ML19220A427
| ML19220A427 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/14/1975 |
| From: | Winter P Metropolitan Edison Co |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7904170581 | |
| Download: ML19220A427 (50) | |
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Eefore 'he Atcmic Safety and Licensire Peard In the "atter of
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- EIROPOLITA'l EDISC:I COMPA'iY,
)
3.'r AL.
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Decket !o. 50-320
)
(Three Mile Island Iuclea'-
)
Station, Unit 2)
)
AFFIDAVIT OF PAUL E. '4T:.":TR Cc=ncnvealth Pennsylvania
)
SS County of Berks
)
PAUL E. 'dI: ITER, being duly svorn according to law, deposes and says that he is a Manager-Planning with Metrcpolitan Ediscn Cc=pany; that the infernation contained in Applicants '
Responses to Interrogatory ?!cs. 1, 2, 3, 9, 11, 13, 17, 18, 19, 20, 21, 25, 25, 25, 27, 28, 32, 35, 36, ho, 51, h3, 56, 57, 59, 60, 62, 63 and 6h in true and correct to the best of his knculedge and belief.
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p(M[,... L ' s. dA Paul E. 'dinter Manager-Planning Metropolitan Edisen Conpany Sworn to and subscribed before ne this NM day of July,1975
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
)
Docket No. 50-320
)
(Three. Mile Island Nuclear
)
Station, Unit 2)
)
APPLICANTS' RESPONSE TO INTERVENORS' INTERROGATORY NO. 1 INTERROGATORY NO. 1 State whether the Bechtelsville-Hosensack (herein-after "Bechtelsville line") is the subject of any agreements.
If so, identify said agreements and produce copies of same.
RESFONSE The Bechtelsville-Hosensack line, as a part of the TMI to Hosensack 500KV line, is not presently the subject of any agreement although it is one of the subjects that will be covered under a 500KV Transmission System Agreement currently being negotiated by the Suscuehanna-Eastern EHV Transmission Group (discussed further in Applicants' Response to Interrogatory Nos. 27 and 32).
48.e43
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Station, Unit 2)
)
APPLICANTS' RESPONSE TO INTERVENO RS ' INTERROGATORY NO. 2 INTERROGATORY NO. 2 Was the Bechtelsville line origianlly planned to be initially constructed as a 230 kv line?
If so, state and explain fully the reasons for changing the same to a 500 kv line.
RESPONSE
The Bechtelsville to Hosensack line was always planned for 500KV construction and condemnation of the affected lands was conducted to provide a corridor for construction of a line capable of operation at 500KV.
c.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
)
Docket 'lo.
50-320
)
(Three Mile Island Nuclear
)
Staiton, Unit 2)
)
APPLICANTS' RESPONSE TO INTERVENORS' INTERROGATORY NO. 3 INTERROGATORY NO. 3
'vho shall own the Bechtelsville line?
State fully the =cchod of ownership and what ownership agreements there are concerning the same.
Identify such agreements and pro-duce copies of same.
RESPONSE
Met-Ed owns the entire Three Mile Island to Hosensack.
500KV circuit including the Bechtelsville-Hosensack portion.
Acknowledgement of this ownership will be reflected in the Susquehanna-Eastern 500KV Transmission System Agreement, which is currently being negotiated.
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UNITED STATE 3 OF AMERICA NUCLEAR REGULATORY COMMISSIGN Before the Atomic Safety and Licensinc Board In the Matter of
)
)
METROPOLITAN EDISON CCMPANY,
)
)
Docket No. 50-320
)
(Three Mile Island Nuclear
)
Staiton, Unit 2)
)
APPLICANTS' RESPONSE TO INTERVENORS' INTERROGATORY NOs.
9, 13, 26, 35, 36 INTERROGATORY NO. 9 Detail and identify what studies were made in order to interconnect Unit 2 with the PJM system by alternative transmission line routes that would not cause the erection and creation of the Bechtelsville line.
Produce copies of all such studies.
INTERROGATORY NO. 13 Set forth in detail and with particularity any and all engineering reasons and considerations for establishing the transmission line that gave rise to the Bechtelsville sector.
With respect to each reason and consideration, detail fully what alternative considerations were reviewed.
As to all such reviews, set forth copies of any and all documents, studies and reports concerning the same and produce copies of same.
INTERROGATORY NO. 26 What considerations with regard to the shape of the overall loud, installation costs, transmission costs and operating costs over the transmission lines were made and considered in establishing the Bechtelsville line?
Detail fully your answer and produce copies of any memoranda, reports and/or documents concerning the same.
4g INTERROGATORY MO. 35 Identify all purposes and justifications for the design of the Bechtelsville line.
INTERROGATORY NO. 36 Justify fully why the shortest way to interconnect Unit 2 with the PJM system is through the design line as pro-posed, including the Bechtelsville line.
Detail your answer fully and explain fully why the reliability of the inter-connection system necessarily caused a design as proposed and why other alternative options were foreclosed or not considered.
RESPONSE
Early in 1969, planning personnel developed a 230KV transmission plan for Three Mile Island #2 nuclear unit, which included a Three Mile Island to HosenJack 230KV circuit and met the MAAC reliability principles and standards.
(See Applicants' Response to Interrogatory Nos. 24 and 25 for addi-tional discussion of effect of load forecasts in this regard).
At about the same time, planning studies of the early to mid-1970 time period showed overloads would result on certain portions of the PJM bulk power interconnected system if outages occurred on either of the two then existing 500KV paths east of the Susquehanna River.
Thus, although the GPU 230KV trans-mission plans did meet the MAAC reliability criteria, they did not alleviate other identified future problems.
It was sug-gested that perhaps a 500KV transmission plan for Three Mile Island Unit #2 might also alleviate future potential overloads in the network.
46 E47 A study group, consisting of members from GPU, Philadelphia Electric Company (PE), and Pennsylvania Power
& Light Company (PP&L), conducted in early 1969 a preliminary investigation of possible 500KV transmission plans for TMI #2.
The study group investigated four alternate plans that would provide outlet for Three Mile Island Unit #2 pcwer output, while simultaneously providing a third west to east 500KV transmission path east of the Susquehanna River.
The alternate plans only considered routings that went easterly from Three Mile Island, since the shape of interconnection system load increases in a generally easterly direction.
Copies of the four plans, extracted from the study group's report, entitled,
" Report on Preliminary Study of Three Mile Island #2 500KV Transmission Plans," dated May 1969, are attached, and reflect the costs of each of the alternate plans considered.
All plans had the advantage of providing a third west to east 500KV transmission path, supplementing the exist-ing Alburtis-Branchburg and Peach Bottom-Whitpain 500KV lines.
This would permit the loss of either of the two existing paths without resultant system overloads, and was necessary by the mid-1970 's in order to meet Mid-Atlantic Area Council (MAAC) reliability principles and standards.
In addition, a 500KV p-lan would provide a greater power transfer capability from western to eas tern areas of PJM.
Finally, transmission at 500KV rather than 230KV had the added benefit of reducing the associated transmission line losses.
The report concluded that 46 ;?48
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plan four (4) was the mor,t desirable from load flow, reli-ability and cost considerations.
Moreover, recognizing the constraints of right-of-way acquisition, the line routing adopted was reasonably the shortest path satisfying the require ents of a third west to east 500KV circuit terminating east of Whitpain while providing a source at Hosensack for service to the eastern Met-Ed System and Jersey Central Power and Light Company.
After issuance of the May, 1969 report, considerable evaluation took place comparing the 500 and 230KV transmission plans.
Due to the May 1973 in-service date for TMI Unit #2, it was felt that there was insufficient time to implement a 5 0KV plan and actions were taken to proceed with the 230KV transmissica plans for TMI #2.
However, an August, 1969 slippage in the schedule in-service date of TMI Unit #2 to May, 1974 removed the concern that insufficient time existed to accommodate a voltage change, and allowed enough time to further evaluate a change frca the original plan of 230KV transmission to 500KV transmis sio n.
In early 1970, GPU, PE and PP&L completed,further studAes of the 500KV transmission system and determined several western and eastern substation and line arrangement alternates.
The report on these study results was issued in February 1970, and is entitled " Report on Three Mile Island 500KV Transmission Study."
The principal recommendations of this report were:
(1) a 500KV circuit should be built from Three Mile Island 500KV Substation to Souderton; (2) the Peach Bottom-Juniata 500KV circuit should ce looped into the Three Mile Island 500KV 46 ;MS location; and (3) a 500/230KV transformer should be installed at the Three Mile Island 500KV Substation.
Installation of these facilities would provide west to east transmission for the output of Three Mile Island #2, relief to overloads for outage of the Peach Echtom-Whitpain and Alburtis-Branchburg 500KV lines, and reduced loadings on the then existing PJM 500KV transmission across southeast Pennsylvania.
Implementation of the report's recommendations, hcwever, had one significant drawback--it would have required Jersey Central Power and Light Company and tae eastern Met-Ed System to receive a portion of their share of TMI #2 output through the 500KV system and lower voltage facilities of other PJM member companies.
To avoid this, an intermediate 500/230KV stepdown substation (retaining a 230KV capability to Hosensack) somewhere between the western terminal at TMI 500KV Substation and the eastera terminal at Souderton was deemed nc..cessary.
Hosensack, the original choice for this 500/230KV substation locaticn since its exists as a 230KV hub, was initially ruled out due to right-of-way widening probicms and area aesthet.les.
After much discussion the Bechtelsville area was picked in October of 1970 as the site for this substation (See Applicants' Response to Interrogatory Nos.
4, 7 and 34).
This allcwed both a reasonable route se:ection for 500KV transmission to Souderton,and a location for installation of stepdown trans-formation capacity and 230KV transmission to Met-Ed's 230KV station at Hosensack.
46 30
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In the fall of 1970, Met-Ed began negotiations to acquire the Bechtelsville Substation site and an agreement of sale for the property was entered into in December of 1970.
In the summer of 1971, Met-Ed began construction of the Bechtels-ville Substation in order to meet the then proposed in-service date of May, 1974 for TMI Unit #2.
In the Fall of 1971, the in-service of TMI Unit #2 was again delayed for a year to May of 1975.
Also during this same period, the MAAC completed a report entitled "MAAC System Re-liability Review 1971" which specifically pointed out the importance of completing the Bechtelsville-Souderton 500KV circuit before June of 1974, stating that "all delays of the Bechtelsville-Souderton line beyond June 1, 1974, will result in the failure of eastern PJM (PE, PSEG, GPU/NJ) to meet the MAAC reliability criteria."
The PJM Planning and Engineering Committee recommended to the PJM Management Committee that the construction of the Bechtelsville-Scuderton line be "given the utmost priority."
In December of 1971, GPU submitted a report entitled,
" Transmission Plans for Three Mile Island Generating Station" including the 9echtelsville-Hosensack Line to MAAC fer its review and subs quent approval.
Between January 1972 and the end of 1972, the Montgomery County Planning Commission held several meetings on the route of the Becntelsville-Souderton line.
Their recommendation, to which Philadelphia Electric Company agreed, was that the
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~~"-direct Bechtelsvillet-Sladerton line be replaced by a circuit through Hosensack such that the line north from Souderton to Hosensack could parallel an existing Hosensack-Buxmont 230KV circuit.
The third west-east 500KV path thus became a TMI-Bechtelsville-Hosensack-Souderton (Elroy) circuit as opposed to the fCrmer TMI-Bechtelsville-Souderton path.
To eftect this change Met-Ed's circuit from Bechtelsville to Hosensack, which was sized and already under construction for a 500KV capability but for initial operation at 230KV, recuired an initial operating voltage change from 230KV to 500KV, and the 500/230KV transformer and equipment, formerly t be located at a Bechtelsville Substation, required relocatica to Hosensack.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSICN 3efore the Atomic Safety and Licensing Board In the Matter of ) ) METROPOLITAN EDISCN COMPANY, ) ET AL. Docket No. 50-320 ) (Three Mile Island Nuclear Station.) Unit 2) ) APPLICANTS' RESPONSE TO INTERVENO FS ' INTERRCGATO RY NO. 11 INTERROGATORY NO. 11 Set forth whether applicants assert that the proposed Bechtelsville line is necessary for the direct service of customers in the Metropolitan Edison service area. Explain fully your aniwer. By direct service, in-tervenors mean that the line.s necessary to bring energy directly to customers in the scrvice area rather than assur-ing service by " reliability" aad interconnection agreements.
RESPONSE
The Bechtelsville-Eosensack line as a portion of the TMI-Hosensack circuit is necessary for the direct service of customers in the Metropolitan Edison Company service area. At Hosensack the 500KV is reduced to a 230KV or 115KV voltage level. It then flows over our 230KV or ll5KV transmission lines to other substations for further voltage reduction, as necessary, and distribution for customer use.
UNITED STATES OF AMERICA ' ' ~ NUCLEAR REGULATORY CO!OIISSIC'N Before the Atomic Safety and Licensing Board In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear Station,) Unit 2) ) APPLICANTS' RESPONSE TO INTE RVENORS ' INTERROGATORY NO. 17 INTERROGATORY NC. 17 Produce copies of all testimony and statements of Paul Winter, 1tetropolitan Edison's Systems Plannin-J Engineer, concerning testimony and statements he made before the Pennsylvania Public Utility Cc= mission concerning the said line.
RESPONSE
Paul Winter, then System Planning Engineer, Metro-politan Edison Company, presented testimony and/or state-ments before the Pennsylvania Public Utility Commission on August 8, 1972, and June 8, 1973, in Norristown, Pa., and June 23, 1973, in Allentown, Pa., in only one case con-cerning the Bechtelsville line, Application Docket 97163. His testimony and/or statements are on nages 62 through 92, 99 through 105, and pages 235 through 248 of the transcript of this proceeding. 46 'J58
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of ) ) METROPOLITAN EDISCN COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPONSE TO INTERV. DORS ' INTERROGATORY NOs. 18, 19 and 20 INTERROGATORY NO. 18 Detail fully how the proposed line would increase the reliability of the Metropolitan Edison system. INTERROGATORY NO. 19 With reference to your answer to the last question, set forth fully what alternatives were considered to assure the same objectives. Produce copies of any and all reports, documents, and memoranda concerning said considerations, objectives, and evaluations. INTERROGATORY NO. 20 If the applicant's position is that the transmission lines were necessary to assure system reliability, set forth any and all evidence with reference to the fact that the sys tem would not be reliable without the proposed Bechtelsville line.
RESPONSE
For system reliability Met-Ed adheres to the Reliability Principles and Standards ~of MAAC (Mid-Atlantic Area Council) which were developed to test reliability of the bulk power 48 259
k interconnected MAAC System. Since the criteria measure the ability of the entire or large area portions of the intercon-nected system to meet the established minimum accpetable standards they cannot be applied to the facilitien of one company when considering one specific line in the overall ne two rk. The reliability of the Met-Ed system is not specifically determinable since it is a part of the overall PJM bulk power interconnected network. Some of the consequences of the 500KV plans do have a tendency to increase reliability aspects of Met-Ed's facilities in that the 500KV plan resulted in icwor 230 KV loadings on Met-Ed area circuits which in turn provides greater spare capacity for meeting emergency conditions. Other reliability-oriented cc..siderations are lower power losses and less voltage drop at 500KV. The Becthelsville-Hosensack circuit as part of the transmission system additions associated with Three Mile Island Unit #2 generating addition was necessary primarily as an outlet for Unit #2 power and subsequent transmission and distribution of this power to our customers. When the initial alternate 500KV plans were investigated (See Applicants' Responses to Interrogatory Nos. 9, 13, 26, 35 and 36) they were tested as part of the planning process for compliance with the MAAC criteria. Their ability to meet and exceed the criteria wma pr_ mary factor in determining the superiority oi the 48 2E0
recommended plan. With the Bechtelsville-Hosensack circuit ~ as an integral part of the Three Mile Island to Hosensack to Souderton 500KV circuit the MAAC standards are met. With-out the circuit the criteria are not met and the overall system is lors reliable. (See Applicsnts ' Response to Interrogatory No. 57). S 9 48 'iG1
UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION Before the Atcmic Safety and Licensing Board In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear Station,) Unit 2) ) APPLICANTS' RESPCNSE TO INTERVENO RS ' INTERROGATORY NO. 21 INTERROGATORY NO. 21 With reference to the Bechtelsville line, was any consideration given to the design of said line that Metro-politan Edison's customers would consume more electricity in the future in the area in which the line transverses, making the line necessary? If so, produce copies of any memoranda, studies and/or reports concerning said consider-ations. Detail in full precisely what the objectives and concerns of the applicant wem in ' nat regard. Set forth any and all estimates and opinier that gave rise to these concerns and objectives.
RESPONSE
A portion of Met-Ed's total customer growth in-dicated in its load forecasts is atributable to the customers in our service area which the line traverses. However, load growth in the specific area around Bechtelsville and Hosensack is not the reason that the 500KV transmission line was routed as it now is. A 500KV transmission line transports very large amounts of power and generally serves to bring 48 ?G2
. power frcm large generating facilities to major substation locations from which the pcwer can be further distributed. f a r3 g-r) L dO
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Beard In the Matter of ) ) METHOPOLITA'i EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPONSE TO INTERVE:; ORS ' INTERROGATORY NOs. 24 and 25 INTERRCGATORY NO. 24 What considerations of load forecasting, if any, gave rise to the Bechtelsville line? Detail and explain fully your answer. Identify and produce copies of any and all memo randa, reports, and/or documents concerning the same. INTERROGATORY NO. 25 Set forth the factual foundaticn and basis for any load forecasts that were considered and used in justifying the necessity and/or the design of the Bechtelsville line. With reference to any load forecasts that were so considered, were any revised? If so, detail the revisions thereto.
RESPONSE
Load forecasting considerations gave need to the Bech-telsville line in that a peak load forecast establishes the expected amount of power to be served in a future time period and provides the basis for determining future needs. As a general matter the Met-Ed peak load forecast is reviewed and revised periodically and combined with the peak load forecasts 48 'JG4
. of the other GPU operating subsidiaries resulting in the com-bined GPU System peak load forecast. Once this tabulation of future year-by-year combined peak loads is established the capacity planning group determines a schedule of generating additions to meet the expected future loads in addition to providing a reserve margin for loads higher than forecast, maintenance of existing generating units, and emergency outages. In establishing the unit additions, consideration is given to a multitude of factors including the availability of water for cooling purposes, the availability of a generating site suit-able for the type unit being installed, expected availability of future fuel types, in addition to the size, type and number of units to be installed and in what requence. Once ahe forecast loads and generating capacity additionc are determined for the GPU companies, this information is combined with that of the other PJM companies to establish a PJM system schedule of company loads and generating capacity additions. The next step in the process for any given future year is for system planners to model the future PJM system with the expected load and generat-ing additions in order to determine necessarv transmission requirements. At the time that the need for the TMI to Bechtelsville to Souderton 500KV line was being finalized, the GPU load and capacity forecast, dated September 1969, incorporated a Met-Ed seasonal peak forecast which was developed as follows: Historical seasonal peak loads were tabulated for a base period of 7 years. The 1967 and 1968 summer actual values
- were adjusted to accoun:for voltage reductions that occurred over the peak period. Af ter adjusting the loads in this fashion a set of values existed that represented the historical load growth pattern of our system for the several years prior to the year in which the forecast was made. Using statistical methods the adjusted values were trended in order to establish future seasonal peak loads. An addition was made to these peaks to account for a larr;a steel company going in service early in the forecast period. With this set of statistically determined future peak loads, and judgment factors to include many less tangible items such as future air conditioner utilization, competition among the various sources of energy for home heat-ing purposes, other marketing considerations, etc. a load fore-cast for the next ten year period was established. A copy of the Su==er Peak Load Forecas t 1969-1978 and Schedule of Generating Unit Additions for each of the GPU operating subsidiaries as issued 't. September, 1969, is attached. Three Mile Unit #2 is shown in this schedule with a Ma', 1974 projected in-service date. Ownership at that time was 75% Met-Ed and 25% New Jersey / Jersey Central which was subsequently changed to 50% Met-Ed and 25% each to Penelec and Jersey Central. As part of the normal planning process load forecasts are reviewed at least annually and frequently are reviewed and revised as often as two or three times per year, depending upon the fluctuation of future expectations. Attached is the latest GPU load and capacity forecast, issued in May, 1975. 46 PGG
TABLE ID GPU LOAD AND CAPACITY F0HECAST i SUM'ER 1969" 1970 1971 1972 1973 197h 1975 1976 1977 1978 T11~ Cupacity-IN 1518 191h 1939 1939 1866 18h6 2166 2166 2666 2666 Load -!N 1201 1370 1h60 1560 1660 1770 1870 1980 2080 2190 Reserve -ini 317 Shh h79 379 186 76 296 186 586 976 26.4 39 7 32.8 24.3 11.2 h.3 15.8 9.4 28.2 21 7 El Capaci ty-ini 996 1356 1h66 170h 170h 2311 2h01 2h01 2h01 2hC1 Load -tm 1186 ' 1270 1370 14'(0 1580' 1'(00 1830 1970 2120 2290 Reserve -tal -190 86 96 23h 12h 611-571 h31 281 111' -16.0 6.8 7.0 15 9 7.8 35 9 31.2 21.9 13.3 4.8 NJ/JC Capacity-tm 1036 16h9 1949 2287 2687 3290 3320 h220 h220 5120 Inad -;ni 1633 1750 1950 2170 2h10 2680 2970 3310 3680 4100 Heserve 4nt -597 -101 -1 117 277 610 350 910 SLO 1020 -36.6 -S.8 -0.1 S.h 11 5 22.8 11.8 al.S 16.7 Ph.9 " Actual Summer Values Through September 1, 1969 Adjusted For Estimated Load Reductions On July 18, 1969 Service HET PE Service ET @ _Jbtn _ PN 11E MJ/JC Date P.1 'T i:J /J Insta11cd Capacity - 9/1/69 1518 996 1936 Retirements -2Uh lietirements --27 Installed - Summer 1972 1939 170h 22b] Oyster Creek #1 9/69 515 Retirements -93 @h" Seneca //1-3 (GPU Share) 11/69 76 Union Beach #1 S/73 licmcr City #2 & Reallocation 11/69 320 100 ~ 1666 170L 2.' 7 Installed - Summer 1973 l'eystene #1 & 2 Rerating -27 Conemaugh Diesels 3 Mile Island E2 5/7'4 'C7 d ,Conenauch #1 (Derated) h/70 13 Union Reach //2 S/74 Ud 1(omer City Reallocation S/70 15 Installed - Sunmer 197h 1: 6 2311 329- ,) Gas Turbines 125 Homer City //3 S/75
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UNITED STATES OF A. ERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Cocket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPONSE TO INTERVENORS' INTERROGATORY Nos. 27 and 32 INTERROGATORY NO. 27 Was the design of the Bechtelsville line influence? in any regard, whatsoever, by agreenents between Metropolitan Edison Company and any other utilities? If so, identify said agreement and produce copies of same. INTERROGATORY NO. 32 Do the applicants justify the design and location of the Bechtelsville line on the basis of any of the aforesaid agreements? If so, identify the section of said agreements that the applicants relied upon. RESPCNS E The planning of the 500KV line from TMI to Hosensack, including the Bechtelsville to Hosensack portion was influenced by certain agreements between Metropolitan Edison Company and other utiEties. These agreements are: 1. Power Pooling Agreement among Pennsylvania Electric Company, Metropolitan Edison Company, 48 2G9
. New Jersey Power & Light Company, and Jersey Central Power & Light Ccmpany, dated July 2, 1969, as supplemented on June 28, 1974. 2. Pennsylvania-New Jersey-Maryland Interconnect-ion Agreement. 3. Extra High Voltage Transmission System Agreement. 4. Mid-Atlantic Area Coordination Agreement. The GPU power pooling agreement reflects, among other things, that Met-Ed and its affiliates constitute an integrated public utility system at the bulk power supply level which essentially means that the physical assets of the system, under normal conditions, may be economically operated as a single interconnected and coordinated system. The PJM agreement is a pooling agreement among six operating entities of which GPU is one. This agreement is the major agreement under which the GPU system as a whole is interconnected with the other PJM signatory entities and, in turn, PJM is interconnected with the outside world through multi-pool agreements. These two agreements influenced the planning that resulted in the Bechtelsville-Hosensack circuit portion in that there is recognition in both agreements of an obligation of each party to install and maintain a proportionate share of the generating capacity and associated transmission of the over-all system. Additionally, under normal operating conditions, and subject to area load protection requirements, the use of the pool power supplying facilities are to be designed to achieve 48 270
h the overall greatest economy. Both of these agreements result in coordinated planning and operation at the bulk pcwcr level of the PJM network. The EHV agreement covers the initial portion of the 500KV system which was provided to transmit the output power of the jointly owned Keystone and Conemaugh mine mouth generat-ing plants to the eastern load centers as well as to provide major interconnections between PJM and other power pools. Although the Three Mile Island to Hosensack 500KV line will not be brought under the EHV agreement, it is relevant in that the 500KV lines for TMI Unit #2 will be connected to the lines covered by that agreement. Therefore, the Unit #2 500KV plans depend upon the prior existence of the EHV system. The last of these agreements is the MAAC agreement. MAAC is an area reliability group consisting of the PJM member en=panies and certain other electric utilities in what is known as the MAAC reliability region. A major responsiblity of this group is to review and approve additions to the bulk power interconnected power system and measure thest. additions against the ' Reliability, Principles and Standards for Planning Bulk Economic Supply System of MAAC Group." The MAAC Agreement influenced the planning of the 500 KV line from Three Mile Island to Hosensack since compliance with the MAAC standarcs is necessary for plan approval. The following Articles and Sectior.s of the above Agreements influenced the planning process that gave rise to 48 271
h the transmission plans for Three Mile Island Unit #2 including the Bechtelsville to Hosensack line section: GPU Power Pooling Agreement Article I, Section 1 Article I, Section 2 Article II, Section 1 Article II, Section 2 PMJ Interconnection Agreement Article 4, Section 4.1 EHV Transmission System Agreement Article 3, Section 2.2 O e YD'k
UNITED STATES OF A". ERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of ) ) METROPOLITAN EC120N COMPANY, ) ET AL. ) Docket No. 50-320 i (Three Mile 1 land Nuclear ) Station, Unit 2) ) APPLICANTS' RESPCNSE TO INTERVENORS' INTERECGATORY NO. 28 INTERROGATORY NO. 28 Is it not so that the design of the proposed Sechtels-ville line as a portion of the line coming from Unit 2 was primarily established so thac power and transmission could be supplied through the Metropolitan Edison's service territory to other electric companies in the power pool, including the other utility applicants herein? If you disagree with said statement, fully set forth the basis for said disagreement and explain fully your answer. RESTONSE The design of the Three Mile Island to Hosensack 500KV circuit was not primarily established so that power and trans-mission could be supplied through the Metropolitan Edison Company's service territory to other electric companies in the power pool. The circuit was primarily established to provide an outlet for TMI Unit 42 generation to Met-Ed's customers with interconnection considerations of secondary importance. The two: functions are not entirely separable since the free flowing i i ' &k.13 Wrf w"" *% f p i 48 273
g, q :-,. _,.: - rdture of the bulk power interconnected MAAC system makes it virtually impossible to identify the routing of any particular unit of power as it flows from gene'rator to load. Recognizing that the major load in the MAAC system is east of the Three Mile Island Generating Station, the plans to provide an outlet for Unit #2 power considered generally west to east transmissio circuits only. No westerly circuit in-o Penelec territory for providing outlet of their share of unit output was necessary. Thus, no additional transmission burden in that direction was imposed. Penelec derives its benefit frcm TMI Unit 42 genera-tion simply by displaced power flow that was previously flowing east. 48 ' 74 2
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinc Board In the Matter of ) ) METROPOLITAN EDISON COMPA'IY, ) ET AL. ) Docket No. 50-320 (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICA';TS' RESPONSE TO INTERVENORS' INTERRCGATORY Nos. 40, 41 and 43 INTERROGATORY NO. 40 With reference to the origiani proposal by the appli-cants, particularly Metropolitan Edison, to construct a line from Bechtelsville to Souderton, please set forth the justi-fication for same with reference to lead forecasts, the neces-sity for said line, and any other analysis :cncerning the appropriateness and necessity of said line for reliability purpose s. INTERROGATORY NO. 41 With reference to the Bechtelsville-Souderton proposal, how, if in any way, did the original analysis of the applicant change with reference to the need of said line concerning reliability aspects, load forecasting, and the other censider-ations set forth in the previous question and answer thereto, with the exception of environmental factors? Set forth your answer in detail and document the foundation for same. INTERROGATORY NO. 43 Produce copies of any and all analyses, documents, studies and memoranda of the applicants concerning the need and propriety for the proposed Bechtelsville to Souderton line. 48 275
e.
RESPONSE
There was never a proposal by Metropolitan Edison Company or the other NRC applicants in this proceeding to construct the circuit from Bechtelsville to Souderton. The Bechtclsville to Souderton line was primarily the responsibility of the Philadelphia Electric Company. Since the Bechtelsville to Souderton 500KV line was a portion of the plan for a third 500KV west to east circuit east of the Susquehanna River from TMI to Bechtelsville to Souderton, cne of the needs for the line was necessarily to accomplish this purrose. Philadelphia Electric Company participated in development o." these plans that gave rise to the circuit, as enumerated in Applicants ' Responwe to Interrogatory Nos. 9, 13, 26, 35, 36. Need for a Bechtelsville to Scuderton 500KV path remains and will be satisfied by the 500KV circuit from Sechtelsville to Hosensack to Souderton. 4 8 c e/ 6' .s.
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. UNITED-ST.kES OF AXERICA s NUCLEAR FIGULATORY CCMMISSICN Before the Atomic Safety and Licensinc Ecard In the Matter of ) ) METROPOLITAN EDISON CCMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICA'iTS' RESPCNSE TO INTERVENORS' INTERRCGATORY NO. 56 INTERROGATORY NO. 56 Is it not so that the Bechtelsville to 3ouderton line would have been closer to your lead and would have resulted in less of a loss of electricity than as compared to the 3echtelsville line? Explain fully your answer. RESPCNSE The plan which included the Bechtelsville to Souderton line also incltded the Bechtelsville to Hosensack 500KV circuit (Bechtelsville line) operated at 230KV. Under either that plan or the plan which has been adopted, power is supplied to Hosensack Substation for distribution to our customers. The electrical line losses of the Bechtelsville to Souderton route, including the Bechtelsville to Hosensack 500KV line operated at 230KV, would have been comparable to those expected on the pre.sent Bechtelsville-Hosensack-Souderton 500KV route. n n~$ 0 )
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO.c!ISSION Before the Atomic Safety and Licensing Board In the Matter of ) ) METROPLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Staiton, Unit 2) ) APPLICANTS' RESPONSE TO INTE RVENORS ' INTE RROGATORY NO. 57 INTERROGATORY NO. 57 Is it not so that the MAAC System Liability Review of the fall of 1971 indicated that the Suchtelsville to Souder-ton line was necessary in order to establish system reliability and should not be delayed beyond June, 1974? If you disagree, please explain fully your answer. If you agree, please ex-plain any changes in j udgment and the basis therefore.
RESPONSE
The 1971 MAAC System Reliability Review did indicate that the Bechtelsville to Scuderton line was necessary to meet the MAAC reliability criteria. S ubs equent reliability reviews have repeatedly recognized the necessity of the TMI-Hosensack-Souderton 500KV circuit to meet the MAAC reliability criterit. In June of 1973, a PJM study, entitled " Review of 1976 PJM Transmissicn System," concluded that the 1976 system without the Hosensack-Souderton 500KV line would not meet the MAAC criteria due to import restrictions for eastern companies. 48 ~ '. 78 A similar study of the 1976 sjstem is now in progress to evaluate compliance with the :G.AC criteria in light of reduced load grcwth and the associated generating unit rescheduling that has transpired since 1973. 48 C79
g UNITED STATES OF AMERICA <? ~~ ~ ] N CC LE A "--72G'JL AMRY - COM2-11 S S I ON - Before the Atomic Safety and Licensinc Board In the Matter of ) ) METROPOLITAN LDISCN CCMPANY, ) ET AL. ) Cocket No. 50-320 ) (Three Miles Island Nuclear ) Station, Unit 2) ) APPLICANTS' PISPONSE TO INTERVENORS' INTERRCGATORY NO. 59 INTERROGATORY NO. 59 Will there be any tap-ins to the Bechtelsville line between Bechtelsville and Hosensak? Would there have been any tap-ins for the line between Bechtelsville and Scuderton? Is it not so that the benefits to be derived from a tap-in were more probable for a Behetelsville to to Souderton line than for a Bechtelsville to Hosenak line? Please explain in detail your answers fully.
RESPONSE
It is highly unlikely that ther, will ever be any tap-ins to the 500KV line between Bechtelsville and Hosensack. Regarding any possible tap-ins for the line between Bechtels-ville and Souderton, Met-Ed is not aware that any tap-ins were contemplated by Philadelphia Electric Company for this circuit. No analysis has been done comparing the probability of 500KV tap-ins along the Bechtelsville to Souderton lina with the probability of 500KV tap-ins along the Bechtelsville to Hosensack line. 48 280
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN Before the Atomic Safety and Licensinc Board In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Statien, Unit 2) ' ) APPLICANTS' RESPONSE TO INTERVENORS' INTERROGATORY NO. 60 INTERROGATORY NO. 60 Is it not so that the transmission line path was recommended and decided as a result of coordinated efforts between Metropolitan Edison, GPU, PJM interconnection, and MAAC? If you disagree, explain fully why you disagree. If you agree, set forth and produce any communication, memoranda, reports, and/or documents concerning the said coordination effort.
RESPONSE
The transmission line path was determined almost entirely by Metropolitan Edison Company. The determination,of the eastern and western transmission line terminals was the result of coordinated study efforts of Metropolitan Edison Company, GPU and certain other PJ:1 member company representatives. Insofar as reliability considerations played a role in the decision, MAAC, too, was involved. MAAC reviewed and approved the GPU report entitled, " Transmission Plans for Three Mile Island Nuclear Generating Station". 48 ' 81 J
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COM24ISSION Before the Atomic Safety and Licens _ng Boa _Ed In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPCNSE TO INTERVENORS' INTERRCGATORY NO. 62 INTERROGATORY NO. 62 Is it not so that the applicant controlsua substation on the east side of the Susquehanna thrcugh which currnet generated at Unit 2 will pass?
RESPONSE
Met-Ed controls the Three Mile Island 500KV substation which is located east of the Susquehanna River. Power generated by the Three Mile Island #2 Unit will be transported directly to the Substation for transmission to other locations. O
UNITED STATES OF AMERICA NUCLEAR REGULATORY CO:siISSION -~ ~ ~ Before the Atomic Safety and Licensinc Board In the Matter of ) ) METROPOLITAN EDISCN COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPONSE TO INTERVENORS ' INTERRCGATORY NO. 63 INTERROGATORY NO. 63 With reference to the answer to the previous question, is it not further so that the; current passing through said substation for Unit 2 would go in two directions: one into an existing 500KV line that would take the electric flow throug&' or tcwards the Juniata line and the other direction would be for the proposed line eventually coming into the Behctelsville line? If you disagree, set forth the facts and basis for your disagreeing with the previous statement and question.
RESPONSE
The power from Three M.i.le Island #2 will split at the TMI 500KV substation. Most will generally flow from inree Mile Island to Hosensack at 500KV; some will be stepped down at the TMI 500KV substation for further transmission at 230KV through the TMI230KV substation to other 230KV substatica locations. It is expected that under varying system operating conditions some power could flow touard Peach Ecttom in the Juniata-Peach Bottom line. Since the major load concentrations 48 283
~2-to in the PJM interconnected system lie to the east of Three Mile Island, power will necessarily tend to flow in that direction. W a e 4 9 48 '284
UNITED STATES OF AMERICA NUC2AR REGULITORY CO>' MISSION Before the Atomic Safety and Licensing Ebard In the Matter of ) ) METROPOLITAN EDISON COMPANY, ) ET AL. ) Docket No. 50-320 ) (Three Mile Island Nuclear ) Station, Unit 2) ) APPLICANTS' RESPONSE TO INTERVENORS ' INTERROGATORY NO. 64 INTERROGATORY NO. 64 Set forth the reasons why all the electricity from Unit 2 could not be transmitted in the direction or through the Juniata line, giving particular reference to the construction of additional transmission facilities along the right-of-way of the Juniata line. _ RESPONSE All the electricity from Three Mile Island L 12 could not be transmitted through the existing Juniatt _ rtil it' for several reasons. First, as a contractural matter the Juniata line is jointly owned by those companies signatory to the Extra High Voltage Transmission System Agreement and additional input of power into that system is not allowed without agreement of all parties. Second, transmitting all the electricity from Unit 2 through the Juniata line would not have been acceptable since the potential for overloads that might occur in the future for certain 500KV outages would only have been aggravated by this operation. This would have violated AB 285
(..% J ~ v the M4AC criteria. Finally, construction of transmission facilities alorig the right-of-way of the Juniata line would have required a much more lengthy routing to feed our customers from Hosensack than the plan adopted requires. With reference to the possibility of constructing additional tranmission facilities along the Juniata line right-of-way, the nature of the transmission system load and genera-tion is such that a transmission circuit from west to east such as the TMI to Hosensack to Scuderton (Elroy) circuit provides the greatest benefit to all companies. Additionally a 500KV circuit adjacent to an existing 500KV line is not desirable, since a single outage can simultaneously interrupt two major transmission paths. 48 CS6}}