter K. Matt, Esq.
Seymour Wenner, Esq. Bonnie S. Blair, Esq.
Atomic Safety and Licensing Board Thomas C. Trauger, Esq.
4807 Morgan Drive 2600 Virginia Avenue, N.W.
Chevy Chase, Maryland 20015- Washington, D.C. 20037 Edward Luton, Esq. Evelle J. Younger Atomic Safety and Licensing Board Attorney General of California U.S. Nuclear Regulatory Commission Michael J. Strumwasser Washington, D.C. 20555
- Deputy Attorney General of California Donald A. Kaplan, Esq. 555 Capitol Mall, Suite 550 P.O. Box 14141 Sacramento, California 95814 Washington, D.C. 20044 Morris' M. Doyle, Esq.
Jerome Saltzman, Chief William H. Armstrong, Esq.
Antitrust and Indemnity Group McCutchen, Doyle, Brown & Enersen U.S. Nuclear Regulatory Commission Three Embarcadero Center, 28th Floor Washington, D.C. 20555
- San Francisco, Califo nia 94111 Philip A. Crane, Jr. H. Chester Horn, Jr., Esq.
Glen West, Esq. Deputy Attorney General Pacific Gas & Electric Company Office of the Attorney General 77 Beale Street 3580 Wilshire Blvd., Suite 800 San Francisco, Cali fornia 94106 Los Angeles, California 90010 I .
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Ron Nichols '
Energy Commission 1111 Howe Avenue Sacramento, California 95825 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 * ,
Clarice Turney 3900 Main Street Riverside, California 92521 f '!f f l
.k tb! 'M Jjck R. Goldberg rounsel for NRC Staf
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