ML19319C500
| ML19319C500 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 10/17/1975 |
| From: | Mayben W Atomic Safety and Licensing Board Panel, R.W. BECK & ASSOCIATES |
| To: | |
| References | |
| NUDOCS 8002190937 | |
| Download: ML19319C500 (31) | |
Text
.-
e-UNITED STATES OF AMERICA Q
NUCLEAR RF 3ULATORY COMMISSION 06 QlT2 1
Before the Atomic Safety and Licensing Board 2
3 In the Matter of
)
)
, -7 Docket Nos.1' 50-3-lhA 4
The Toledo Edison Company, et al.
)
50-500A (David-Besse Nuclear Power Station, )
50-501A 5
Units 1, 2 and 3)
)
)
6 The Cleveland Electric Illuminating
)
Docket Nos. 50-440A Company, et al.
)
50-441 A 7
(Perry Nuclear Power Plant, Units
)
l and 2)
)
8 9
TESTIMONY OF WILLIAM R. MAYBEN 10 11 Q.
Please state your name and address.
My name is William R. Mayben and my residence is No. 49, 12 A.
13 Stires Lake, Columbus, Nebraska.
14 Q.
What is your occupation?
15 A.
I am a registered professional engineer and a partner in the 16 consulting engineering firm of R. W. Beck and Associates.
17 Q.
Would you describe R. W. Beck and Associates.
18 A.
R. W. Beck and Associates is an analytical and consulting 19 engineering firm providing consulting engineering services 20 extensively throughout the United States and in certain inter-21 national locations. The firm, owned by a partnership of 18 professional engineers and economists, employs over 320 22 professional and support personnel to prosecute our various 23 24 a s signments. The firm provid s a full range of consulting fsu N
8002190 g
/
1 engineering services involving virtually all engineering, economic 2
and environmental disciplines. We have offices in seven cities 3
throughout the country, with our general office in Seattle, Wa shington.
4 Q.
What is your educational background?
5 A.
I graduated from the University of Colorado, Boulder, Colorado, in 6
June of 1962 receiving a Bachelor of Science Degree in Electrical 7
Engineering.
8 Q.
In what states are you registered to practice engineering?
9 A.
I hold registration as a professional engineer in Chio (No. 36140) 10 and some thirteen additional states.
11 Q.
Would you briefly describe your responsibilities with R. W. Beck 12 and Associates.
13 A.
Since 1968, I h- - %en a partner and supervising executive engineer.
14 As such, I ha,
.ne direct responsibility for the activities of the firm's 15 offices in Columbus, Nebraska, and Indianapolis, Indiana. My business iE address is 1453 29th Avenue, Columbus, Nebraska 68601. I supervise 17 a large staff of engineers and utility analysts who provide consulting 18 engineering services to our various utility clients throughout the 19 midwestern part of the United States.
20 Q.
Would you briefly state your professional engineering experience as 21 it relates to power system planning, design and operations.
22 A.
For two and one-half years following my initial employment by 23 R. W. Beck and Associates in 1962, I was assigned to the firm's 24 design office where I worked principally on design of power generating s
i 1
stations, high-voltage transmission lines and substations. I have 2
had complete responsibility for design and construction of trans-3 mission and substation facilities with voltages ranging from 4.16 kV 4
to 230 kV.
For intermittent periods prior to 1965 and extensively 5
since then, I participated in power supply planning for several 6
electric utilities conducting transmission studies and economic 7
evaluations. My work has been particularly concerned with power 8
pooling and coordinated power supply among utility systems.
9 I served as the principal systems engineer to the Missouri 10 Basin Systems Group (MBSG), a power planning and power pooling 11 organization, whose electric utility members have generation and 12 transmission facilities covering a multi-state area in the Upper 13 Missouri River Basin Region. In this capacity, I served on
- arious i
14 engineering committees responsible for planning the expansion of 15 power supply and transmission systm facilities in the Forth Central 10 Region of the United States. Since 1967, I have been wc rking exten-17 sively in development and implernentation of an ongoing bulk power supply program for the Nebrassa Public Power Distric', a utility f
18 19 which has the bulk power responsibility for a major por tion of the
'O State of Nebraska. As part of this assignment, I have participated 21 in the development of plans for interconnection to and.ntegration with 22 the state and regional power systems of generation ou ned and operated by 23 NPPD consisting of an 800 MWe nominally rated nuclear generating 24 station, a 650 MW coal-fired thermal electric generating station and i.
I 150 hiW of oill-fired combustion turbine generating capacity. I have 2
also had the primary responsibili*r for determining the technical and l
3 financial feasibility of the Nebraska power resource expansion pro-4 grams while s erving as NPPD's independent consulting engineer 5
pursuant to the terms of that utility's revenue bond indentures.
6 I have worked with power supply utilities in developing coordi-7 nated long-range power resource expansion programs in various other 8
regions of the country. Such assignments have included the preparation 9
of power pooling agreements and other documents to accomplish coor-10 dinated development and integrated power supply operations among 11 utilitie s.
12 Q.
Have you conducted power supply studies for small electric utilities 13 such as municipally owned systems?
14 A.
Yes, I have personally prosecuted such studies and in recent years 15 have supervised staff prosecution of several power supply studies 16 for small municipal electric utilitlas contemplating various alterna-17 tive methods of meeting their iature power supply requirements. Such 18 studies usually include an economic evaluation of various power supply 19 alternatives readily available to the municipal electric utility and the 20 preparation of a report setting forth the results of such studies and 21 making recommendations concerning the method of meeting the utility's 22 future load growth.
23 Q.
Have you participated in negotiation of contracts concerning 24 coordinated power supply among utilities?..
.~
~
1 A.
Yes, I have participated in the negotiation of contracts where I 2
have represented small electric utility systems seeking coordinated 3
development and coordinated power supply operations with larger 4
power supply utilities. In addition, I have provided technical assist-1 5
ance to a large utility client who was negotiating on reasonably equal 6
terms for coordinated power supply with another comparably sized 7
utility. Finally, I have had experience in representing a large utility 8
client dealing with a much smaller utility seeking coordinated power 9
supply arrangements.
10 Q.
Have you had experience in the area of wholesale power rates, trans-11 mission rates and rates for other forms of utility service?
12 A.
Yes, I have conducted cost analyses and cost recovery studies for 13 clients providing wholesale power service and transmission service.
14 In addition, I have participated in negotiations and litigation providing 15 technical assistance to our clients seeking changes in tariff provisions 4
16 for full and partial requirements, wholesale power service, transmission 17 service and other forms of services usually rendered by utilities engaged 18 in interconnected and coordinated power supply operations.
19 Q.
Have you ever appeared a ~ an expert witness before State or Federal 20 regulatory agencies ?
21 A.
Yes, I have appeared before State regulatory commissions on matters 22 pertaining to power resource development. In addition, I have partici-23 pated as an expert witness in proceedings before the Federal Power 24
. Commission and before the Atomic Energy Commission. i 1
1 I appeared before the FPC in its Docket E-7278 as an expert 2
witness for the Missouri Basin Municipal Power Agency and the 3
Village of Elbow I.ake in the proceeding against the Otter Tail Power 4
Company, where Elbow Lake sought an electrical interconnection with 5
Ctter Tail. In that particular proceeding, I developed testimony and 6
was examined on matters relating to appropriate terms for interconnection 7
and interconnected operation between Elbow Lake and Ctter Tail Power.
8 I have also appeared before the FPC in its Docket E-7740 on 9
behalf of Richmond Power and Light, a municipally owned utility in 10 Richmond, Indiana, which has intervened in opposition to the filed 11 application for an increase in wholesale power rates by the Indiana-12 Michigan Electric Company. My testimony and examination pertained 13 to interconnected operations designed to permit more effective utiliza-14 tion of Richmond Power and Light's existing generation. In this particu-15 lar case, I outlined principles for reserve sharing between Richmond 16 Power and Light and the American Electric Power System and made 17 an analysis of the economic effect of the application of such reserve 18 sharing principles.
19 I appeared before the FPC in its Docket E-7704, et al. on behalf 20 of the Kentucky-Indiana Municipal Power Association and on behalf of 21 the City of Frankfort, Kentucky, i~n their respective intervention in 22 several dockets involving, among other matters, the filing of the 23 Kentucky-Indiana Power Pool (KIP) Agreement. The nature and purpose 34 of these intervenors' case before the FPC involves coordinated power i
r--
1 supply development and interconnected operations of the KIP Pool and 2
the admission policies of the pool. In this particular case, I proffered
.3 testimony and was examined on matters pertaining to the methods in 4
which a small electric utility or a group of small utilities might coor-5 dinate their respective power supply operations with members of an 6
existing power pool.
7 I have appeared before the AEC in its Dockets Nos. 50-329A and 8
50-330 A in the matter pertaining to Consumers Power Company's Mid-9 land Plant Units 1 and 2, and in Docket Nos. 50-348 A and 50-364A in 10 matters pertaining to Alabama Pnwer Company's Farley Units. I 11 appeared in that proceeding on behalf of the Department of Justice for 12 the principal purpose of outlining generally accepted nrinciples of 13 coordinated power supply development and coordinated power supply 14 operations among utilities.
15 Q.
On whose behalf do you appear in this proceeding?
16 A.
I am offering this testimony on behalf of the City of Cleveland.
17 Q.
T/ould you explain the nature of the assignment received by your 18 firm from the City of Cleveland.
19 A.
My firm has been providing consulting engineering services of a 20 specified nature to the Division of Light and Power of the Department 21 of Public Utilities of the City of Cleveland since May of 1973.
22 Generally speaking, the assignments have been associated with 23
. matters concerning the Division's electric power supply, either 24 generation or interconnections to the Cleveland Electric Illurmnating 25 Company., _ _ _.
1 Q.
What is the scope of your testimony in this proceeding ?
2 A.
I intend to describe the Division's present mode of bulk power supply 3
and discuss in general terms, without quantitive example, what is 4
required by the Division in its relatiocship with the Cleveland Electric 5
Illuminating Company to gain access to regional power exchanges where 6
various forms of bulk power exchanges are available to utilities and 7
access occurs to ownership in power generating facilities displaying 8
the highest level of technology and the best characteristics of 9
economies of scale.
10 Q.
First, would you describe the nature of the Division's power supply 11 operations ?
12 A.
The Division has installed generating facilities with an aggregate 13 nominal generating capacity of 205,000 kilowatts although the reported 14 net capability demonstrated to date is 180,000 kilo watts. The 15 generating capacity consists of three steam electric generating units 16 each rated 25,000 kilowatts net capability, one 85,000 kilowatt steam 17 electric generating unit with demonstrated maximum net capability of 13 60,000 kilowatts, and three dual-fuel (gas and oil) combustion turbine 19 generating units each rated 16,500 kilowatts but with a demonstrated j
20 maximum net capability aach of 15,000 kilowatts. The Division's 21 electric system is temporarily interconnected with the electric system 22 of CEI at a 100,000 kva and 138 kv substation owned by the City and 23 connected at the end of a 1.6 mile 138 kv transmission circuit from 24 CEI's Lake Shore Station located within the City of Cleveland.
4 1
The Division presently operates its generating units at whatever 2
loading levels are mechanically possible so as to keep the amount 3
of energy received by the Division over the 138 kv interconnection
- 4 with CEI at an absolute minimum.
5 Q.
Is the demonstrated net of their generating units sufficient to meet 6
the peak load of the Division?
7 A.
Yes. The Division's greatest measured peak load prior to com-8 pletion of the 138 kv interconnection was 123,000 kilowatts, occurring 9
in September,1973, which is less than the demonstrated net capability 10 of the aggregate of the Division's generating units. However, if 11 allowance is made for capacity reserves, which in the Division's 12 case at that time was an amount equal to the capacity of the Division's 13 largest single generating unit, the assured net demonstrated aggregate 14 capacity was less than the experienced peak load.
15 Q.
How was the Division able to avert power outages in September,1973, j
16 if its assured net demonstrated aggregate capacity was less than the 17 Division's peak load ?
18 A.
At that particular time, the Division had their largest unit available 19 for service and did not incur a forced outage which gave the Division 20 sufficient generating capacity synchrenized to the system to meet the 21 load.
22
'Q.
What would have happened had the Division experienced a forced 23 outage of the 60,000 kilowatt generating unit at the time the Division's 24 measured peak load was at or near 127,000 kilowatts ? __
1 A.
Some or all of the electric customers of the Division would have 2
experienced an outage while the Division and CEI made arrange-3 ments to transfer a fraction of the Division's electric distribution 4
system over to the CEI electric system to secure emergency service, 5
thus making the amount of load remaining on the Division's electric 6
system equal to or less than the capability of the generating units 7
synchronized to the system.
8 Q.
You previously described an interconnection between the electric 9
systems of the Division and CEI. How long has this been in existence ?
10 A.
Since May 4,1975.
11 Q.
What existed prior to that date s'hich would cause an outage to electric 12 customers of the Division for the Division to receive emergency 13 service from CEI?
14 A.
Prior to the existence of the temporary 138 kv synchronous inter-15 connection between the electric systems of the Division and CEI, 16 emergency service was afforded to the Division by two means. The 17 first, perfected in February,1970, was an arrangement where 18 segments of the Division's low voltage' distribution system would be 19 physically disconnected from the Division's electric system and 20 reconnected to CEI's electric system. These disconnects and 21 reconnects occurred at locations commonly referred to as the " load 22 transfer points" on the Division's electric system and caused the 23 customers of the Division to suffer an interruption of electric 24 service while the disconnect-reconnect process was accomplished.
25 They suffered a similar interruption when the transfer br k to I
the Division's electric system occurred. A second emergency 2
type interconnection other than the load transfer points, perfected in 3
September,1972, was a 69 kv non-synchronous tie between the 4
transmission systems of the Division and CEI which required 5
segregation of an even larger segment of the Division's electric 6
system be interrupted of electric service to permit the Division to 7
recover emergency service from CEI. A similar interruption of 8
electric service was incurred to transfer the segment of the Division's A
9 system back to the Division upon alleviation of the emergency.
10 Q.
Would you describe the present electric interconnection and emergency
^
11 service relationship between the Division and CEI?
12 A.
As I previously testified, the electric systems of the Division and 13 CEI are temporarily synchronously interconnected at 138 kv through 14 a 100,000 kv and 138/64 kv substation owned by the City. An inte r-15 connection agreement dated April 17, 1975, provides that the Division 16 may receive emergency service up to the amount available from CEI 17 but not in excess of the capacity of the interconnection. Thus, when 18 the Division experiences an outage of onb or more of its generating 19 units and is unable to meet the bulk power requirements of its electric 20 customers, it requests and receives emergency service from CEI 21 over the temporary 138 kv synchronous interconnection without inter-22 ruption of service to retail customers of the Division.
23 Q.
What wculd happen if the emergency service requirements of the 24 Division were to exceed the capacity of the temporary 138 k".. --.
1 synchronous interconnection or exceed the amount of emergency 2
service which CEI could supply at its Lake Shore Station.
3 A.
The Division would again be faced with interruption of service 4
to some of its customers while a segment of its electric distribution 5
system would be disconnected and reconnected to the electric 6
system of CEI.
7 Q.
How important is adequate emergency service to the Division 8
from CEI?
9 A.
Very important, in terms of reliability of service to the Division's 10 electric customers and in terms of retaining existing customers 11 and gaining additional ones. The Division's outage record increased 12 by the dead bus transfer of segments of its system during emergencies 13 has been generally detrimental to the Division's ability to retain 14 existing customers and attract new ones.
15 Q.
Is the importance of emergency service in the Division greater than 16 you customarily find in the industry?
17 A.
Yes, to a substantial degree.
18 Q.
What in your opinion is the cause of this greater necessity for 19 adequate en ergency service by the Division?
20 A.
The fundamental reason is the poor condition of the generating 21 facilities of the Division caused presumably by inadequate routine 22 maintenance and repair of the equipment which is normally 23 practiced by electric utilities throughout the industry.
y=
1 Q.
Do you see any particular reason from an engineering viewpoint why 2
the Division would have maintenance and repair practices different 3
than normally found in the industry?
4 A.
Yes. Prior to the completion of the temporary 138 kv synchronous 5
interconnection, the Division would have been reluctant to remove 6
generating units from service for maintenance or repair during 7
off-peak periods when maintenance is rountinely scheduled because 8
to do so would require a dead bus tri nsfer should forced outage 9
of a remaining unit occur during the maintenanc.: period or shou?d 10 removal of a particular unit result in the capacity of the remaining 11 units be less than the expected maximum load during the scheduled 12 outage. Thus generating equipment went for long periods wit).out 13 routine maintenance and repair resulting in a general detoriation 11 of equipment and reduction in reliability performance to levels 15 substantially below facilities of comparable size and characteristics 16 in the industry dependant upon self generation which demonstrates 17 such disrepair of its generating equipment and therefore places 18 so much dependence upon its interconnections for emergency service.
19 Q.
In your opinion, could this situation have been avoided?
20 A.
Yes. Had the Di.tsion been granted a synchronous interconnection 21 with CEI at the time it began discussing an interconnection in the fall 22 of 1962 and had routine coordination of scheduled outages of generating 23 units for maintenance been established between the Division and 24 CEI as is practiced usually by interconnected utilities, the 1
Division could have kept its generating equipment in good repair 2
without fear of interruption of electric service to its customers.
3 Q.
What are the economic consequences to an electric utility of the 4
electrical interconnection and emergency service arrangement 5
which now exist between the Division and CEI?
6 A.
With the Division taking virtually its total requirements over the 7
interconnection as emergency service under the tariff for emergency 8
serivce provided by CEI to the Division, the Division is charged for 9
emergency energy supplied on the basis of the highest incremental 10 cost incurred each hour to produce electric energy plus 10 percent 1i At the same time, the Division continues to incur the City's cost of 12 ownership of the generating facilities and the fixed operating costs 13 associated with the personnal to operate and maintain the facilities 14 which are now in such disrepair as to be unable to produce energy.
15 The economic results is that the Division is incurring hourly variable 15 cost equal to the highest hourly incremental costs of CEI and total 17 average cost of service far in excess of CEI's average costs. These 18 costs are in excess of the revenues derived by the Division from its 19 electric rates, which rates are expected to be competitive with those 20 of CEI. The economic consequence is the same as any business enter-21 prise whose costs exceed the price which the public has a choice to b ear.
22 Q.
What is the logical engineering solution to the Division's dilemma of 23 poor repair and reliability of internal generation, virtual total 24 dependance upon the temporary 138 kv synchronous interconnection i
i n
a 4
1 1
and hourly incremental pricing of emergency interchange service 2
from CEI.
3 A.
The Division must seek to lower the price of replacement energy 4
while it proceeds with a logical program to rehabilitate its existing 5
generating equipment and must obtain through coordinated develop-t l
6 ment with other utilities, power supply from the largest, most modern 7
resources avsilable to other utilities in the region.
8 Q.
Are you generally familar with the competitive situation between 9
the Division and CEI with respect to existing and potential future 10 retail electric customer in the Cleveland area?
e 11 A.
Yes, I am generally fr.milar with the competitive position of the 12 Division with respect to retaining its existing customers and 13 attracting new ones. If the Division does not gain access to lower 14 cost replacement energy permitting it to begin a generating equipment 15 rehabilitation program, its short run costs of power supply will be 16 higher than that supportable by the competitive level of retail rates 17 in the area. If the Division does not obtain access to other forms 18 of bulk power supply including but not limited to partial requirements 19 purchase of firm power from CEI.or other bulk power supplies, j
20 joint ownership of generating resources with or without power 1
21 purchases from CEI or other bulk power supplies and other forms 22 of power interchange, the Division's long run cost of power supply l
23
- will be higher than supportable by the competitive retail rates in 5
24
~ the area.,
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v-
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1 Q.
Have you undertaken studies of future power supply for the Division?
2 A.
In a general way, primarily to ascertain whether or not nuclear 3
capacity could be expected to be beneficial to the Division. M y fir m 4
also analyzed the cost of power supply for a short run period during 5
which the Divisions' internal generation was scheduled for repair 6
and rehabilitation.
7 Q.
If you were authorized to undertake specific studies to ascertain 8
the Divisions mode of future power supply, what would be the 9
approach employed?
10 A.
The first prerequisite to such a study would be an understanding 11 with regard to the possible future relationship between the Division 12 and CEI. For the studies, and therefore the results to be meaning-13 ful at all in todays power supply economy, some or all of the prin-14 ciples of coordinated development and coordinated operations as 15 engaged in by virtually all of the large utilities in the industry, 16 would have to be embodied in the understanding between the Division 17
. and CEI.
18 Q.
You have used the terms " coordinated operations" and " coordinated 19 development'. Would you explain them as they apply to bulk power 20 supply?
21 A.
The leading companies in the electric utility industry recognized 22 long ago that reliability and economies of bulk power supply could 23 best be achieved through coordination. Early in the development 24 of the electric industry, limited coordination was of course required I
when two utilities established synchronous interconnection between 2
their electric systems. That simple form of coordination has been 3
expanded in scope and complexity to encompass the regional power 4
pools which exist today throughout the industry. Some of the 5
coordination is achieved through a corporate relationship such as 6
with the member companies of the American Electric Power 7
Corporation and some coordination is achieved through contractual 8
relationship such as with the members of CAPCO.
9 Coordinated operations depict the hour by hour, day by day 10 and to some extent seasonal operations between utilities who are 11 synchronously interconnected and operating their cespective electric 12 systems in a manner to cause more than a casual interchange of 13 power and energy to occur. Forms of coordinated operations found 14 in interchange or power pooling agreements among utilities and 15 which would be of importance in the understanding between the 16 Division and CEI in perfection of a suitable bulk power supply 17 program for the Division are:
18 (a) Reserve sharing and mutual emergency support.
19 (b) Emergency energy interchange.
20 (c) Maintenance scheduling and maintenance power interchange.
21 (d) Transmission service.
22 (e) Short-term power and ener'gy interchante.
23 (f) Spinning reserve interchange.
j 24 (g) Diversity interchange (time zone).
1 25 (h) Economy interchange including peaking power service.
1 Coordinated development depicts the types of relationship between 2
two or more utilities which are designed to cause the most economic 3
method of expansion of power generation and transmission facilities 4
by and among such utilities consistent with a proper balance of fuel 5
types and reliability standards. Forms of coordinated development 6
found in the industry and of interest to the Division in perfection of a 7
suitable bulk power supply program are:
8 (a) Generating unit participation.
9 (i)
Common ownership 10 (ii)
Unit power purchase 11 (b) Transmis sion participation.
12 (c) Transmission system interconnection and expansion.
13 (d) Staggered construction of generating units accomplished 14 through planned exchanges of surplus power.
15 (e) Diversity power interchange (seasonal).
16 (f) Firm power sales.
17 Q.
Could the Division expect to develop a bulk power supply program 18 without the forms of coordination you have previously identified?
19 A.
It would be physically possible for the Division to perfect a bulk 20 power supply program absent the aforelisted items of coordination 21 contemplating that new generating equipment would be sited, sized 22 and scheduled in accordance with Division's requirements only.
23 However, in view of the present magnitude of the Division loads 24 such a bulk power supply plan is predictably higher in cost and )
c therefore' economically infeasible in comparison to a plan or plans I
2 involving coordination. This infeasibility would be due in part to the substantial amount of reserve capacity required by the Division 3
to protect against loss of load caused by scheduled or forced outage 4
5 of generating capacity. Also, such an independent plan would deny 6
the Division access to the full benefits of scale which are inherent in large base load steam electric generating stations, including the 7
8 size of nuclear power plants which is the topic of these proceedings.
9 Q.
You have listed transmission as being an item of coordinated 10 operations and coordinated develepment. Would you explain?
The transmission noted under coordinated operations is the type 11 A.
12 existing between two utilities where a leap-frog interchange of a short 13 term nature, either daily, monthly or seasonally, with a third utility 14 is desirable for reliability purposes, economic purposes or both.
15 This type of transmission service is usually on an if-and-when 16 capacity available commitment without specific transmission 17 facilities constructed except those which permit the interconnections 18 in the first place. Compensation for the service can be either in kind, The 19 energy losses, or monetary through specially designed rates.
20 transmissica cded under coordinated development is the type where 21 one utility will agree to transmit specific blocks of power across its system, or over specific facilities for a longer period of time ranging 22 23 from a season to several years when necessary. This type of 24 transmission service is usually associated with a form of coordinated _
6 I
development of power supply resources and usually requires the 2
construction or dedication of specific facilities. Compensation for 3
this type of transmission can be in the form of contribution of 4
transmiss' ion facilities, contribution of construction capital, or a 5
rate reflecting the supplying utility's long run costs of providing 6
the service.
7 Q.
Would such transmission arrangements between the Division and 8
CEI be important to the Division ?
9 A.
Yes. Both types of transmission arrangements are essential if the 10 Division is to achieve access to regional power exchanges.
11 Q.
Could the Division expect to construct its own transmission lines 12 to effect interconnection with power supply utilities other than CEI 13 so as to obviate the need for the transmission relationship you 14 describe as being essential for the Division ?
15 A.
No. An interconnection can be considered feasible if the benefits 16 derived from such interconnection are equal to or greater than the 17 cost of perfecting the interconnection. In the case of the Division, 18 its electric system is surrounded on three sides by the highly 19 urbanized part of the City and on the north by Lake Erie. In my 20 judgment, the magnitude of the interchanges which could be of 21 benefit to the Division would not be sufficient to justify the cost of 22 the facilities.
23 Q.
Are you aware of any opportunities which exist or have existed when 24 the Division could have benefitted by a transmission arrangement i
25 with CEI? l
1 A.
Yes.
2 Q.
Would you identify them?
3 A.
The Division has engaged in discussion with the Power Authority of 4
the State of New York to acquire an allocation of firm hydro power.
5 The Division has also discussed purchasing seasonal power from 6
Buckeye, Inc., a power supply entity serving the cooperatives in 7
Ohio. The Division has also been approached by the City of Richmond, 8
Indiana, concerning short term interchanges. While I have not 9
analyzed the specific interchange propositions, they certainly appeared 10 on the surface to be of benefit to the Division in comparison to the 11 prices it sometimes pays for emergency energy from CEI.
12 Q.
If the Division were to completely rehabilitate one of its own local 13 generating facilities, would that eliminate its need for coordinated 14 operations and development ?
15 A.
No. If the Division could establish its generating equipmeni. as 16 normally reliable, it would need such features of coordinated 17 operations as reserve sharing, emergency interchange, and scheduled 18
- maintenance outage power in order to insure reliability of electric 19 service and economies of bulk power supply. With these benefits 20 of coordinated operation associated with the Division's existing 21 power supply resources, I would then predict a growth in power supply requirements like other utilities experience which would 22 23 create the need for coordinated development to give the Division 24 access to the best technologies in the industry. 1
D.
1 Q.
Could the Division expect to :onstruct its own nuclear generating 2
station ?
3 A.
No, principally because of its size and the least size nuclear units 4
now considered to be economically feasible.
5 Q.
In your opinion is it necessary for the Division to obtain direct 6
- access to nuclear energy?
7 A.
Yes. Because nuclear capacity represents an important energy 8
resource. To be denied access just because the Division is too 9
small to justify independent development of such a facility would 10 force the Division to use resources of less desirability.
11 Q.
Are you familiar with the Policy Commitments of CEI dated 12 May 22, 1974 ?
13 A,
- yes, 14 Q.
Do you consider the Commitments to be within your requirements for 15 arrangements between the Division and CEI for coordinated 16 operation and coordinated development?
17 A.
No. They fail in one major respect, namely, transmission.
18 Q.
Have you prepared an exhibit setting forth those forms of access 19 and coordination which yo t feel would be satisfactory in an arrange-20 ment between the Division and CEI?
21 A.
Yes, I have prepared Exhibit No.
(WRM-1) which sets forth these matters in terms of proposed license conditions for the Perry 23 and Davis-Besse plants. __.
Exhibit No.
(WRM-1)
Fobruary 28, 1974 LICENSE CONDITIONS FOR DAVIS-BESSE NUCLEAR POWER STATION, PERRY NUCLEAR POWER PLANT, UNITS 1 AND 2, AND BEAVER VALLEY POWER STATION, UNIT 2.
DEFINITIONS 1
" Company" means severally and jointly, the Cleveland Electric I
Illuminating Company, the Toledo Edison Company, Duquesne Light Company, Ohio Edison Company and Pennsylvania Power Company and each subsidiary, affiliate or successor company engaged in the genera-tion, transmission and/or the distribution of electric power in the States of Ohio and Pennsylvania, 2.
" Bulk Power" means the electric power and attendant energy supplied I
or made available at transmission or subtransmission voltage.
3.
" Costs" means all appropriate operating and maintenance expenses anr all ownership costs where applicable.
4.
" Entity" means a person, a private or public corporation, a governmental i
agency or authority, a municipality, a cooperative or an association owning or operating or proposing in good faith to own or operate facilities for generation, transmi'Jsion and/or distribution of electric power and energy.
5.
"CAPCO" means Central Area Power Coordinating Group or its members.
POLICY COMMITMENTS 1.
The Company shall afford to the City of Cleveland participation in Davis-Besse Nuclear Power Station through ownership or the purchase of unit power in the amount of 55,000 Kw.
2.
The Company shall afford to the City of Cleveland participation in Beaver Valley Power Station, Unit 2, through ownership or the purchase of unit power in the amount of 26,600 Kw.
3.
The Company shall afford to the City of Cleveland participation in Perry Nuclear Dower Plant, Units 1 and 2, through ownership or the i
purchase of unit power in the amount of 30,100 Kw in each unit.
4.
In connection with the City of Cleveland's participation in Davis-Besse, l
]
Beaver Valley and Perry units, the Company also will interconnect with i
and provide the necessary transmission services required for delivery of the power and energy from such units to the City of Cleveland at a point or points on the Company's transmission system to which the City of Cleveland is interconnected, on a basis that will fully compensate the
-Company for its costs, including a reasonable return on investment in connection therewith.
1 5.
The Company shall afford to any entity (ies) in Company's service area (s) opportunity to participate in any of CAPCO's future generating plants or units through ownership or the purchase of unit power on reasonable terms
d and conditions and on a basis that will be fully compensatory for the costs involved in the construction and operation of the plant or units.
In connection with such participation, the Company also will inter-connect with and provide transmission service as may be required for delivery of such power and energy to such entity (les) at a point or points on the Company's electric system (s) on a basis that will fully compensate it for its costs, inclui ng a reasonable return on investment in connection therewith.
6.
The Company will interconnect and enter into an arrangement for equalized reserves between the Company and any entity (ies) on terms which cause the Company and the entity (ies) to maintain, or acquire if necessary, equal percentage capacity reserves as such reserves relate to the parties' annual peak load. To the extent that capacity reserves are acquired by the entity (ies) from the Company to satisfy the equalized reserve arrangement of the entity (ies), such sale by the Company will be made, only if available and on terms that will provide for the Company's costs, inciuding a reasonable return on investment in connection therewith.
7.
Emergency service and/or scheduled maintenance service to be pro-vided by each party as a part of an equalized reserve arrangement shall be furnished to the fullest extent available from the supplying party and desired by the party in need. The Company and each entity (ies) shall provide to the other emergency service and/or scheduled maintenance service if and when available to the extent they can do so without im-pairing service to their customers, including other electric systems to whom they have firm commitments. Sharing of reserves during a period of emergency or scheduled maintenance outage will be accom-plished through the sale and purchase of emergency and/or scheduled maintenance energy at incremental cost of production plus a nominal allowance for handling the transaction.
8.
The Company and the entity (ies) to an equalized reserve sharing arrangement shall establish the daily minimum operating reserves to be maintained by the parties and the Company and entity (ies) will share such daily operating reserves on an equalized percentage basis. The level of daily minimum operating reserves shall be determined in accordance with ECAR Document #2
" Daily Operating Reserves,"
or whichever criteria are being practiced at the time by t' e Company and other utilities in the area. Such daily minimum operating reserve requirements can be satisfied by the parties through purchase of opera.
ting reserves.
9.
Interconnections will not be limited to low voltages when higher voltages are available from the Company's installed facilities in the area where interconnection is desired, when the proposed arrangement is found to be technically and economically feasible. Control and telemetering facilities
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shall be provided as required for safe and prudent operation of the inter-connected systems.
10.
Interconnection and coordination agreements shall not embody any restrictive provisions pertaining to intersystem coordination. Good industry practice as developed in the area from time to time (if not un-reasonably restrictive) will satisfy this provision.
11 The Company shall provide transmission services to facilitate the exchange of bulk power by transmission over its transmission facilities between or among two or more entity (ies) with which it is interconnected, and between any such entity (ies) and such other entity (ies) whose facilities the Company's transmission lines and other transmission lines would form a continuous electrical path, provided that (a) permission to utilise such other transmission lines has been obtained by the proponent of the arrangement, and (b)the arrangements reasonably can be accommodated from a functional and technical standpoint. Such transmission shall be on terms that fully compensate the Company for its costs, including a reasonable return on investment. Each request for such transmission shall include reasonable advance notice : the scheduling and require-ments. The Company shall not be required to enter into any arrangement which would impair system reliability or emergency transmission capa-city, it being recognized that while some transmission may be operated fully loaded, other transmission may be for emergency use and operated either unloaded o'r partially loaded. (The foregoing applies to any entity (ies) to which the Company may be interconnecte'd in the future as well as those to which they are now interconnected).
12.
The Company shall include in its plaiining and construction programs sufficient transmission capacity as required for the transactions re-ferred to in paragraph 11, provided the Company is given sufficient advance n'otice to accommodate the requirements from a functional and technical standpoint and that the Company shall be fully compensated for its costs, including a reasonable return on investment. The Company shall not be required to construct transmission facilities in paragraph 11 if it finds construction of such facilities infeasible, or if it finds such would impair system reliability or emergency transmission capacity.
13.
The Company will enter into arrangements with entity (ies) for the sale of firm power and energy to meet all or a portion of such entity (ies) power requirements at rates which will compensate the Company for its costs, including a reasonable return.,
e CERTIFICATE OF SERVICE I hereby certify that service of the foregoing Testimony Of William R. Mayben, has been made on the following parties listed on the attachment hereto this 17th day of October,1975, by depositing copies thereof in the United States mail, first class or air mail, postage prepaid.
W J G M d., M David C. Hjelngelt /
Attachment
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ATTACHMENT Douglas V. Rigler, Esq., Chairman Ivan W. Smith, Esq.
Atomic Safety and Licensing Board Panel John M. Frysiak, Esq.
Foley, Lardner, Hollabaugh and Jacobs Atomic Safety and Licensing Board Panel 815 Connecticut Avenue, N. W.
U. S. Nuclear Regulatory Commission Washington, D. C.
20006 Washington, D. C.
20555 Alan S. Rosenthal, Chairman Richard S. Salzman, Chairman Atomic Safety and Licensing Appeals Board Atomic Safety and Licensing Appeals Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Dr. John H. Buck Michael C. Farrar Dr. Lawrence K. Quarles Dr. W. Reed Johnson Atomic Safety and Licensing Appeals Board Atomic Safety and Licensing Appeals Board U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Howard K. Shapar, Esq.
Andrew F. Popper, Esq.
Executive Legal Director -
. Office of the Executive Legal Director U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Washington, D. C.
20555 Mr. Frank W. Karas, Chief Benjamin H. Vogler, Esq.
Public Proceedings Branch Joseph Rutberg, Esq.
Office of the Secretary Robert J. Verdisco, Esq.
U.S. Nuclear Regulatory Commission Roy P. Les sy, Jr., Esq.
Washington, D. C.
20f'3 Office of the General Counsel Regulation Abraham Braitman-, Esq.
U. S. Nuclear Regulatory Commission Office of Antitrust and Indemnity Washington, D. C.
20555 U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Melvin C. Berger, Esq.
Joseph J. Saunders, Esq.
Frank R. Clokey, Esq.
Steven M. Charno, Esq.
Special Assistant Attorney General David A. Leckie, Esq.
Towne House Apartments, Room 219 Janet R. Urban, Esq.
Harrisburg, Pennsylvania 17105 Ruth Greenspan Bell, Esq.
Antitrust Division Edward A. Matto, Esq.
Department of Justice Assistant Attorney General Post Office Box 7513 Chief, Antitrust Section Washington, D. C.
20044 30 East Broad Street, 15th floor Columbus, Ohio 43215 Karen H. Adkins, Esq.
Richard M. Firestone, Esq.
Christopher R. Schraff, Esq.
Assistant Attorneys General Assistant Attorney General Antitrust Section Environmental Law Section 30 East Broad Street, 15th floor 361 East Broad Street, 8th floor Columbus, Ohio 43215 Columbus, Ohio 43215
s g
Pape 2 ATTACHMENT (Continusd)
John R. White, Esq.
Leslie Henry, Esq.
Thomas A. Kayuha, Esq.
Michae'. M. Briley, Esq.
Ohio Edison Company Roger P. Klee, Esq.
47 North Main Street Fuller, Henry, Hodge & Snyder Akron, Ohio 44308 300 Madison Avenue Toledo, Ohio 43604 John Lansdale, Jr., Esq.
Cox, Langford & Brown Pennsylvania Power Company 21 Dupont Circle, N. W.
1 East Washington Street Washington, D. C.
20036 New Castle, Pennsylvania 16103 Lee C. Howely, Esq.
Donald H. Hauser, Esq.
Vice President and General Counsel Corporata Solicitor The Clevoland Electric Illuminating Co.
The Cleveland Electric Illuminatong Co.
Post Office Box 5000 Post Office Box 5000 Cleveland, Ohio 44101 Cleveland, Ohio 44101 Gerald Charnoff, Esq.
Thomas J. Munsch, Jr., Esq.
Wm. Bradford Reynolds, Esq.
General Attorney Shaw, Pittman, Potts & Trowbridge Duquesne Light Company 910 Seventeenth Street, N. W.
435 Sixth Avenue Washington, D. C.
20006 Pittsburgh, Pennsylvania 15219 David McNeill Olds, Esq.
Joseph Rieser, Esq.
John McN. Cramer, Esq.
Reed, Smith, Shaw & McClay William S. Lerach, Esq.
Suite 440 Reed, Smith, Shaw & McClay 1155 Fifteenth Street, N. W.
Post Office Box 2009 Washington, D. C.
20005 Pittsburgh, Pennsylvania 15230 John C. Engle, President Terrence H. Bcnbow, Esq.
AMP-O, Inc.
Winthrop, Stimson, Putnam & Robertr Municipal Building 40 Wall Street 20 High Street New York, New York 10005 Hamilton, Ohio 45012 Jon T. Brown, Esq.
Duncan, Brown, Weinberg & Palmer Suite 777 1700 Pennsylvania Avenue, N. W.
Washington, D. C.
20006
.