ML19208C306

From kanterella
Jump to navigation Jump to search
Testimony in Response to Tx Utils Generating Co & Houston Lighting & Power First Set of Interrogatories
ML19208C306
Person / Time
Site: South Texas, Comanche Peak  Luminant icon.png
Issue date: 08/01/1979
From: Springs D
GEORGIA POWER CO.
To:
Shared Package
ML19208C305 List:
References
E-9091, NUDOCS 7909260012
Download: ML19208C306 (5)


Text

GEORGIA POWER COMPAhT FPC DOCKET NO. E-9091 PREPARED TESTIMONY OF DAVID A. SPRINGS 1 Q PLEASE STATE YOUR NAME AND Pt. ACE OF RESIDENCE.

23 A David A. Springs, 4514 Narth Peachtree Road, Chamblee, Georgia.

4 5 Q WOULD YOU STATE YOUR EDUCATIONAL BACKGROUND.

67 A I was graduated from Georgia Institute of Technology in 1948 with a 8

Bachelor of Electrical Engineering Degree, and again in 1949, with 9

a Degree of Fbster of Scienec ~in Electrical Engineering.

10 11 Q WOULD YOU STATE PRIEFLY YOUR EXPERIENCE.

12 13 A During graduate work at Georgic Tech, I worked 15 nonths as Assistant 14 Operator of the Georgia Tech AC Network Calculator.

At that time, the 15 calculator was the most advanced tool for studying the overall operations 16 of power systems.

This experience gave me a very early understanding of 17 load flow and stability problems on large utility systems.

18 19 After graduation, I worked for Southern Engineering Company in Atlanta, 20 Georgia, for approximately three years, doing distribution design work, 21 transmission system design, and long range power supply planning.

22 23 From 1952 to 1963, I was with the South Carolina Public Service Authority,

(

24 first as supervisor in charge of wholesale billing and then for a period 25 of six years as their planning engineer.

One of my responsibilitics with 26 the South Carolina Public Service iuthority was to rework and update the 27

" rule curve" of the Pinopolis Hydroelectric Plant Reservoir as steam 2S generation was added to the system.

29 30 Since returning to Southern Engineering Company in 1963, I have been 31 in charge of the power supply planning and power system planning section.

32 I have been involved as a principal engineer in power system planning or 33 power supply planning for existing or potential systems in the following 34 sectes: Maine, Vermont, Virginia, North Carolina, South Carolina, Georgia, 35 Florida, Alabama,' Mississippi, Oklahoma, Kansas, Illinois, Kentucky and 36 Ohio.

37 38 Q HAVE YOU EVER TESTIFIED BEFORE ANY REGULATORY COSSilSSIONS?

39 40 A Yes, I have testified before this Commission in Carolina Power and Light 41 Company, Docket No. E-7564; Georgia Power Company, Docket No. E-7548; 42 Florida Power Corporation, Docket No. E-7679; Duke Power Company, Docket 43 No. E-7720; and Central Vermont Public Service Company, becket No. E-76SS.

44 I have testified before the Atomic Energy Commission (now the Nuclear 45 Regulatory Commission) in Alabama Power Company, Joseph M. Farley Nuclear 46 Plant, Units 1 and 2, Docket Nos. 50-348A and 50-364A.

I have also 47 testified before the Public Service Board of the State of Vermont on two 48 occasions.

(

49 50 Q ARE YOU A REGISTERED PROFESSIONAL ENGINEER?

i 013 094 ' 7 904260(9 /g?

~

(

1 A Yes, I am registered in the States of Georgia and Kansas.

2 3 Q TO WHAT SCHOLASTIC A. D PROFESSIONAL SOCIETIES DO YOU BELONG?

45 A I am a member of IEEE and the Georgia Society of Professional Engineers.

6 I am also a member of Tau Beta Pi (Scholastic Engineering) and of Eta 7

Kappa Nu (Scholastic Electrical).

8 9 Q WHAT WERE YOUR ASSIGNMENTS IN THIS PROCEEDING 7 10 11 A My assignments were in two areas. Fy first assignment involved the 12 method used by Georgia Power Company to determine the power supply de=and 13 allocation factors.

I was asked to study Georgia Power's method of 14 selecting demand allocation factors and determine whether or not the 15 demand allocators calculated by this method would properly allocate to 16 the whoicsale customers within the State of Georgia their proper share 17 of power supply costs.

My second assignment was to determine whether 18 or not the subfunctionalization of Georgia Power's transmission facilities 19 into step-up, bulk transmission, and subtransmicsion facilities is proper.

20 21 Q WHAT SWIDIES HAVE YOU IMDE IN THIS PROCEEDING?

2223 A I have reviewed the testimony and exhibits filed by Georgia Power in this 24 proceeding, Georgia Power's 1974 and 1975 EPC Form No. 1 and Form No. 12, 25 and certain responses made by Georgia Power to various requests for in-(

26 formation made by the FPC Staff and the intervenors in this proceeding.

27 I have also reviewed the testimony and exhibits filed by the FPC staff.

28 29 Q WHAT WERE THE RESULTS OF YOUR STUDIES CONCERNING GEORGIA POWER'S METHOD 30 0F DETERMINING THE DEIGND ALLOCATION FACTORS?

31 32 A Georgia Power uses demand allocation factors derived from the five-day 33 average coincident peak demand responsibility method to allocate production 34 and certain transmission facilities to the wholesale customers.

The 35 reasoning behind using the five-day average method is to reduce the influence 36 of loads of short duration which may coincide; however, it is still a peak 37 month type of responsibility allocation.

38 39 This method proves to be particularly applicable within the Georgia Power 40 system.

Georgia Power experiences a relatively high summer peak demand 41 which now is from 207. to 30% above the average monthly peaks of October 42 through May (see Cooperative Intervenors' Exhibit No.

(DAS-1)).

43 On a MW-month basis, Georgia Power's reserve capacity for maintenance 44 purposes during off-peak seasons is substantial.

Scheduling of maintenance 45 is not critical (see Cooperative Intervenors' Exhibit No.

(DAS -2)).

46 No maintenance is scheduled over the summer peak, unless a unit needs 47 emergency maintenance.

In other words, Georgia Power is not " maintenance 48 saturated" (see Cooperative Intervenors' Exhibit No.

(DAS-3)), and 49 capacity availability during the off-peak months is not critical and should 50 not be given the same weight as the peak month capacity availability.

k

+

.1 1 0 1 3 of9 5 i --

.iu' 1 Q DO YOU AGREE WITH GEORGIA POWER COMPANY'S FETHOD OF CALCULATING del %ND 2

ALLOCATION FACTORS?

3 4 A Yes, I do.

5 6 Q IN YOUR STU'DY OF THE FETHOD OF DETERMINING THE DEMAND ALLOCATION FACTORS, 7

HAVE YOU REVIEWED THE TESTIMONY PRESENTED BY COMMISSION STAFF?

8 9 A Yes, I have.

in this case, the Georgia Pr.wer method is more equitable 10 than the twelve-month average peak method used by FPC Staff.

I disagree 11 with the assumptions inherent in the staff's rationalization that monthly 12 peaks are somehow as important as the annual peak regardless of the 13 magnitude of excess capacity above load and maintenance requirements.

If 14 maintenance requirements reduced seasonal excess capacity to close to zero, 15 then staff would be correct; however, this is not the case on the Georgia 16 Power system.

Sales (and purchases) of excess capacity would be peripheral 17 in nature and cannot be expected to support average system cost responsi-18 bilities as wholesale sales are expected to.

This excess capacity should 19 not be considered as valuable as firm load carrying capacity.

20 21 Q WHAT WERE THE KESULTS OF YOUR STUDIES OF THE ASSIGNMEh7 BY GEORGIA POWER 22 0F ITS TRANSMISSION FACILITIES?

23 24 A Georgia Power stratifies its transmission facilities into four voltage 25 levels.

These four voltage levels are:

"B-1",

Step-up Substations at 26 generator plant; "3-2",

Transmission Lines (115 kV to 500 kV);

"C",

27 Transmission Cubstations; and "D", Subtransmission Lines (38 kV to 69 28 kV).

Georgia Power alleges that its concept enables it to identify 29 the location of its customers with respect to their relative use of 30 Georgia Pcwer's syste=,

Georgia Power has subfunctionalized the step-up 31 facilities from its transmission facilities and has allocated them to its 32 customers by production demand allocation factors.

The remainder of the 33 transmission facilities have been subfunctionalized into bulk and sub-34 transmission facilities which were then allocated to the wholesale 35 customers according to the bulk transmission and subtransmission 36 allocation factors.

37 38 Q DO YOU AGREE WITH GEORGIA POWER COMPANY'S METHOD OF ALLOCATING ITS 39 TRANSMISSION FACILITIES TO EACH CLASS OF ITS CUSTO>ERS?

40 41 A I agree with Georgia Power's subfunctionalization of step-up facilities 42 from its transmission facilities.

I do not, however, agree with tne 43 allocation of Georgia Power's other transmission facilities.

44 45 Q WHAT ARE YOUR REASONS FOR AGREEING WITH THE SUBFUNCTIONALIZING OF STEP-46 UP TRANSMISSION FACILITIES FROM TRANSMISSION FACILITIES?

47 48 A Georgia Power's step-up transmission facilities are not an integral part 49 of its bulk trans=ission system.

Their primary function is to transform 50 the power and energy generated by the generating units to the voltage

( ~ b? ff

F

(

1 level which is compatible with the bulk transmission system.

Staff 2

witness Der erred in the inclusion of Georgia Power's step-up trans-3 mission facilities in transmission power supply.

4 5 Q WILL YOU PLEASE EXPLAIN WHY YOU DISAGREE WITH THE STAFF WITNESS' 6

CONCLUSION THAT GEORGIA POWER COMPAW'S STEP-UP SUBSTATIONS SHOULD 7

BE INCLUDED IN THE TRANSMISSION FACILITIES WHICH ARE ALLOCATED TO

(

8 GEORGIA POWER'S CUSTOMERS BY THE " ROLLED-IN" METHOD?

9 10 A As I have just stated, the step-up substation performs as a part of 11 power supply production facilities rather than as a part of transmission 12 facilities in that it tran; forms the output of a generating unit to the 13 higher voltage of a transmission system.

In this proceeding, Georgia

(

14 Power indicates that it has provided a transmission (wheeling) service 15 for the Southeastern Power Administration (SEPA).

Georgia Power transmits 16 272,000 kilowatts for SEPA which flows only through Georgia Power's 17 transmission system and not through the "B-1" level step-up facilities.

18 Thus, it would be unfair tc SEPA's customers to be. allocated cocts as 19 if these step-up facilities were used to provide service related to 20 SEPA purchases.

21 22 Q WILL YOU PLEASE EXPLAIN WHY YOU DISAGREE WITH GEORGIA POWER'S ALLOCATION 23 0F THE OTHER TRANSMISSION FACILITIES?

24 25 A I disagree with Georgia Power's method of grouping its 110 kV to 500 kV

(

26 transmission lines as bulk transmission facilitics, while separating 27 its 38 kV to 69 kV lines as subtransmission facilities.

My studies of 28 Georgia Power's transmission syste= show that some of its 115 kV trans-29 mission lines serve local load just as do the 33 kV to 69 kV transmission 30 lines.

In other words, some of Georgia Power's 115 kV transmission lines 31 are not fulfilling the service of movinS bulk power from one location to 32 another.

33 34 Georgia Power has assumed that all of its power and energy will flow from 35 500 kV facilities down to its distribution facilities.

Georgia Power's 36 filing, Statement "M", Period II, Page 2 shows that Georgia Power's power 37 and energy, the so-called " Territorial Input" at Level "A", will flow 38 through its "B-2" transmission lines (115 kV to 500 kV).

However, my 39 analysis of Georgia Power's 1974 Electric System Property indicates that 40 all of Georgia Power's power and energy may not flow through its "B-2" 41 facilitics.

Cooperative Intervenors' Exhibit No.

(DAS-4) which 42 is a portion of Georgia Power's Electric System Property Map, shows 43 that Georgia Power has an interconnection with Alabama Power Company 44 at 44 kV; Transmission Line Section C-12 as circled.

The power and energy 45 imported from Alabama Power Company through this line will not flow 46 through Georgia Power's "B-2" facilities.

47 48 Georgia Power has assumed that its "B-2" facilities are power supply 49 transmission lines.

However, my analysis of Georgia Power's map indicates 50 that some of its 115 kV transmission lines do not perform the function

(

~ 1013 097

(

1 of transmitting bulk power; instead, they perform the function of 2

serving local loads.

Cooperative Intervenors' Exhibit No.

3 (DAS-5) indicates Line Section A-45a which is a section of 115 kV 4

transmission line (operated at 110 kV) which serves only local load.

5 Cooperative Intervenors' Exhibit No.

(DAS-6) indicates Line 6

Section A-16 which is also a section of 115 kV transmission line 7

(operated at 110 kV) and serves only local load, Neither Line Section 8

A-45a nor A-16 serve any wholesale customers, therefore, they should 9

be specifically assigned to Georgia Power's retail customers in order 10 to be consistent with Georgia Power's assumption that certain trans-11 mission facilities should be specifically assigned.

12 13 Q HOW SHOULD GEORGIA POWER COMPAW'S TRANSMISSION PLANT BE ASSIGNED?

14 15 A I have recomaended to Witness Solomon that he use the " rolled-in" 16 method to allocate Georgia Power Company's transmission facilities 17 to customer groups in the cost of service studies for the Cooperative 18 Intervanors.

The " rolled-in" nathod is based on a single de=and 19 allocation factor for each customer group.

20 21 22 23 24 25

(

26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 l

1013 098