ML19208C310

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Testimony in Response to Tx Utils Generating Co & Houston Lighting & Power First Set of Interrogatories
ML19208C310
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
ER-76-589, NUDOCS 7909260022
Download: ML19208C310 (6)
v • d • e


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FPC DOCKET NO. ER76-587 PREPARED TESTIMONY OF DAVID A. SPRINGS 1 Q. PLEASE STATE YOUR NAME AND PLACE OF RESIDENCE.

2 3 A. David A. Springs, 4514 North Peachtree Road, Chamblee, Georgia 4

5 Q. WOULD YOU STATE YOUR EDUCATIONAL BACKGROUND?

6 7 A. I graduated from Georgia Institute of Technology in 1948 with a 8 Bachelor of Electrical Engineering Degree, and again in 1949, with a 3 Degree of Master of Science in Electrical Engineering.

10 11 . WOULD YOU STATE BRIEFLY YOUR ENPERIENCE?

12 13 A. During graduate work at Georgia Tech, I worked 15 months 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 17 of load flow and stability problems on large utility systems.

18 19 After graduation, I worked for Southern Engineering Company of Georgia 20 in Atlanta, Georgia, for approximately three years, doing distribution 21 design work, transmission system design, and long range power supply 22 planning.

23 24 From 1952 to 1963, I was with the South Carolina Public Service Authority, 25 first as supervisor in charge of wholesale billing and then for a period

( 26 of t'x years as their planning engineer. One of my responsibilities 27 with the South Carolina Public Servi.ce Authority was to rework and update 28 the " rule curve" of

  • Pinopolis Hydroelectric Plant Reservoir as steam 29 generation was added - the system.

30 31 Since returning to Southern Engineering Company of Georgia in 1963, I 32 have been in charge of the power supply planning and power system plan-33 ning section. I have been involved as a principal engineer in power 34 system planning or power supply planning for existing or potential sys-35 tems in the following states: Maine, Vermont, Virginia, North Carolina, 36 South Carolina, Georgia, Florida, Alabama, Mississippi, Oklahoma, Kansas, 37 Illinois, Kentucky and Ohio. I am a Vice President of Southern Engineer-38 ing Company of Georgia.

39 40 Q. HAVE YOU EVER TESTIFIED BEFORE ANY REGULATORY COMMISSIONS?

41 42 A. Yes, I have testified before this Cotmission in Carolina Power and Light 43 Company, Docket No. E-7564; Georgia Power Company, Docket Nos. E-7548, 44 E-9091, E-9521; Florida Power Corporation, Docket No. E-7679; Duke Power 45 Company, Docket No. E-7720; and Central Vermont Public Service Company, 46 Docket No. E-7685. I have testified before the Atomic Energy Commission 47 (n w the Nuclear Regulatory Commission) in Alabama Power Company, 48 J seph M. Farley Nuclear Plant, Units 1 and 2, Docket Nos. 50-348A and 49 50-364A. I have also testified before the Public Service Board of the 50 State of Vermont on two occasions.

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1 Q. ARE YOU A REGISTERED PROFESSIONAL ENGINEER?

C 2 3 A. Yes, I am registered in the States of Georgia and Kansas.

4 5 Q. TO WHAT SCHOLASTIC AND PROFESSIONAL SOCIETIFS DO YOU BELONG?

6 7 A. I am a member of IEEE and the Georgia Society of Professional Engineers, t 8 I am also a member of Tau Beta Pi (Scholastic Engineering) and of Eta 9 Kappa Nu (Scholastic Electrical).

10 11 Q. WHAT WERE YOUR ASSIGN'4ENTS IN THIS PROCEEDING?

12 13 A. My assignments were in two areas. The first was to demonstrate why Georgia

( 14 Power Company (GPC) should adjust its generating resources for Period II 15 (January through December 1976) to reficct only those generating resources 16 (capacity and associated energy) available to GPC in meeting its terri-17 torial load responsibility. Neither CPC's PR-2 rate filing with respect 18 to capacity charges nor its actual energy billing under PR-2 reflected 19 adjustments for certain transactions with others through the Southern 20 Company Pool.

21 22 My second assignment was to express an opinion as to whether GPC was 23 correct in its PR-2 rate filing to provide that OEMC should be billed 24 for its annual capacity responsibility based upon an estimated peak demand 25 contribution rather than OEMC's actual peak demand contribution.

( 26 27 Q. PLEASE ENPLAIN YOUR FIRST ASSIGNMENT AS TO UHY GPC SHOULD HAVE MADE 28 CERTAIN ADJUSTMENTS IN ITS PR-2 RATE FILING AND liS ENERGY BILLING UNDER 29 THE PR-2 RATE.

30 31 A. GPC prepared its PR-2 rate filing based upon a projected territo.-ial 32 generating capability " stack" (and related annual cost other than fuel) 33 including generating units owned solely by GPC and units jointly owned 34 by GPC and OEMC plus certain other Pencrating resources contractually 3 available to GPC during Leriod II including its purchase of 75,000 kW 36 from South Carolina Electric and Gcs Company, its purchase from Southern 37 Electric Generating Company of 522,950 kW, and its 157,795 kW share of L 38 the TVA seasonal exchange. GPC also included in the monthly energy 39 " stack" used for computing monthly energy billings to OEMC under the 40 PR-2 rate, the energy (and the fuel costs of such energy) provided by 41 each such generating resource-during each month. GPC did not reflect 42 in its projected annual terri.orial generating capacity " stack" nor its 43 monthly energy " stack" other transactions through the Southern Company 44 Pool which definitely either subtract from or add to the capacity and 45 energy resources of GPC and which should be recognized in establishing 46 the net resources available to GPC in meeting its territorial load 47 responsibility.

48 49 I have had prepared under my direct supervision OEMC Exhibit No. (DAS-1) 50 for the purpose of identifying the other transactions referred to above

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so that they n _ght be analyzed separately. From this analysis I will

(' ' 1 identify certain capacity related transactions which GPC should reflect 2

3 in the annual territorial generating capacity " stack". I have recom-4 mended to Witness Solomon that he include appropriate adjustments for 5 such capacity amounts in his annual capacity cost responsibility com-6 putations. These capacity related transactions will have a substantial 7 effect upon the capacity cost responsibility of OEMC under an appro-8 priately modified PR-2 filing as Witnesses Solomon and Gross testify.

9 10 From the analysis of OEMC Exhibit No. (DAS-1) certain energy trans-11 actions will also be identified which GPC should take into account 12 monthly in arriving at the energy " stack" actually available to GPC to 13 meet territorial load responsibility. OEMC Exhibit (DAS-2) has 14 been prepared under my direct supervision to show the effect of such 15 energy " stack" adjustments on the OEMC monthly billing for the months 16 o f August, September, October and November of 1976, 17 18 Q. WOULD YOU UOW DESCRIBE OEMC EXHIBIT (DAS-1) AND IDENTIFY THE TRANS-19 ACTIONS WHICH GPC HAS NOT TAKEN INTO ACCOUNT.

20 21 A. Page 1 of OEMC Exhibit (DAS-1) is a copy of Schedule B, sheet 1 of 22 2 from the Southern Company System 1976 Interchange Contract Analysis 23 for the Contract Year 1976 covering the period January through May. This 24 shows on line B1(c) that GPC was a " surplus capacity" pool member with 25 respect to " peak period" capacity and associated energy In the amount 26 of 314,853 kW and therefore contracted to sell this " surplus" capacity

(- 27 and associated energy to " deficit" pool members. Line B4 shows that 28 GPC was "short" of " peak hour" capacity in the amount of 43,842 kW and 29 contracted to purchase such shortage from those pool members long on 30 " peak hour" capacity. The method used for GPC to receive payment for 31 the " surplus" capacity sale is to include a portion of such capacity 32 Payments in the pricing of surplus energy (as exchange energy) and the 33 net remaining difference as an adjustment to the other fixed payments 34 of GPC for the period (see lines B2 through B5) .

35 36 Page 2 of OEMC Ex5Lbit (DAS-1) is a copy of Schedule B, sheet 2 of 37 2 from the South ( n Company System 1976 Interchange Contract Analysis for 38 the Contract Year 1276 cvcering the period June through December 1976.

39 This is similar tc Page 1 described above except it shows GPC selling 40 792,516 kW of " surplus peak period" capacity and as:sciated energy and 41 purchasing its shortage of 200,878 kW of " peak hour" capacity.

42 43 These capacity sales and purchases of GPC should be respectively removed 44 from and added to the annual capacity " stack" of GPC to obtain the net 45 territorial capacity " stack" of GPC available to meet territorial load 46 responsibility. I have recommended to Witness Gross that he make such 47 adjustments.

48 49 Page 3 of Exhibit DAS-1 is 'a listing of the transactions of GPC with 50 others for the month of August 1976 as recorded in the Operating Report 1013 084

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of GPC for August 1976. Starting with the total transactions for the month in both dollars and kWh (see line 2) we first remove those trans-3 actions with others which GPC has included in the capacity " stack" and 4 monthly energy " stack" (line 2A through line 2I). We then removed the 5 fixed payments (and' credits) GPC makes to the pool including the " peak 6 hour" capacity purchase payments and rentals but the adjustment to the 7 surplus capacity and energy sale (see line 3A) described as Pesk 8 Period Equivalent Payments is carried down and credited to the " surplus" 9 capacity and associated energy sale (see line 4B). The " surplus" trans-10 action for the month is now complete (see line 4C). By removing the 11 capacity related cost (see line 4D) the remainder is the revenue received 12 for " surplus" energy sold (see line 4E).

13 14 The "other variable" cost related to this " surplus" energy sale is

. 15 assumed to be 1.158624 mills /kWh ir accordance with Witness Solomon's 16 OEMC Exhibit No. (JBS-3). After removing the "other variable" 17 cost the remaining fuel cost (dollars and associated KWH) should be 18 removed from the appropriate energy resource in the energy " stack" 19 for August, 1976. This is shown on line 21 of page 1 of OEMC Exhibit 20 No. (DAS-2).

21 22 Next we removed pool capacity energy sold, and added that purchased, 23 adjusting the respective dollars cost or credit by the "other variable" 24 cost factor related to pool capacity energy exchanges in accordance 25 with page 14 of Witness Solomon's OEMC Exhibit No. (JBS-3) , (s ee 26 line SA through 5F). The remaining fuel cost (dollars and associated

( 27 KWH) shculd be removed from s. added to the appropriate energy resource 28 as was done previously for "surplua" energy (see lines 31 and 32 of 29 page 1 of OEMC Exhibit No. (DAS -2)) .

30 31 The same procedure was followed to add, or remove, economy energy 32 purchases or sales, (see line 6A through 6F) adjusting for "other 33 variabic costs" in accordance with the testimony of Witness Solomon 34 (see lines 26 and 28 of page 1 of OEMC Exhibit No. (DAS-2)).

35 36 Line 7 of OEMC Exhibit No. (DAS-1) described as "other exchanges 37 with associated companies" and line 8, described as "other interchange 38 transactions with non-associated companies" have not been adjusted 39 in the energy " stack" for August, 1976 since the information available 40 to us was insufficient to determine the proper resource of resources 41 to be adjusted. However, sufficient information to properly account 42 for these transactions is available to GPC and should be used to 43 properly apply the transactions as adjustmen r 1.

44 45 The sales on line 9A and 9B are comm.ittents of GPC which are considered 46 in'the territorini load responsibility and therefore generating 47 resources to supply these commitments should remain in the " stack". Line 48 9C however, should be added to the " stack" as a resource. This is 49 shown on line 5 of page 1 of OEMC Exhibit No. (DAS-2).

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9 1 The resulting revised energy " stack" for August 1976 is then used to 2 determine the energy cost by category for a recomputation of the 3 August 1976 energy billing for OEMC shown on pages 2 through 6 of 4 OEMC Exhibit No. (DAS-2).

5 6 The same procedure as illustrated on pages 3 and 4 of OEMC Exhibit 7 No. (DAS-1) for the month of August was repeated for the months 8 of September, October and November 1976 in developing revised energy 9 " stacks". These revised " stacks" were then used in recomputing energy 10 billing for OEMC for each month as shown on pages 7 , 8 and 9 ,

11 respectively, of OEMC Exhibit No. (DAS-2).

12 13 Page 10 of OEMC Exhibit No. (DAS-2) shows a comparison of energy 14 billing to OEMC for the four months as actually billed, as recomputed 15 herein, and the difference between the two. It will be noted that 16 the recomputed billing is $163,193 less than the actual billing.

17 18 Q. PLEASE EXPLAIN YOUR SECOND ASSICRIEhT AS TO MIETilER GPC WAS CORRECT 19 OR INCORRECT IN ITS PR-2 RATE FILING BY PROVIDING FOR ODIC TO BE BILLED 20 ON AN ESTDIATED, RATHER THAN AN ACTUAL PEAK DEMAND C0hTRIBUTION.

21 22 A. It is my opinion that GPC was incorrect in providing for OEMC to be 23 billed on an estimated peak basis. GPC and OEMC will be continuously 24 Pl anning together to meet their respective power requirements and

( 25 responsibilities. To penalize OEMC for overestimating its peak demand 26 and require that it pay for capacity and reserves that it did not 27 require means that OEMC will bear costs which should be carried by 28 thers. Additionally this will require OEMC to consistently under-29 Stim t their exP cted Peak demand in order to ensure that they d n t pay f r cap city and reserves they do not require.

30 31 32 For GPC and OEMC to jointly plan for their future needs requires 33 that both parties estimate their future demands as accurately as 34 Possible. OEMC, as well as GPC, will be disadvantaged if OEMC is 35 r quir d to plan for future requirements based on underestimates of 36 its peak demand because of this incorrect provision in the PR-2 rate filing.

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UNITED STATES FEDERAL POWER C0:011SSION DOCKET NO. ER76-587 STATE Oi GEORGIA )

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COUNTY OF FULTON )

I certify that the attached testicony and exhibits in this docket vere prepared by me or under my supervision and that the answers con-tained in such testimony and exhibits are true and correct to the best of my knowledge and belief.

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David A. Sppfngs /

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( Subscribed and sworn to before me this k

@ [d b f x.y Nott)ry Public flotary Peb"e, G orril St:t? ct t.arge

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