ML20071B347

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Info for Antitrust Review of OL Application,Marble Hill Nuclear Generating Station Units 1 & 2
ML20071B347
Person / Time
Site: Marble Hill
Issue date: 02/28/1983
From:
PSI ENERGY, INC. A/K/A PUBLIC SERVICE CO. OF INDIANA
To:
Shared Package
ML20071B341 List:
References
NUDOCS 8302280177
Download: ML20071B347 (43)


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Docket Numbers: 50-546 50-547 INFORMATION FOR ANTITRUST REVIEW OF THE OPERATING LICENSE APPLICATION MARBLE E1LL NUCLEAR GENERATING STATION UNITS 1 and 2 PUBLIC SERVICE COMPANY OF INDIANA, INC.

FEBRUARY, 1983 I

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TABLE OF CONTENTS Section g I. Introduction 2 II. Responses to R.G.9.3, Part B 4 Item 1(a) 4 Item 1(b) 7 .

Item 1(c) 8 Item 1(d) 15 Item 1(e)' 16 Item 1(f) 17 Item 1(g) 20 Item 1(h) 21 Item 2 24 III. Exhibits A. PSI 1983-96 Resource Plan 25 l

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I. INTRODUCTION This information is submitted by Public Service Company of Inciana, Inc.

(PSI), pursuant to the Nuclear Regulatory Commission's (the Commission)

Regulatory Guide 9.3, dated October 1974. As such, this submittal supplements the amendment to PSI's application to construct and operate the Marble Hill Nuclear Generating Station, Units 1 and 2, dated November 23, 1982 and tendered to the Commission on November 26, 1982.

Marble Hill Nuclear Generating Station, Units 1 and 2, is jointly owned by PSI and Wabash Valley Power Association, Inc. (WVPA) as tenants in common. These owners will share the electrical output and have paid construction costs according to their respective ownership share in the facilities. PSI, which owns eighty-three (83) percent of the units,. is acting as agent for WVPA and has sole responsibility for licensing, design, procurement, construction, operation, and all related functions with respect to the facilities. WVPA, which owns seventeen (17) percent of the units, has delegated to PSI the authority to act on its behalf in obtaining such further facilities and materials license applications and amendments as may be required by law or regulation.

On July 2, 1975, PSI submitted an. application to the Commission for licenses to construct and operate the Marble Hill facility. After the issuance of two partial decisions by the Atomic Safety and Licensing Board, the Commission's staff issued two Limited Work Authorizations on August 24, 1977 and December 13, 1977. The construction permits were issued on April 4, 1978.

The "Information Requested by the Attorney General for Antitrust Review" l

l pertaining to PSI and required by 10 CFR 50.33a and Appendix L was docketed by'the Commission on January 8, 1975 and assigned Docket No. P-505-A. The conclusions of the Antitrust Division of the Department

of Justice were transmitted to the Commission by letter dated April 15, l 1975.

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l j- The "Information Requested by the Attorney General for Antitrust Review" pertaining to WPA and required by 10 CFR 50.33a and Appendix L was -

docketed by the Conunission on June 10, 1977. The conclusions of the Antitrust Division of the Department of Justice were transmitted to the

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Conunission by letter dated December 29, 1977.

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f II. Responses to RG 9.3, Part B (1) To assist the regulatory staff in its review, an applicant for a license to operate a commercial nuclear power plant should consider the following items and any related changes that have occurred or are  ;

planned to occur since submission of the construction permit application:

Item 1(a)

Anticipated excess or shortage in generating capacity resources not expected at the construction permit stage. Reasons for the excess or shortage along with data on how the excess will be allocated, distributed, or otherwise utilized or how the shortage will be obtained.

Response

Since the submission of the construction permit application, there have been changes in PSI's capacity resource plans. These changes.are primarily the result of reduced load growth projections from those which were predicted at the construction permit stage.

PSI's current Resource Plan through 1996 is attached as Exhibit A. 'The capacity in excess of PSI's peak load plus 20% reserve requirement will be available for both short term and long term sales. Discussions have taken place with other utilities regarding these possible sales. Except for some normal short term transactions, no definite commitments for this power have been made at this time.

Since' submittal of the construction permit application, the following transactions have occurred.

(1) On February.1,1978, PSI and WVPA entered into an agreement entitled

" Marble Hill Plant Purchase and Ownership Participation Agreement."

This agreement provided for the acquisition by kVPA of a seventeen g ,

percent undivided interest as a tenant in common of the Marble Hill Nuclear Generating Station, Units 1 and 2 and was submitted to the Atomic Safety and Licensing Board by letter dated February 6, 1978, prior to. issue of the Construction Permit.

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(2) On August 27, 1982, PSI entered into an agreement to' transfer undivided ownership' interests in its newest fossil-fired unit, Gibson No. 5, to WVPA and the Indiana Municipal Power Agency (IMPA). WVPA

owns a 25% undivided interest in Gibson No. 5 and related facilities and IMPA owns a 24.95% undivided interest in Gibson No. 5 and related facilities.

IMPA is an association of municipal electric systems located in Indiana.

IMPA consists of the following municipal utilities:

Anderson Bargersville Centerville 3

Darlington Flora Frankfort Frankton Greendale 4

Greenfield Jamestown Lawrenceburg Lebanon j Linton Middletown Paoli Pendleton Rensselaer Rising Sun r- Scottsburg Tipton Washington Crawfordsville Peru Richmond

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The transfers of the undivided interests in Gibson Unit.No. 5 are subject to the jurisdiction of and approval by the Public Service Commission of Indiana. Such approval was granted in Cause No. 36835, Cause No. 36902, and Cause No. 36956.

PSI has agreed to purchase a declining percentage of WVPA's and IMPA's capacity entitlement from Gibson No. 5.

PSI has agreed to wheel power for IMPA to any of its member systems located on the PSI system and will wheel power to adjoining utilities for transmission to IMPA members not located on the PSI system. Pursuant to a certain Distribution Facilities Ownership, Operation and Maintenance Agreement and a Transmission Participation Agreement between PSI and WVPA, WVPA owns transmission facilities sufficient for WVPA to transmit energy from its share of Gibson No. 5 and Marble Hill to its member systems.

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Item No. 1(b)

New power pools or coordinating groups or changes in structure, activities, policies, practices, or membership of power pools ur coordinating groups in which the licensee was, is, or will be a participant.

Response

Pursuant to Article 6.01 of the Kentucky-Indiana Power Pool Agreement (KIP), PSI terminated the joint planning portion of the KIP Agreement by letter dated June 7, 1976. The Federal Energy Regulatory Commission (FERC) Staff opened an inve6tigation of this termination in Docket No.

ER76-739. On March 17, 1980, FERC issued an Order accepting the FERC Staff investigative ' port and terminating the proceeding.

On August 27, 1982, PSI, WVPA and IMPA entered into the following agreements.

(1) Gibson Unit No. 5 Joint Ownership, Participation, Operation and Maintenance Agreement By and Between PSI, WVPA and IMPA.

(2) Power Coordination Agreement Between PSI and IMPA.

(3) Power Coordination Agreement Between PSI and WVPA.

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Item 1(c)

Changes in transmission with respect to (1) the nuclear plant, (2) inter-connections, or'(3) connections to wholesale customers.

Response

(1) Nuclear Plant Operation of the Marble Hill Nuclear Generating Station, Units 1 and 2 will require three (3) 765 kV transmission lines and one (1) 345 kV lo)p line to connect the static to the existing transmission network. Two 765 kV lines and the 345 kV loop extend westward from the site boundary in a common corridor 0.05-mile long, where they either cross or join the existing PSI Speed-Madison transmission line right-of-way. One of the 765 kV lines crosses this right-of-way and then extends northwest for 48.5 miles to the existing PSI-Columbus substation near Columbus, Indiana.

The second 765 kV line also crosses the existing Speed Madison right-of-way and then parallels this right of-way for approximately nix (6) miles north. It then continues an additional seven (7) miles northeast to tie in*o the existing Jefferson substation owned by Indiana and Michigan Electric Company (I&M) located west of Madison, Indiana. The 0.05-mile 345 kV loop will extend only to the Speed-Madison north-south right-of-way where it will tie into the 345 kV circuit of an existing 138/345 kV double circuit line. This Speed-Madison 138 kV circuit is cu.rently supplying construction power to the Marble Hill site.

In addition, a third 765 kV line will extend northeast from the new Elizabethtown switching station near Columbus, Indiana, for a distance of 36.6 miles to the new Gwynneville substation located 2 miles south of Gwynneville, Indiana. The 13-mile long Marble Hill to Jefferson Line and the 36.6-mile long Elizabethtown to Gwynneville line replace the 65.5-mile long Marble Hill to Rush line presented in the Environmental Report - Construction Permit (ER-CP).

I (2) Interconnections PSI has planned, under construction, or in service multiple interconnections with eight (8) investor-owned electric utilities, Hoosier Energy Rural Electric Cooperative, Inc. (HEREC), and several municipalities. The following is a summary of interconnections installed since submittal of the construction permit applications presently under construction or planned.

Under Construction or In Service Since Submittal of the Construction Permit Application

1. Greentown 765 kV (Under Construction)

This substation is jointly owned by PSI and Indiana and Michigan PSI Electric Company (16M) and has a 765 kV/138 kV transformer.

has three 138 kV circuits and 1&M has two 138 kV circuits out of the substation. An additional 765/230/138 kV transformer is under construction. PSI will own the 230 kV capacity and have two 230 kV transmission lines out of the substation. I&M plans additional 138 kV lines in future.

2. Petersburg 345 kV (In Service)

PSI has placed in service a 3-mile double circuit 345 kV line into the Indianapolis Power & Light Company (IP&L) Petersburg plant.

This is a loop off the PSI Gibson-Bedford-Columbus 345 kV line in and out of the plant to replace the need for IP&L building a 345 kV line from Petersburg to Indianapolis and improve the stabilit) margins at PSI's Gibson Station.

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3. Merom 345 kV (In Service)

PSI has placed in service a 345 kV loop in and out of Hoosier Energy Rural Electric Cooperative, Inc. (HEREC) Merom plant from the Gibson-Dresser 345 kV line. This provides additional outlet capacity from the Merom plant and eliminates the need for HEREC to build an additional 345 kV line.

4. Worthington 345 kV (In Service)

This substation owned by HEREC has a 345/138 kV, a 161/138 kV, and two 138/69 kV transformers. PSI owns two 138 kV lines and HEREC owns three 69 kV lines out of the substation. This substation is fed by the HEREC Merom to Bloomington 345 kV circuit and the 161 kV from the Ratts plant (HEREC).

5. Speed-Marble Hill 345 kV (In Service)

PSI established a third interconnection with Kentucky Utilities Company (KU) by constructing a Ghent-Marble Hill-Speed 345 kV c ircuit . The Marble hill - Ghent portion of this circuit will tie together PSI's Marble Hill and KU's Ghent plants.

6. Gibson-Albion 345 kV (In Service)

A second interconnection between PSI and Central Illinois Public Service Company (CIPSCO) was established by constructing a Gibson-Albion 345 kV circuit. In addition to serving as a transmission outlet for PSI's Gibson Station, this circuit also provides local area support to CIPSCO's Albion area and as a path for transfer of power.

7. Deedsville-Leesburg 345 kV (In Service)

PSI and Northern Indiana Public Service Company (NIPSCO) olaced in service a 345 kV interconnection between PSI's Deedsville and NIPSCO's Leesburg substations. This interconnection terminates in a 500 MVA, 345/230 kV transformer at the Deedsville substation.

8. Speed-Northside 138 kV (In Service)

PSI and Louisville Gas and Electric Company (LG&E) tied together -

their 345/138 kV substations at Speed and Northside with a 138 kV interconnection. This circuit serves to provide sufficient capability to transfer power between the two companies and as back up support for the two substations.

9. Bloomington 230 kV (In Servica)

This substation contains a 345/230 kV transformer owned by HEREC and a 230/69 kV transformer and a 230/138 kV transformer owned by PSI. This substation is served by HEREC's 345 kV line from Merom-Worthington. PSI has 230, 138 and 69 kV lines from this substation.

10. Worthington 69 kV (In Service)

PSI tapped HEREC's Worthington-Stearleyville 69 kV circuit in order to provide a 69/34.5 kV substation at Worthington. This interconnection is utilized for local area support to the PSI load in the Worthington area.

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11. Ramsey 345 kV (In Service)

This substation is owned by HEREC and is served by a 345 kV line looped in and out of PSI's Gibson-Speed 345 kV line. HEREC has three 69 kV lines and PSI has one 69 kV line out of the substation. Future development will add one more 69 kV line.

12. Centerville 138 kV (In Service)

PSI owns the substation, which has been converted to 138/69 kV.

This substation is served from I&M's 138 kV line (College -

Corner-Delaware) and connects into the PSI 69 kV system.

Committed, Planned, or Under Serious Consideration

1. Gwynneville 765 kV (Committed)'

This 1500 MVA, 765/345 kV substation is to be constructed by PSI and served by the I&M Jefferson-Greentown 765 kV line and the Elizabethtown-Gwynneville 765 kV line. PSI will construct one 345 kV line from Gwynneville to Greensboro, and IP&L will construct two 345 kV lines, one to Columbus (PSI) and one to Sunnyside (IP&L). PSI will also have a 345/69 kV transformer in this substation, with 69 kV lines connecting into the existing 69 kV system.

2. Patriot Generation Plant 345 kV (Under Consideration)

This plant is planned by IP&L. The first unit's transmission outlet would be provided by looping PSI's 345 kV line from Ghent (KU) to Batesville into the plant at Patriot. IP&L will be purchasing the Patriot tu 2%ent porcion of this line in order to accomplish this. A 345 kV -cuit will also be constructed from Batesville to Greensboro which completes the 345 kV Patriot transmission development for Unit #1 and provides two-way 345 kV 4 support into Greensboro.

3. Smith Valley 345 kV (Under Consideration)

PSI plans to tap the IP&L 345 kV line (Petersburg-Hanna) and construct a 345/69 kV substation for 69 kV. support in Johnson County.

4. Speed-Northside 345 kV (Under Consideration)

PSI and LG&E plan to construct a 345 kV line from Speed (PSI) to Northside (LG&E) to increase transfer capability between the companies.

5. Marble Hill-Jefferson 765 kV (Committed)

PSI plans to construct a 765 kV line from Marble Hill to the Jefferson substation (I&M) to connect into the I&M 765 kV system for additional outlet from Marble Hill.

6. Jeffersonville 138 kV (Under Consideration)

PSI plans to construct a 138/12 kV substation that will be served from LG&E 138 kV line.

7. Pritchard 138 kV (Planned, Not Committed)

PSI plans to construct a 138/69 kV substation that will be served from the 138 kV line at Pritchard Genereting Station (IP&L).

8. Rockville Road 345 kV (Planned, Not Committed)

This substation (345/138 kV) is owned by IP&L. PSI plans to construct a 138 kV line from this substation to serve loads in i the Brownsburg-Avon area and eventually connect to the 345-138 kV substation planned for the future in the Danville area.

(3) Connections With Wholesale Customers Since the submission of the construction permit application, PSI and

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WVPA have entered into the following agreements.

(a) Transmission Participation Agreement, dated February 27, 1978.

(b) First Supplemental Agreement to Transmission Participation Agreement, dated April 14, 1978.

4 (c) Second Supplemental Agreement.to Transmission Participation Agreement, dated March 3, 1981.

(d) Third Supplemental Agreement to Transmission Participation Agreement, dated December 2, 1981.

(e) Transmission Facilities Operation and Maintenance Agreement, dated February 27, 1978.

(f) Distribution Facilities Ownership, Operation and Maintenance Agreement, dated March 6, 1981.

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Item No. 1(d)

Changes in the ownership or contractual allocation of the output of the' nuclear facility. Reasons and basis for such changes should be included.

Response

On February 1,1978, PSI and WVPA entered into an agreement entitled

" Marble Hill Plant Purchase and Ownership Participation Agreement." This agreement provided for the acquisition by WVPA of a seventeen percent undivided interest as a tenant in common of the Marble Hill Nuclear Generating Station, Units l'and 2.

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Item No. 1(e)

Changes 'in design, provisions, or conditions of rate schedules and reasons for such changes. Rate increases or decreases are not necessary.

Response

Since submission'of the construction permit application, changes in design, provisions, or conditions of rate schedules have been, in general, made in connection with rate increase petitions or to comply with

. provisions of the Public Utility Regulatory Practices Act (PURPA).

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List of-all (1) new wholesale customers, (2) transfers'from one rate-schedule to another, including copies of schedules not previously furnished, -(3) changes in licensee's service area, and (4) licensee's acquisitions or mergers.

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Response

-(l) New Wholesale Customers On February 27, 1978, WVPA and PSI entered int an Interconnection

Agreement. This agreement provides that PSI shall provide WVPA Supplemental Power and Energy, Reserve Capacity, Back-Up Energy and Replacement Energy.

(2) Transfer from One Rate Schedule to Another The following transf ers from one rate schedule to another have

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(a) City of Crawfordsville from FERC Rate. Schedule Number 211 to i FERC Rate Schedule Number 229 per the Interconnection Agreement between PSI'and Crawfordsville, dated January 3, 1978.

i (b) City of Frankfort from FERC Rate Schedule Number 224 to FERC Ele'tric c Tariff Original Volume Number 1 (Rate MUN).

1 (c ) City of Washington from FERC Rate Schedule Number 215 to FERC Electric Tariff Original Volume Number 1 (Rate MUN).

(d) . Member Systems of WVPA from FERC Electric Tarriff Original -

Volume Number 2 (Rate REMC-1) to FERC Rate Schedule Number 232.

(e) City of Logansport from FERC Rate Schedule Number 223 to FERC Rate Schedule Number 230 per the Agreement for Supply of Base Load Capacity between Logansport and PSI dated June 24, 1980.

(f) The transfer of ownership of Gibson Unit 5 per the Joint Ownership, Participation, Operation and Maintenance Agreement, dated August 27, 1982, by and between PSI, WVPA and IMPA has resulted in the following FERC Rate Schedule transfers.

(i) Member Systems of WVPA from Rate Schedule FERC No. 232 to Rate Schedule FERC No. 233.

(ii) Towns of Bargersville, Centerville, Darlington, Flora, Greendale, Jamestown, Middletown, Pendleton and Cities of Greenfield, Lebanon, Linton, Paoli, Rising Sun, Scottsburg, Tipton, Washington, and Frankfort from Electric Tariff Original Volume No.1 (Rate MUN) to Rate Schedule FERC No. 234.

(iii) City of Crawfordsville from Rate Schedule FERC No. 229 to Rate Schedule FERC No. 234.

(iv) City of Peru from Rate Schedule FERC No. 212 to Rate

. Schedule FERC No. 234.

(g) City of Logansport from Rate Schedule FERC No. 230 to Rate Schedule No. 235 per the First Supplemental Agreement, dated October 1, 1982, to the Agreement for Supply of Base Load Capacity between Logansport and PSI, dated June 24, 1980.

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(3) Changes in Licensee's Service Area Since the submittal of the Construction Permit Application, there have been several. routine service area territorial-adjustments with REMCs adjoining PSI's service territory. The Indiana General Assembly in 1980 enacted P.L. 69, now codified as IC 8-1-2.3-1, a statute entitled " Electricity Supplier's Service Area Assignments".

This act requires all electric suppliers within the State of Indiana, including REMCs, investor-owned utilities, and municipal utilities, to negotiate with all adjacent electricity suppliers as soon as practicable in an effort to agree on boundaries of the service areas to be assigned to each electric supplier. Maps are to be prepared and filed with the Public' Service Commission of Indiana requesting approval of an assignment of service areas. Pursuant to this act, PSI has negotiated with adjoining electric suppliers, REMCs,-

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municipals, and other investor-owned utilities and has filed numerous Petitions with the Public Service Commission of Indiana. If these Petitions are approved by the Public Service Commission of Indiana, there will be several minor adjustments to PSI's service territory.

4 (4) Licensee's Acquisitions or Mergers (i) The town of Patoka was acquired on December 15, 1977 and-discontinued as Bate MUN.

(ii) The Hillsdale sectic, of the town of Montezuma was acquired on July 15, 1977 and disc 3ntinued as Rate MUN.

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Item No.-1(g)

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List of those generating capacity additions comitted for operation af ter

'the nuclear facility, including ownership rights or power output-allocations.

Response

PSI currently has no firm commitments for additional generating capacity beyond Marble Hill Generating Station, Units 1 and 2.

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Item No. 1(h) 4 Summary of requests or indications of interest by other electric power wholesale or retail distributors, and licensee's response, for any type of electric service or cooperative venture or study.

Response

PSI's Statement of Bulk Power Supply Policies is included in Section 3E of Construction Permits CPPR-170 and CPPR-171. Since issuance of those permits, inquiries from electric power wholesale or retail distributors for any type of electric service or cooperative venture or study were handled in compliance with this statement. These inquiries include the following:

(1) On April 22, 1974 East Kentucky Rural Electric Cooperative Corporation requested PSI to furnish certain construction, maintenance and operating information relative to the subject units for use and analysis of East Kentucky's generation and transmission requirements in the next ten or more years. PSI furnished the requested information and entered into a letter of intent to sell East Kentucky an ownership interest in the subject units. In February 1977, East Kentucky withdrew its request for participation for reasons of regulatory burdens and rescinded its letter of intent.

(2) Kentucky Utilities Company (KU) and Northern Indiana Public Service Company (NIPSCO) had expressed interest in some participation in the subject units or unit power purchase. PSI held discussions with both parties. -NIPSCO entered into a letter of intent with PSI in August 1974 to purchase an ownership interest in the subject units and subsequently withdrew from the Agreement. PSI has agreed to sell NIPSCO unit power from the subject units. No agreement was ever reached with KU.

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.(3) In 1975 the Cities of Anderson, Richmond and Mishawaka, Indiana (all of whom are served by the lines of Indiana & Michigan Electric Company) asked if PSI could supply power to them. They were told l that PSI could not supply power to them directly as they were beyond PSI's transmission lines, but PSI would sell power to them from fossil fuel plants then under construction, and transmit the power over PSI's lines to the system of 1&M. Such power would have to be transmitted over the lines of I&M to each of the cities pursuant to an arrangement between the cities and I&M.

(4) In 1978 the Cities of Anderson, Crawfordsville, Logansport and Richmond, and possibly some unnamed municipalities represented by the Indiana Municipal Electric Association, expressed interest in the joint ownership with PSI of nuclear and fossil-fired generating units if they were able to obtain state legislation which would enable them to participate in such ownership. PSI indicated that it would be interested in such joint ownership. This eventually led to the sale of the 24.95% undivided interest of Gibson Unit 5 to IMPA described in response 1(a).

(5) In April 1973 the City of Crawfordsville, Indiana, sent to applicant a study of generation and transmission facilities prepared for the Kentucky-Indiana Municipal Power Association (KIMPA) and asked applicant to look it over in preparction for discussing the study with applicant. KIMPA consists of the Cities of Frankfort and Paris, Kentucky, and the Cities of Crawfordsville, Ferdinand, Huntingburg, Jasper, and Washington, Indiana. In August, 1973, the applicant, in response to a request for a conference between KIMPA, the applicant, '

and the other three participating members of KT.P relative to the KIMPA study, responded that applicant was willing to enter into discussions with those members of KIMPA, with whom applicant is interconnected (i.e., Crawsfordsville and Washington) about their future electrical requirements, but was not in a position to discuss the future requirements of the members of KIMPA located beyond applicant's transmission lines.

v PSI informed KIMPA that it would have to qualify as a utility in the State of Indiana. KIMPA was denied a certificate of public convenience and necessity by the Public Service Commission of Indiana and appealed this ruling. The Court of Appeals of Indiana upheld the Commission in an opinion issued August 27, 1979, KIMPA vs. PSI et.

al.,-(1979) Ind. App., 393 NE 2nd 776.

(6) KIMPA was permitted by FERC to intervene in the filing of the KIP pooling agreement (and the supplement thereto) as a rate schedule.

KIMPA opposed the pooling agreement en the grounds that the terms of the agreement excluded KIMPA from being a member of the pool. The case has been decided against KIMPA by FERC in Opinion No. 15, issued on June 22, 1978, in FERC Docket Nos. E-7704, E-7669, E-7937, and E-8053 (consolidated for hearing). On September 30,-1982, the FEkC issued an Opinion and Order Denying Rehearing.

(7) In March of 1978, the Town of Frankton, Indiana municipal utility requested PSI to submit a bid to provide wholesale power. PSI declined to submit such a bid because of the cost of constructing additional facilities to serve the load. Frankton has since become a member of IMPA.

(8) In December, 1982, representatives of American Municipal Power-Ohio (AMP-Ohio), an association of Ohio municipal utilities, met with representatives of PSI and expressed an interest in arranging for PSI to wheel power to AMP-Ohio members. In January, 1983, PSI responded on and work by letter that it was willing to consider such a r .

with AMP-Ohio and suggested a meeting to begin w v 'etails.

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Item No. 2 Licensees whose. construction permits include conditions pertaining to antitrust aspects should list and discuss those actions or policies which' have been implemented in accordance with such conditions.

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Response

Prior to the issuance of Construction Permits CPPR-170 and CPPR-171, PSI submitted on March 18, 1975 to the United State Departtant of Justice a Statement of Bulk Power Supply Policies. At that time, PSI agreed to have the Statement made a condition of any construction permits or operating licenses issued by the Nuclear Regulatory Commission for construction or operation of the Marble Hill Nuclear Generation Station, Units 1 and 2.

Subsequently, PSI responded to any inquiries from interested parties concerning possible power supply agreements, interconnection agreements, transmission participation agreements, etc. in compliance with this policy. Discussions were held and some agreements were made. The present status of such agreements is as detailed in response to Question No. 1.

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.. m EXHIBIT A PSI CURRENT RESOURCE PLAN YEAR 1983 1984 .1985 1986 1987 SEASON (1) (S) (W) (S) (W) (S) (W) (S) (W) (S) (W)

PSI NATIVE LOAD (2) 3891 4048 4008 4211 4117 4368 4240 4179 4163 4333 FIRM SALES- 0 0 0 0' 0 0 0 0 0 0 FIRM TO WVPA 0 0 0 0 0 0 0 275 113 289 WVPA' SHARE OF MARBLE HILL 0 0 0 0 0 0 0 79 79 79 TOTAL RESERVED LOAD 3891 4048 4008 4211 4117 4368 4240 4533 4355 4701 INSTALLED CAPACITY 5939 5999 5939 5999 :5939.5999 5939 7129 7069 7129 KENTUCKY-INDIANA POOL SALE 0 0 0 0 0 0 0 0 0 0 WVPA SALE TO NORTHERN INDIANA 0 0 0 0 0 0 0 113 113 113 PUBLIC SERVICE COMPANY, INC.

OTHER SALES 0 0 0 0 0 0 0 113 113 0 TOTAL CAPACITY 5939 5999 5939 5999 5939 5999 5939 6903 6843 7016 RESERVE MW 2048 1951 1931 1788 1822 1631 1699 2370 2488 2315 PERCENT 52.6 48.7 48.2 42.5 44.3 37.3 40.1 52.3 57.1 49.2 RESERVE REQUIREMENT ~ 778 810 802 842 823 874 848 907 871 940 MW BELOW(-)/ABOVE(+) 1270 1141 1129 946- 999 757 851 1463 1617 1375 d

MW ADDITIONS 0 0 0 0 0 0 0 1130 0 0 MW RETIREMENTS (3) 0 0 0 0 0 0 0 0 0 0 (1) S = Summer

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(2) All loads are presented in Megawatts (MW).

-(3) The indicated MW retirements and additions are planning projections only.

l' No commitment has been made.

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EKHIBIT A PSI CURRENT RESOURCE PLAN

-YEAR 1988 1989 1990 1991 1992 (S) (W) (S) (W) (S) (W) (S) (W) (S) (W)

PSI NATIVE LOAD (2) 4271 4482 4372 4645 4488 4813 4612 4997 4730 5178 FIRM SALES 0 0 0 0 0 0 0- 0 0 0 FIRM TO WVFA 43 225 51 240' 59 256 68 272 77 288 WVPA SHARE OF MARBLE HILL 158 158 158 158 158 158 158 158 158 158 TOTAL RESERVED LOAD 4472 4865 4581 5043 4705 5227 4838 5427 4965 5624 INSTALLED CAPACITY 8199 8259 8199 8259 8109 8169 7944 8004 7944 8004 KENTUCKY-INDIANA POOL SALE O O O 0 0 0 0 0 0 0 WVPA SALE TO NORTHERN INDIANA 226 226 226 226 226 226 226 226 226 226 PUBLIC SERVICE COMPANY, INC.

OTHER SALES 0 0 0 0 0 0 0 0' O 0 TOTAL CAPACITY 7973 8033 7973 8033 7883 7943 7718 7778 7718 7778 RESERVE MW 3501 3168 3392 2990 3178-2716 2880 2351 2753 2154 PERCENT 78.3 65.1 74.0 59.3 67.5 52.0 59.5 43.3 55.4'38.3 RESERVE REQUIREMENT 894 973 916 1009 941 1045 968 1085 993 1125 MW BELOW(-)/ABOVE(+) 2607 2195' 2476 1981 2237 1671 1912 1266 1760 1029 MW ADDITIONS 1130 0 0 0 0 0 0 0 0 0 MW RETIREMENTS (3) 0 0 0 0 90 0 165 0 0 0

~(1) S = Summer W = Winter -

(2) All loads are presented in Megawatts (NW).

.(3) The indicated-MW retirements and additions are planning projections only.

No commitment has been made.

EXHIBIT'A PSI CURRENT RESOURCE PLAN YEAR-1993 1994 1995 1996 SEASON (1) (S) (W) (S) (W) (S) (W) (S) (W)

PSI NATIVE LOAD (2) 4861 5364 4975 5518 5090 5674 5204 5830.

FIRM SALES 0 0 0 0 0 0 0 0 FIRM TO WVPA 87 306 97 324 107 343 118 362 WVPA SHARE OF MARBLE HILL 158 158 158 158 158 158 158 158 TOTAL RESERVED. LOAD 5106 5828 5230 6000 -5355 6175 5480 6350 INSTALLED CAPACITY 7944 8004 7944 8004 7944 8004 7509 8119 4

KENTUCKY-INDIANA POOL SALE 'O O O 0 0- 0 0 0 WVPA SALE TO NORTHERN INDIANA 226 226 226 226 226 226 226 226 PUBLIC SERVICE COMPANY, INC.

OTHER SALES 0 0 0 0 0 0 0 0 TOTAL CAPACITY 7718 7778 7718 7778 7718 7778 7283 7893 RESERVE MW 2612 1950 2488 1778 2363 1603 1803 1543 PERCENT 51.2 33.5 47.6 29.6 44.1 26.0 32.9 24.3 RESERVE REQUIREMENT 1021 1166 1046 1200 1071 1235 1096 1270 MW BELOW(-)/ABOVE(+) 1591 784 1442 578 1292 368 707 273 MW ADDITIONS (3) 0 0 0 0 0 0 0 550 MW RETIREMENTS (3) 0 0 0 0 0 0 435 0 (1) S = Summer W = Winter s (2) All loads are presented in Megawatts (MW).

- (3) The indicated MW retirements and additions are planning projections only.

No commitment has been made.

INFORMATION NEEDED BY THE NUCLEAR REGULATORY COMMISSION REGULATORY STAFF IN CONNECTION WITH ITS ANTI-TRUST REVIEW OF THE OPERATING LICENSE APPLICATION FOR MARBLE HILL NUCLEAR PLANT UNITS 1 AND 2 This information is submitted on behalf of Wabash Valley Power Association, Inc. (hereinafter referred to as "WVPA") in response to Nuclear Regulatory Commission Regulatory Guide 9.3. WVPA's member-ship consists of twenty-four (24) rural electric distribution systems generally located north of Highway 40 in the State of Indiana, with one member located in. the State of Michigan and one member located in the State of Ohio. The 24 member systems are:

Boone County REMC Miami-Cass County REMC Carroll County REMC Newton County REMC Fruit Belt Electric Cooperative Noble County REMC Fulton County REMC- Parke County REMC Hancock County REMC Paulding-Putnam Electric Hendricks County REMC Cooperative, Inc.

Jasper County REMC Steuben County REMC Jay County REMC Tipmont REMC Kankakee Valley REMC United REMC Kosciusko County REMC Wabash County REMC LaGrange County REMC Warren County REMC Marshall County REMC White County REMC Whitley County REMC

. Question #1 To assist the regulatory staff in its review, an applicant for a license to operate a commercial nuc-lear power plant should consider the following items and any related changes that have occurred or are planned to occur since submission of the construction permit application:

Question #1a Anticipated excess or shortage in generating capacity resources not expected at the construction permit stage. Reasons for the excess or shortage along with data on how the excess will be allocated, distrib-uted, or otherwise utilized or how the shortage will be obtained.

Answer Sla At the time the construction permit application was submitted, WVPA did not own or operate any generating facilities. This shortage of generating capacity was to be met through wholesale power purchases from area suppliers.

Since the submission of the construction permit, WVPA has financially acquired or sought entitled commit-ments of generated capacity. Such capacity and entitlement shall reduce the shortage of generated capacity, hence, reducing required wholesale power purchases.

Question #1b New power pools or coordinating groups or changes in structure, activities, policies, practices, or mem-bership of power pools or coordinating groups in which the licensee was, is, or will be a partici-pant.

Answer #1b On August 27, 1982, WVPA and Public Service Company of Indiana, Inc. (PSI) executed a Power Coordination Agreement.. This Agreement will become effective when approved by all appropriate regulatory agencies.

Generally, the Power Coordination Agreement provides for coordination between WVPA and PSI in the planning and operation of their respective generation, trans-mission, and distribution facilities. The essence of the Agreement is that planning of future electric facilities will be on a one-system approach.

Question #1c Changes in transmission with respect to (1) the nu-clear plant, (2) interconnections, or (3) connections to wholesale customers.

Answer #1c WVPA has purchased certain transmission facilities from PSI pursuant to agreements with that company.

All facilities purchased were either existing.or under construction and are, or will be, used to transport power to WVPA's members.

(1) WVPA purchased the Marble Hill 345kV switchyard facility and reduced its planned ownership in the Marble Hill-Columbus 765kV transmission line from 78% to-60%.

(2) In conjunctior, with the agreements between WVPA and Northern Indiana Public Service Company (NIPSCO), WVPA sent a notification of cancella-tion of the service agreement betweeen NIPSCO and WVPA and requested a transmission agreement.

NIPSCO has not responded to such request. WVPA is proceeding with plans to take power to its members now being served by NIPSCO. However, no changes with respect to interconnections have been made or are planned at this time. At this point, WVPA has several options with respect to the source of such power, and the interconnec-tions necessary will depend upon which source is used.

(3) None.

Question #1d Changes in the ownership or contractual allocation of

the output of the nuclear facility. Reasons and basis for such changes should be included.

. t

' Answer #1d No changes have occurred or are planned to occur since submission of the construction permit applica-tion.

Question fle Changes in design,' provisions, or conditions of rate schedules and reasons for such changes. . Rate in-creases or decreases are not necessary.

Answer ele .From May, 1979, to May, 1982, WVPA continued to serve its member systems under a single pooling rate. The designation " pooling" is attributable to WVPA's blending the cost of its purchases from-its four (4) investor-owned suppliers. During this span of time, there have been general- rate increases and wholesale power cost adjustment increases. . However, there were no changes in design or provision of the rates, with the exception that the demand and energy charges incorporated therein have been periodically re-aligned with the underlying demand and energy costs.

On May 20, 1982, WVPA' received approval from the Pub-lic Service Commission of Indiana of a new schedule of rates ("WVPA-5"), which provides for a separate

., rate for delivery points falling-in each of WVPA's supplier's service areas. As will be highlighted below, the primary reason for this rate change was to i alleviate the competitive disadvantage some of WVPA's members were-placed in by a growing disparity in the underlying costs of WVPA's power purchases.

When WVPA's rates were originally implemented in January of 1978, none of WVPA's members experienced.

4 an increase or decrease in its annual wholesale power costs of more than 4.2% and 2.3%, respectively. In i contrast, the most recent data indicates this differ-ential had increased dramatically. ~ For example, Whitley County REMC was originally paying approxi-mately 4.2% more to WVPA than they would have paid to Indiana'& Michigan Electric Company (IEM), as opposed to currently paying 23.1% more. On the other* hand, Jasper County REMC was originally paying 2.3% less to WVPA than they would have paid to NIPSCO and would presently pay approximately 11.6% less.

Comparisons of WVPA's investor-owned suppliers' retail rates indicate that the wide variances in cost of power in each of WVPA's supplier areas is indica-tive of the similar comparison that can be made on the retail level. This being true , some of WVPA's members were placed in a position where they were

~

forced to charge retail rates materially higher than

h the retail rates being charged by . the neighboring retail distributor. Likewise other members were able to charge rates less than those of the neighbor-ing disbributor. To alleviate'this problem, WVPA's Board of Directors decided, after. extensive review of.

-the various alternatives, to. seek approval of an area rate. This area rate, in essence, splits the differ-ence between WVPA's pooled cost of power and the comparable wholesale rates being charged individually by the investor-owned suppliers, thus resulting in four (4) . separate rates to be charged by WVPA. The following excerpt from testimony supporting WVPA's Petition requesting the area rate describes the con-cept more completely:

"The rates to be applied to WVPA sales consist of two components, which are:

(1) the power cost component, and (2) the WVPA operation and maintenance com-ponent. The power cost component is unique to each supplier area and is based-(50%) upon WVPA's costs of power in that area, and the other (50%) is

based upon the pooled concept. The WVPA OEM is the same for all supplier areas and will collect WVPA's non-purchased power revenue requirements, which in-clude, but-are not limited to, the own-ership of transmission and distribution facilities, the ownership and operation j of WVPA's load management system, and the ownership and operation of WVPA's headquarters building."

In its Order approving WVPA's area rate, the Public Service Commission of Indiana stated:

. . . the tariff concept approved L herein shall be applicable for a period

! of one (1) year from the effective date l of this Order and that at the end of such period, Petitioner shall pres?nt evidence as to cost of providing power and other services to each of its mem-bers to support the 50% Pooling /50% Area rate concept approved herein . . . ."

l The Public Service Commission further Orde'ed: r l

. . . when Petitioner has generation resources in commercial operation over which it has load scheduling control, Petitioner shall apply to this Commis-l sion for an Order returning Petitioner

I to a 100% pooled rate concept for its rates . . . ."

Thus, while WVPA has its area rate "WVPA-5" in effect at present, subsequent justification has to be sub--

mitted to the Public Service Commission in early 1983.. Further, when WVPA has generation resources (i.e. Marble Hill) which.it.can actively schedule, it has no choice but to return'to a 100% pooled rate as was in effect prior to May, 1982.

Question #1f List of all (1) new wholesale customers, (2) trans-fers from one rate schedule to another, including copies of schedules not previously furnished, (3) changes in licensee's service area, and (4) licens-ee's acquisitions or mergers.

l Answer #lf(l) At the Etime of the construction permit application, Paulding-Putnam Electric Cooperative, Inc., R.R. 3, Paulding,-Ohio 45879, indicated an interest in receiving electric service from WVPA. Since then, Paulding-Putnam has become a member of WVPA.

Answer #1f(2) With the implementation of "WVPA-5," all delivery points were converted from a 100% pooled rate

("WVPA-4a") charged to all' members, to a seoarate rate charged according to supplier area as identified below (See Answer le). In.the following schedule, the numbers indicate the rate contained in "WVPA-5"

, that applies to sales to WVPA's member systems:

Rate Code Supplier Area 02 Public Service Company of Indiana, Inc.

03 Northern Indiana Public ServiceJCompany 04 Indiana & Michigan Electric Company 05 Indianapolis Power &

Light Company i

Member Delivery System Points Rate Code Boone County REMC 9 02 1 05 Carroll County-REMC 2 03 5 02 Fruit Belt Electric Cooperative 20 04 Fulton County REMC 2 03 4 02 Hancock County REMC 6 02 He.idricks County REMC 11 02 Jasper County REMC 7 03 Jay J REMC 10 04 Kankakee Valley REMC 13 03

., Kosciusko County REMC 12' 03 1 02 LaGrange County REMC 6 03 Marshall County REMC 8 03 Miami-Cass County REMC 5 02 Newton County REMC 4 03 Noble County REMC 2 03 8 04 Parke County REMC 10 02 Paulding-Putnam Electric l Cooperative, Inc. _

4 04 i

Steuben County REMC 7* 03 Tipmont REMC ~19 02 United REMC 9 04-2 02 Wabash County REMC 8 02 i

_ ,_ -. __ _ ~ _ . _ _ _ ~ _ . . - __ . . _ __ . . _ . . . _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ .

cont. Member Delivery System Points Rate Code Warren County REMC 4 03 6 02 White County REMC 10 03 Whitley County REMC 13 04

  • 0ne delivery point added after the rate change. A copy of approved rate schedule "WVPA-5' is attached hereto as Exhibit "A".

Answer #1f(3) WVPA's service area was increased by the Indiana portion of Paulding-Putnam Electric Cooperative, Inc.'s service area when it became a member of WVPA.

(See response #1f(l).) This addition to WVPA's ser-vice area covers portions of two (2) Indiana counties

---Allen and Adams---and is generally bounded on the north by Decalb County, on the south by the City of Decatur, on the east by the Indiana-Ohio state line, and on the west by the City of Fort Wayne.

Answer #1f(4) None.

Question #19 List of those generating capacity additions committed for operation after the nuclear facility, including ownership rights or power output allocations.

Answer #1g WVPA currently has an entitled commitment from PSI of 150 MW commencing in 1988 through 1996. The follow-ing tabulation represents the current schedule of that entitlement:

Gibson No. 4 Gibson No. 4 Block Available. Block Available Year MW Year MW 1988 150 1993 150 1989 150 1994 113 1990 150 1995 75 1991 150 1996 38 1992 150 1997 0 Question #1h Summary of requests or indications of interest by other electric power wholesale or retail distribu-tors, and licensee's response, for any type of elec-tric service or cooperative venture or study.

Answer #1h Recently, Hoosier Energy Rural Electric Cooperative, Inc., indicated to WVPA an interest in a long-term unit power sale to WVPA. WVPA has responded.that it is interested in such participation if partici-pation provides benefits to its members. WVPA is conducting economic analyses to determine the eco-nomic feasibility of this venture.

Question #2 Licensees whose construction permits include condi-tions pertaining to anti-trust aspects should list and discuss those actions or policies which have been implemented in accordance with such conditions.

Answer #2 Not applicable to WVPA.

f l

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~ f. PSCI NO. 5 Sheet No. 1

,I WKBASH VALLEY POWER ASSOCIATIC4, INC.

RATE SCHEDULE - WVPA-5

)

AVAIIABILITY Available to Rural Electric Membership Cooperatives who have executed a power supply contract with the Wabash Valley Power Association, Inc.

MONTHLY RATE DELIVERY POINTS SERVED BY PUBLIC EERVICE INDIANA THROUGH WVPA Maximum Demand Charge Distribution service at delivery voltages of 15,000 volts or le p Each KW of billing maximum demand ... S8.33 per KW. pgD PW 4 On@ER Transmission service at delivery voltages of 15,000 vol or more.

Each KW of billing maximum demand ... S7.83 per KW.

3$0 .I .

Energy Charge g g S.01744 per kilowatt hour for all energy used per month. .

) DELIVERY POINTS SERVED BY NORTHERN INDIANA PUBLIC SERVICE COMPANY THROUGH WVPA Maximum Demand Charge Distribution service at delivery voltages of 15,000 volts or less.

Each KW of billing maximum demand .. 58.05 per KW.

Transmission service at delivery voltages of 15,000 volts or more.

Each KW of billing maximum demand .. 57.55 per KW.

Energy Charge 3.01695 per kilowatt hour for all energy ust d per month.

DELIVERY POINTS SERVED BY INDIANA & MICHIGAN ELECTRIC COMPANY THROUGH WVPA Maximum Demand Charge Distribution service at delivery voltages of 15,000 volts or less.

Each KW of billing maximum demand . . 38.62 per KW. .

Transmission service at delivery voltages of 15,000 volts or'more.

Each KW of billing maximum demand .. 58.12 per KW. ,

s 5

Energy Charge i

S.01310 per kilowatt hour for all energy used per month.

Exhibit "A"

l l

PsCI NO. 5 I

Sheet No. la 1

}- DELIVERY POINTS SERVED BY INDIANAPOLIS POWER & LIGHT COMPANY THROUGH WVPA Maximum Demand. Charge Distribution service at delivery voltages of 15,000 volts or less.

Eact} KW of billing maximum demand ...$6.47 per EW..

Transmission service at delivery voltages of 15,000 volts or more.

Each KN of billing maximum demand ...$5.97 per EN.

Energy Charge

$.01429 per kilowatt hour for all energy used per month.

Determination of Billing Maximus Demand The monthly billing maximum demand shall be the greatest of the following f I

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, a. The highest 15 minute kilowatt demand metered d ring C***

the month, o

$ ,) Oq~{

b. 60% of the highest meter demand established duri sy *
  • M the previous twelve months, or , eg
c. The contract capacity. .

The billing demand shall be adjusted to reflect any load shifts that occur between delivery points., When delivery is at 15,000 volts or above, the metered demand shall be reduced by 1-1/24 for billing purposes.

l l.

Determination of Billing Energy l

The monthly billing energy shall be the total kilowatt hours used during the billing month. When delivsry is at 15,000 volts or more, the metered energy shall be reduced by 1-1/24 for billing purposes.

Fuel Cost Charge The above rates are subject to change in fuel cost charge' in accord-ance with IC8-1-2-1 et sec., as amended. The amount of the fuel cost charge is calculated in accordance with orders No. 35044 and No. 35687 of the Public Service Cosutission of Indiana. The change in fuel cost charge is stated in Appendix "B" which is . applicable hereto and is issued and effective on the date shown on Appendix "B".

Rate Adjustment ., N The above rates are subject to a wholesale power cost adjustmenti'1, *. .

tracking factor, in accordance with the order of the Public Service

~ ') Commission of Indiana, approved December 17, 1976 in Cause No. 34614

^

PSCI NO. 5 sheet No. lb

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g cnd adapted for use by Wabash Valley Power Association, Inc. in Cause No. 35044, and any such succeeding orders or provisions. The .

wholesale power cost adjustment tracking factor stated in Appendix "A" is applicable hereto and is issued and effective on the data shown on Appendix 'A".

Tax Adjust-mnt Clause .

The rates charged under this schedule shall be adjusted to provide an amount sufficient to reimburse Wabash Valley Power Association, Inc.

for any amounts payable by it as a result of the imposition or removal of any sales, excise or similar taxes or assessments based on the totti sales or receipts of WVPA or a portion thereof imposed after the effec-tiva date of this schedule.

Power Factor The members shall, at all times, take and use power so as to maintain as nearly as practicable a 100% power factor at the time of the metered maximum kilowatt demand. When the power factor at the time of the metered maximum demand is determined to be less than 90%, the maximum billing demand shall be determined by multiplying the metered maximum demand by 90% and dividing the product thus obtained by the actual power factor.

Metering Service will be delivered and metered at a nominal voltage of 12,470 volts or more. If, however, deliveries are metered at a voltage in excess of 12,470 volts, the metered kilowatts and kilowatt hours will be reduced by 1-1/24 for billing purposes.

Terms of Payment Bills shall be rendered monthly and shall be due within 10 days the date thereof. If bills are not paid by the said t ey2It}D l

of 84 per annum shall be applied to the unpaid b pts OSD

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PSCI NO. A Sheet No. 1 1I

) WABASH VAILEY POWER ASSOCIATION, INC.

,l . APPENDIX "A" Rate Adjustment (Applicable to Rate "WVPAS" - PSI Delivery Points) ,

The rate adjustment shall be on the basis of-a Purchased Power Cost Adjustment Tracking Factor occasioned solely by changes in the cost of purchased power in accordance with the orders of the Public Service Connaission of Indiana, approved December 17, 1976 in Cause

= No. "J4614 and t!)e Wabash Valley Power Association, Inc. Pooling Rate Order in Cause No. 35044, approved December 20, 1977.

Rate adjustment applicable to the above listed rate schedule - PSI Area S.000165 Includes Wholesale Power Cost Changes through ,,gg gg 10 PSI ER81-708, 155U p 5LR

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PSCI NO. A Sheet No. la r l WABASH VALIJ:Y POWER ASSOCIATION, INC.

APPENDIX "A" l,

Rate Adjustment (Applicable to Rate "WVPAS" - NIPSCO Delivery Points) j The rate adjustment shall be on the basis of*a Purchased Power Cost Adjustment Tracking Factor occasioned solely by changes in the

, cost of purchased power in accoruance with the orders of the Public I

Service Comunission of Indiana, approved December 17, 1976 in cause No. 34614 and the Wabash Valley Power Association, Inc. Pooling Rate l Order in Cause No. 35044, approved Decsaber 20, 1977.

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Rate adjustment applicable to the above listed rate schedule - NIPSCO Area $.000165 Includes Wholesale Power Cost Changes through ,

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- WhBASH VALLEY POWER ASSOCIATION, INC.

APPENDIX "A" Rate Adjustment (Applicable to Rate "WVPAS" - ism Delivery Points)

The rate adjustment shall be on the basis of a Purchased Power cost Adjustment Tracking Factor occasioned solely by changes in the cost of purchased power in accordance with the orders of the Public Service Connaission of Indiana, approved December 17, 3*76 in Cause No. 34614 and the Wabash Valley Power Association, Inc Pooling Rate Order in Cause No. 35044, approved December 20, 1977.

Rate adjustment applicable to the above listed rate schedule - I&M Area $.000165 Includes Wholesale Power Cost Changes through PSI ER81-708. ,

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/ WABASH VALLEY POWER ASSOCIATION, INC.

APF3IDIX "A" Rate Adjustment (Applicable to Rate "WVPAS" - IP&L Delivery Points)

The rate adjustment shall be on the basis of "a Purchased Power Cost Adjustment Tracking Factor occasioned solely by chuwges in the cost of purchased power in accordance with the orders of the Public Service coussission of Indiana, approved December 17, 1976 in Cause No. 34614 and the Wabash Valley Power Association, Inc. Pooling Rate Order in Cause No. 35044, approved December 20, 1977.

Rate adjustment applicable to the above listed rate schedule - IP&L Area G.000165 Includes wholesale Power Cost Changes through p W e'*A'#

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