ML19326A609

Affidavit Supporting Intervener Reply to Applicants' Motion for Summary Disposition

ML19326A609
Person / Time
Site:	Davis Besse, Perry
Issue date:	10/03/1974
From:	Illingworth C AMERICAN MUNICIPAL POWER-OHIO, INC., O'BRIEN & GERE ENGINEERS, INC.
To:
Shared Package
ML19326A605	List: ML19326A604 ML19326A609
References
NUDOCS 8002250919
Download: ML19326A609 (4)

Text

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UNITED STATES OF AMERICA c)

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308 Before the Atomic Safety and Licensing Boar 4

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In the Matter of: ) -

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THE CLEVELAND ELECTRIC U00 ILLUMINATING COMPANY, 4

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(Perry Nuclear Power Plant, Docket Nos. 50-440A Units 1 and 2) ) 50-441A AFFIDAVIT OF CHARLES H. ILLINGWORTH IN SUPPORT OF THE INTERVENER'S REPLY TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION STATE OF NEW YORK )

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COUNTY OF ON0NDAGA )

I, CHARLES H. ILLINGWORTH, being first duly sworn on oath, depose and state the following:

1. I am presently Managing Engineer for Power System Planning in the Power Division of 0'Brien & Gere Engineers, Inc.

(O' Brien & Gere) of Syracuse , New York. I have responsibility for the management of all electric power planning consulting services provided by O'Brien & Gere. These services include planning for generating , transmission , and dis tribution f acili-ties as well as overall utility financial planning and consulta-tions in power contract negotiations and engineering support for rate cases. One of my present management assignments is to provide engineering support for the American Municipal Power - Ohio, Inc.

( AMP-0) application for a preference power allocation from the Power Authority of the State of New York (PASNY).' I joined O'Brien & Gere and assumed my present position in June 1972.

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2. Prior to my association with O'Brien & Gere I was employed for twenty years by Charles T. Main, Inc - Engineers (Main) of Boston, Massachusetts. This employment was interrupted by my service as a commissioned officer in the United States Army Signal Corps. My last ten years with Main were in the system planning group. I served on the Federal Power Commission Studies Group, Northeast Interconnected System investigating the 1965 North-east power blackout. I graduated from Northeastern University with a Bachelor of Science Degree in Electrical Engineering and was elected to the Eta Kappa Nu electrical engineering honor fraternity.

I completed the General Electric Company Power Systems Engineering Course and attended the U.S. Army Signal School at Fort Monmouth, New Jersey. I am a member of the Institute of Electrical and Electronic Engineers and a member of the Institute Systems Control S ub commi t te e. I am a Registered Engineer in the Commonwealth of Massachusetts.

3. It is my opinion that the AFFIDAVIT OF DALWYN R.

DAVIDSON IN SUPPORT OF APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION does not provide sufficient data to evaluate whether the Perry Nuclear Power Plant will prevent or impair delivery of PASNY preference power to one or more member municipal utilities of AMP-0. Nor is sufficient data available in Mr. Davidson's AFFIDAVIT to evaluate whether the Perry Nuclear Power Plant will prevent or impair delivery of any other amounts of power that may be purchased by AMP-0 for delivery to one or more of its member utilities.

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4. It is impossible to evaluate the effects of the Perry Nuclear Plant on the interconnected transmission system without access to either computer print-out sheets or a drawing representing the complete system with load flows indicated. As mentioned in my letter of February 28, 1974 to don T. Brown, Esq.

, which was forwarded to Chairman Farmakides and all parties to the cases on March 4,1974, AMP-0 is not a member of ECAR and does not have access to all pertinent data. While Mr. Davidson cites in Statement 10 of the AFFIDAVIT " examples" of severe test conditions ,

there is no possible way for any observer to verify the results of the tests performed, the conclusions derived thereof, or to deter-mine whether deliveries to other AMP-0 members other than the City of Cleveland power might be affected.

5. My letter of March 29, 1974 stated "The Cleveland Electric Illuminating Company must demonstrate that computer model simulation has included the vital wheeling facilities for PASNY power and of full representation of the Municipal Generating Facilities in stability studies". This point was not discussed in Mr. Davidson's AFFIDAVIT and there is no way to determine whether the municipal f acilities were represented. As in the case of the load flows discussed in 2 above, no output from stability studies was presented whether in computer print-out or in generator-swing diagrams.

6. In summary, CEI has not presented the results of ,

planning studies in suf ficient detail to evaluate the possible effects of the proposed Perry Plant on the delivery of PASNY power to the _ Cleveland Municipal Utility or the effects of the 1

Perry Plant on limiting any future power contracts by AMP-0.

Furthermore, AMP-0 is not a member of the planning groups in the ECAR region and does not have access to data that would be required for an independent evaluation.

M Y

CHARLES H. ILLING Ef$

TH Subscribed and sworn to before me this day of October,1974.

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Nota ry Publi c 1r e

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