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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196G4021999-06-18018 June 1999 Comment on FRN Re Rev of NRC Enforcement Policy NUREG-1600, Rev 1 & Amend of 10CFR55.49.Concurs with Need to Provide Examples That May Be Used as Guidance in Determining Appropriate Severity Level for Violations as Listed ML20206H1881999-05-0606 May 1999 Exemption from Requirements of 10CFR50,App K Re ECCS Evaluation Models. Commission Grants Licensee Exemption ML20206H2221999-05-0404 May 1999 Exemption from Requirements of 10CFR50.60 That Would Allow STP Nuclear Operating Co to Apply ASME Code Case N-514 for Determining Plant Cold Overpressurization Mitigation Sys Pressure Setpoint.Commission Grants Exemption ML20206M5111999-04-30030 April 1999 Comment Supporting Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e). Recommends That Listed Approach Be Adopted for Changes to Documents Incorporated by Ref CY-99-007, Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-0071999-02-22022 February 1999 Comment Supporting Proposed Changes to Improve Insp & Assessment Processes for Overseeing Commercial Nuclear Industry That Were Published in Fr on 990122 & in SECY-99-007 TXX-9825, Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps1998-12-14014 December 1998 Comment Endorsing NEI Comments on Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness at Npps ML20195C7541998-11-0505 November 1998 Order Approving Application Re Proposed Corporate Merger of Central & South West Corp & American Electric Power Co,Inc.Commission Approves Application Re Merger Agreement Between Csw & Aep ML20155H5511998-11-0202 November 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submission of Revs to UFSAR ML20154C4101998-09-30030 September 1998 Comment Re Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Comanche Peak Electric Station Endorses NEI Comment Ltr & Agrees with NEI Recommendations & Rationale ML20248K5051998-06-0909 June 1998 Confirmatory Order Modifying License (Effective Immediately).Answer for Request for Hearing Shall Not Stay Immediate Effectiveness of Order ML20216E1051998-04-0707 April 1998 Comment Supporting Draft RG DG-1029 Titled Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safety-related Instrumentation & Control Sys NOC-AE-000109, Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Rev to 10CFR50.55a, Industry Codes & Standards.South Texas Project Fully Endorses Comments to Be Provided by NEI ML20217H3611998-03-26026 March 1998 Comment Opposing Draft GL 97-XX, Lab Testing of Nuclear Grade Charcoal, Issued on 980225.Advises That There Will Be Addl Implementation Costs ML20198Q4851998-01-16016 January 1998 Comment Opposing PRM 50-63A by P Crane That Requests NRC Amend Regulations Re Emergency Planning to Require Consideration of Sheltering,Evacuation & Prophylactic Use of Potassium Iodide for General Public ML20211A4871997-09-12012 September 1997 Changes Submittal Date of Response to NRC RAI Re Proposed CPSES risk-informed Inservice Testing Program & Comments on NRC Draft PRA Documents ML20149L0311997-07-21021 July 1997 Comment on Draft Guides DG-1048,DG-1049 & DG-1050.Error Identified in Last Line of DG-1050,item 1.3 of Section Value/Impact Statement.Rev 30 Should Be Rev 11 ML20140A4871997-05-27027 May 1997 Comment Opposing Proposed Rule Re Safety Conscious Work Environ.Util Agrees W/Nuclear Energy Inst Comment Ltr ML20137U3531997-04-0808 April 1997 Order Approving Application Re Formation of Operating Company & Transfer of Operating Authority ML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20135B7881996-11-29029 November 1996 Order Approving Corporate Restructuring of TU to Facilitate Acquistion of Enserch Corp ML20128M8011996-10-0303 October 1996 Comment Opposing Proposed NRC Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20097D7321996-02-0909 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info ML20094Q6421995-11-28028 November 1995 Comment Supporting Petition for RM PRM-50-62 Re Amend to Regulation Re QAPs Permitting NPP Licensees to Change Quality Program Described in SAR W/O NRC Prior Approval If Changes Do Not Potentially Degrade Safety or Change TSs ML20094H4801995-11-0808 November 1995 Comment Supporting Nuclear Energy Inst Comments on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Nuclear Fuel or high-level Radwaste TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20091M6441995-08-25025 August 1995 Comment Opposing Proposed Rule Re Review of Revised NRC SALP Program.Believes That NRC Should Reconsider Need for Ipap or SALP in Light of Redundancy ML20086M7921995-07-0707 July 1995 Comment Supporting Proposed GL Process for Changes to Security Plan Without Prior NRC Approval ML20084A0181995-05-19019 May 1995 Comment Suporting Proposed Rule 10CFR50 Re Containment Leakage Testing.Supports NEI Comments ML20077M7311994-12-30030 December 1994 Comments Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations for Nuclear Power Reactors ML20077L8711994-12-22022 December 1994 Comment Supporting Proposed Rule 10CFR50,55 & 73 Re Reduction of Reporting Requirements Imposed on NRC Licensees ML20073B6951994-09-19019 September 1994 Affidavit of Cl Terry Authorizing Signing & Filing W/Nrc OL Amend Request 94-016 ML20073B6731994-09-19019 September 1994 Affidavit of Cl Terry Re License Amend Request 94-015 ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20092C3911993-11-15015 November 1993 Partially Deleted Response of Rl Balcom to Demand for Info ML20092C4031993-11-15015 November 1993 Partially Deleted Response of Hl&P to Demand for Info ML20058E0561993-11-10010 November 1993 Comment on Proposed Rule Re Staff Meetings Open to Public. Believes That NRC Has Done Well in Commitment to Provide Public W/Fullest Practical Access to Its Activities ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML20045D8321993-06-11011 June 1993 Comment Supporting Proposed Rules 10CFR50 & 54, FSAR Update Submittals. ML20044F3271993-05-21021 May 1993 Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp, Fr Vol 58,Number 52.NRC Should Use EPRI Definitions for Critical Characteristics ML20044D3311993-05-0404 May 1993 Comment Supporting Proposed Generic Communication Re Mod of TS Administrative Control Requirements for Emergency & Security Plans ML20056C0831993-03-19019 March 1993 Texas Utils Electric Co Response to Petitioners Motion to Stay Issuance of Full Power License.* Licensee Urges NRC to Reject Petitioners Motion & to Deny Petitioners Appeal of 921215 Order.Motion Should Be Denied.W/Certificate of Svc ML20056C1881993-03-17017 March 1993 Order.* Directs Util to Respond to Motion by COB 930319 & NRC to Respond by COB 930322.W/Certificate of Svc.Served on 930317 ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20128D9651993-02-0303 February 1993 Memorandum & Order.* Stay Request Filed by Petitioners Denied.W/Certificate of Svc.Served on 930203 ML20128D4651993-02-0202 February 1993 Texas Utils Electric Co Response to Emergency Motion to Stay Issuance of low-power Ol.* Petitioner Request Should Be Denied Based on Failure to Meet Heavy Burden Imposed on Party.W/Certificate of Svc ML20128D3391993-02-0202 February 1993 Emergency Motion to Stay Issuance of low-power Ol.* Petitioners Specific Requests Listed.W/Certificate of Svc ML20128D6321993-01-29029 January 1993 Memorandum & Order.* Denies Citizens for Fair Util Regulation for Fr Notice Hearing on Proposed Issuance of OL for Facility.W/Certificate of Svc.Served on 930129 ML20128D3461993-01-29029 January 1993 NRC Staff Notification of Issuance of OL for Facility.* Low Power License May Be Issued by 930201.W/Certificate of Svc ML20128D6111993-01-26026 January 1993 Joint Affidavit of I Barnes & Ft Grubelich Re Borg-Warner Check Valves.* Discusses Issues Re Borg-Warner Check Valves Raised by Cfur & Adequacy of Actions Taken by TU Electric 1999-06-18
[Table view] Category:TRANSCRIPTS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl 1996-07-19
[Table view] Category:DEPOSITIONS
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl 1996-07-19
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20133G5411996-12-0505 December 1996 Transcript of 961205 Meeting in Arlington,Tx Re Comanche Peak Thermo-Lag Fire Barriers. Pp 1-111 ML20116B8871996-07-19019 July 1996 Transcript of 960719 Predecisional Enforcement Conference Re Apparent Violations of NRC Requirements at Plant ML20072P5441994-07-13013 July 1994 Testimony of Rl Stright Re Results of Liberty Consulting Groups Independent Review of Prudence of Mgt of STP ML20128F6221993-02-0303 February 1993 Transcript of 930203 Affirmation/Discussion & Vote Public Meeting in Rockville,Md.Pp 1-2.Related Info Encl ML20066B5631989-10-27027 October 1989 Transcript of 891027 Investigative Interview of Bp Garde in Arlington,Tx.Pp 1-91 ML20066B5351989-10-23023 October 1989 Transcript of 891023 Investigative Interview of Tl Austin in Houston,Tx.Pp 1-45.Related Info Encl ML20244C9131989-03-28028 March 1989 Transcript of 890328 Meeting in Rockville,Md Re Discussion/ Possible Vote on Full Power Ol.Pp 1-65.Supporting Documentation Encl ML20055G7801988-11-10010 November 1988 Investigative Interview of La Yandell on 881110 in Arlington,Tx.Pp 1-13.Related Info Encl ML20055G7151988-11-0909 November 1988 Investigative Interview of J Kelly on 881109 in Arlington, Tx.Pp 1-35.Supporting Documentation Encl ML20055G7831988-11-0909 November 1988 Investigative Interview of R Caldwell on 881109 in Arlington,Tx.Pp 1-27.Related Info Encl ML20055G7881988-11-0909 November 1988 Investigative Interview of AB Earnest on 881109 in Arlington,Tx.Pp 1-90.Related Info Encl ML20151B3591988-07-13013 July 1988 Transcript of 880713 Hearing in Dallas,Tx.Pp 25.187-25,295 ML20154R3061988-06-0101 June 1988 Transcript of 880601 Prehearing Conference in Dallas,Tx. Pp 25,157-25,186 ML20148K0271988-03-21021 March 1988 Transcript of 880321 Discussion/Possible Vote on Full Power License for South Texas Nuclear Project,Unit 1 (Public Meeting) in Washington,Dc.Viewgraphs Encl.Pp 1-73 ML20151B5821988-02-25025 February 1988 Transcript of 880225-26 Public Meetings W/Case & J Doyle ML20238C3921987-12-0909 December 1987 Transcript of 871209 Public Meeting in Dallas,Tx Re Status of Corrective Action Programs at Facility.Pp 1-60 ML20236J3981987-11-0303 November 1987 Transcript of 871103 Prehearing in Dallas,Tx.Pp 25,139- 25,156 ML20245D1231987-11-0202 November 1987 Transcript of 871102 Special Prehearing Conference in Dallas,Tx.Pp 24,963-25,138 ML20149E5451987-10-16016 October 1987 Transcript of T Tyler 871016 Deposition in Dallas,Tx Re Facility.Pp 1-51 ML20149E5411987-10-16016 October 1987 Transcript of Jf Streeter 871016 Deposition in Dallas,Tx Re Facility.Pp 1-95 ML20149E5231987-10-15015 October 1987 Transcript of Wg Counsil 871015 Deposition in Dallas,Tx Re Facility.Pp 1-86 ML20149E5301987-10-15015 October 1987 Transcript of JW Beck 871015 Deposition in Dallas,Tx Re Facility.Pp 1-56 ML20149E5061987-10-15015 October 1987 Transcript of J Hansel 871015 Deposition in Dallas,Tx Re Facility,Vol Ii.Pp 1-54 ML20149E4191987-10-14014 October 1987 Transcript of J Hansel 871014 Deposition in Dallas,Tx Re Facility,Vol I.Pp 1-125 ML20238A6921987-09-0303 September 1987 Partially Withheld Rept of Interview W/R Spangler Re Allegations Concerning QA Audit Group ML20238A7201987-09-0303 September 1987 Partially Withheld Rept of Interview W/Gs Keeley Re Clarification of Info Contained in 831019 Rept Prepared by R Spangler Re Alleged Intimidation of QA Audit Group by Util QC Site Manager.Related Info Encl ML20235H8341987-08-0505 August 1987 Transcript of 870805 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 128-224 ML20237G2781987-07-30030 July 1987 Vol II of Transcript of 870730 Public Meeting W/Util.Pp 2- 87.Supporting Documentation Encl ML20237G2721987-07-29029 July 1987 Vol I of Transcript of 870729 Public Meeting W/Util.Pp 2- 129.Supporting Matl Encl ML20235H8031987-07-27027 July 1987 Transcript of 870727 Deposition of Bp Garde in Bethesda,Md Re Plant.Pp 1-127.Supporting Documentation Encl ML20235T7021987-07-20020 July 1987 Transcript of 870720 Telcon in Washington,Dc.Pp 24,892- 24,962 ML20237L0731987-04-0909 April 1987 Partially Deleted Transcript of Unnamed Region IV Official 870409 Interview Re Region IV Mgt Handling of Two Insp Repts of Plant ML20214J9581987-04-0707 April 1987 Transcript of 870407 Meeting in Dallas,Tx.Pp 1-85 ML20209E5821987-04-0202 April 1987 Transcript of 870402 Meeting in Bethesda,Md Re Comanche Peak Response Team Program.Pp 1-101.Supporting Documentation Encl ML20212Q7331987-01-29029 January 1987 Transcript of 870129 Hearing in Bethesda,Md.Pp 1-82 ML20097J5141987-01-22022 January 1987 Partially Deleted,Transcript of 870122 Sworn Statement in Bay City,Tx.Pp 1-101 ML20155F8161987-01-0707 January 1987 Transcript of 870107 Nrc/Comanche Peak Steam Electric Station Mgt Meeting in Glen Rose,Tx.Viewgraphs Encl. Pp 1-100 ML20215E0031986-12-15015 December 1986 Transcript of 861215 Prehearing Conference in Bethesda,Md Re Facility.Pp 24,676-24,826 ML20097J4821986-11-0606 November 1986 Partially Deleted Transcript of 861106 Sworn Statement in Lake Jackson,Tx.Pp 1-63 ML20210B3271986-09-10010 September 1986 Transcript of 860910 Hearing in Chicago,Il.Pp 12,338-12,563 ML20214L0401986-08-19019 August 1986 Transcript of 860819 Hearing in Dallas,Tx Re Comanche Peak. Pp 24,600-24,675 ML20214L0301986-08-18018 August 1986 Transcript of 860818 Hearing in Dallas,Tx.Pp 24,423-24,600. Supporting Documentation Encl ML20237L3691986-07-25025 July 1986 Partially Deleted Transcript of I Barnes 860725 Investigative Interview in Arlington,Tx Re Insps at Plant & Region IV Regulation of Facility.Pp 1-75.Supporting Documentation Encl ML20237L7051986-07-24024 July 1986 Transcript of Le Ellershaw 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps of Plant & Region IV Regulation of Facility.Pp 1-16 ML20238A3271986-07-24024 July 1986 Partially Deleted Transcript of W Warren 860724 Sworn Statement in Glen Rose,Tx Re Activities Involving Phillips at Plant ML20237L4311986-07-24024 July 1986 Transcript of C Hale 860724 Investigative Interview in Glen Rose,Tx Re NRC Insps at Plant & Region IV Regulation of Facility.Pp 1-84 ML20237L3581986-07-23023 July 1986 Partially Deleted Transcript of J Gagliardo 860723 Sworn Statement in Arlington,Tx Re Activities of Senior Resident Inspector for Const at Plant.Pp 1-31 ML20238A8021986-07-23023 July 1986 Partially Deleted Transcript of T Westerman 860723 Sworn Statement in Arlington,Tx Re Insp Repts 85-14 & 85-11 & Draft 2-A in Phillips Matrix.Pp 514-707.Supporting Documentation Encl ML20237L5541986-07-22022 July 1986 Marked-up Transcript of E Johnson 860722 Investigative Interview in Arlington,Tx Re Mgt at Plant.Pp 1-138.Partially Deleted Addendum Encl ML20238B8101986-07-22022 July 1986 Partially Deleted Transcript of B Taylor 870722 Investigative Interview in Arlington,Tx Re Region IV Insp Program at Plant.Pp 1-31.Supporting Documentation Encl 1996-07-19
[Table view] |
Text
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. . TESTIMONY OF DAVID A. SPRINGS ,
FPC DOCITT NO. E-7685 1 Q. Please state your name and place of residence.
.2 A David A. Springs, 4514 North Peachtree Road, Chamblee, 3 Georgia.
4 Q Would you state your educational background, please.
5 A I was graduated from GeorgiP. Institute of Technology 6 in 1948 with a Bachelor of Electrical Engineering Degree, 7 and again in 1949 with a Degree of Master of Science in 8 Electrical Engineering.
9 Q Would you state briefly your experience.
I 10 A During graduate work at Georgia Tech, I had the unique s
11 experienge of working 15 ' months as Assistant Operator 12 of the Georgia Tech AC Network Calculator. At that 13 time, the calculator was the most advanced tool for 14 studying the overall operations of power systems. This 15 experience gave me a very early understanding of load 16 flow and stability problems on large utility systems.
17 Af ter graduation, I worked for Southern Engineering 18 Company in Atlanta, Georgia, for approximately three 19 years doing distribution design work, transmission 20 system design, and long-range power supply planning.
b..- 21 From 1952 to 1963, I was with the South Carolina 22 Public Service Authority, first as Supervisor in Charge 7 000= G WO27 1013 002
1 of Wholesale Billing, and then for a period of six 2 years aa their Planning Engineer.
3 Since returning to Southern Engineering Company 4 of Georgia in 1963, I have been in charge of the Power
'S Supply Planning and Power System Planning Section.
6 Q Are you a registered professional engineer?
7 A Yes, I am registered in the State of Georgia.
8 Q To what scholastic and professional societics do 9 you belong?
10 A I am a member of the IEEE and the Georgia Society of 1
11 Professional Engineers. I am also a member of Tau 12 B ta Pi (Scholastic Engineering) and the Eta Kappa Nu 13 (Scholastic Electrical) . -
14 0 nave you ever testified in other Federal Power 15 Commission cases?
16 A Yes. I have previously testified in the following 17 proceedings: Georgia Power Company, FPC Docket No. E-18 7548; Carolina Power and Light, FPC Docket No. E-7564; 19 Duke Power Company, FPC Docket No. E-7557'; and Missis-20 sippi Power Company, FPC Docket No. E-7625. I have 21 also submitted my direct testimony for the Florida 22 Power Corporation Case, FPC Docket No. E-7679.
@b N8 N
A ooj
l Q Ly whom is your firm retained in this proceeding?
{
2 A Vermont Electric Cooperative, Inc.
~
3 Q What was your assignment?
4 A My assignment in this proceeding was a limited one.
5 It was to determine the reasonableness of the 90%
6 " ratchet" provision contained in the Central Vermont 7 Public Service Corporation (CVPS) proposed Resale .
8 Service Rate "R" Schedule as to whether such a ratchet 9 can or should be based upon demand data occurring prior 10 to the effective date of the rate schedule containing t
il the ratchet provision.
. v.
12 O What material and information did you review in carrying 13 out your assigniaent?
14 A The CVPS Monthly Operating Reports for the years 1970 15 and 1971, the FPC Form 1 and Form 12 Reports of CVPS 16 for the same years, CVPS's proposed Resale Service Rate 17 "R" Schedule, CVPS 's Statement "M" filing, and testimony 18 filed by various witnesses in this proceeding, cach in 19 Part as they relate specifically to my assignment.
20 O Would you first explain what is neant by a " demand 21 ratchet provision".
22 A It is a rate-making device which may be used in the
- e design of an electric power rate schedule, when
{ l 2 appropriate, to cause either the pricing elements in 3 the rate schedule to reflect the cost elements being 4 priced, to levelize the revenues from demand charges 5 over a period of time (usually one year) or to encourage 6 improvement in load factor. Essentially, the ratchet 7 sets the minimum billing demand charge in any month 8 relative to the maximum peak demand required by the 9 customer during a preceding period of time.
10 Stated in its simplest form, it may be said that 1
11 a rate schedule usually attempts to price two basic 12 ebements: the demand element and the associated energy 13 element. The demand element is a measure of capacity 14 or capability of delivering power and is usually 15 expressed in kilowatts (KW) or kilovolt-amperes (KVA).
16 The cecond element, the energy element, attempts to 17 put a price on the accumulated hour-by-hour use of the 18 demand or capacity element, and is usually expressed 19 in kilowatt-hours. In effect, the demand' element is 20 usually measured as the maximum rate of using energy 21 throughout the billing period which is usually one month.
22 It is simply the maximum kilowatt-hours taken per hour IOl u!y, ,
4-1013 005 .
1 and therefore expressed in kilowatts.
2 Since the first element, or the demand element, 3 determines the capacity that must be built into the 4 facilities provided by the utility for a service,
5 this is the element the utility would use in attempting 6 to recover its costs which are fixed in nature and do 7 not vary with the amount of energy actually delivered.
8 These costs are primarily those costs associated with 9 investment plus certain operating cos'ts which tend to 10 be fixed. All other costs,which would tend to vary with t
il the amount of energy produced and sold,would be recovered 12 by the utility through the energy or KWH pricing element.
13 It is the im element, or 'the element associated with 14 fixed costs, in which the demand ratchet provision would 15 come into play if found necessary in a rate schedule to 16 Properly recc.er fixed costs for the utility.or if found 17 desirable to levelize revenues.
18 The demand ratchet provision usually states simply 19 that, in the determination of billing demand for any 20 billing month, the billing demand shall not be less 21 than a certain percentage of the maximum demand established during the previous year. This, in effect, 22 1013 006
1 allows for the pricing of fixed cost elements to
(
2 continue at the necessary or desired level even though 3 the use by the customer >r group of customers might 4 drop below the " minimum billing domand" established 5 by the ratcl.et.
6 Q How do you determine whether a given demand ratchet 7 is necessary to recover fixed costs of the utility?
8 A Stated very basically, the necessity of a demand 9 ratchet provision in the rate schedules of a utility 10 usually develops when, throughout the annual cycle of
'11 operation of the utility's facilities, there is gener-
.c
( 12 ating or transmitting capacity which sits idle seasonally 13 and is otherwise unsold and not necessary or usable as 14 needed reserve capacity. If there is no such capacity 15 standing for periods of time unused on a utility system, 16 there is no necessity for that utility to incorporate 17 demand ratchet provisions in its 2. ate schedule. With 18 this simple test as a measure of the need for demand 19 ratchet provisions in rate schedules, there are at least 20 five conditions or circumstances on the utility's system 21 which should be considered and taken into account in 22 determining whether a ratchet provision is necessary j j G --
((
1 to recover fixed costs and, if so, at what level the 2 ratchet should be set:
3 (1) seasonally varying fixed costs. If a utility 4 has a seasonally varying fixed cost pattern, 5 which is similar to its seasonal load pattern, 6 the utility would not have fixed costs in the 7 off-Peak season to be recovered through a 8 ratchet provision.
9 (2) Diversity between seasonal load natterns of 10 customers or classes of customers. To the 1
11 extent that customers or classes of customers
. v.
12 tend to use their maximum demands during different 13 seasons of the year', there would be a certain 34 amount of installed capacity and related fixed 15 costs that would be put to double use and there-16 f re would not be standing idle seasonally.
17 (3) Maintenance and other reserve canacity requirements.
18 To the extent that capacity which is normally sold 19 to customers during peak requirement' periods 26 seasonally is used in the off-season for main-21 tenanta purposes (in other words, used in the 22 P l ace of facilities that are then being maintained) ,
101~3 008 1
1
1 there is a certain amount of capacity that is there-2 by not standing idle seasonally. Incidentally, 3 some utilities are actually " maintenance 4 saturated" whereby they are maintaining generating 5 equipment over their annual peak because they do 6 not have enough capacity in their seasonally off-7 peak periods to carry out their maintenance program.
8 (4) The ability to exchance capacity seasonally with 9 other utilities. If a utility is located within 10 practical transmission distance of other utilities
'll which have seasonally different load atterns,
.c 12 there is a resulting capability for exchanging 13 capacity seasonally with such utilities. This 14 not only tends to reduce the utility's investment 15 in generating facilities, but it also makes good 16 use of some of the off-season capacity which might 17 otherwise be standing idle.
18 (5) Having the ability to buy and the market to sell 19 capacity and/or energy on an " emergency" basis.
20 A utility which has interconnections and arrange-21 ments v/hich give it sources to purchase "emeigency" 22 capacity and/or energy and the market to nell U 3tpt
1013 009
1 " emergency" capacity and/or energy is accordingly 2 able to reduce reserve capaci ty requirements and 3 to obtain some revenue from seasonally off-peak 4 capacity which may ot'erwise stand idle.
5 Q. Have you analyzed CVPS's proposed 90% demand ratchet 6 to determine vihether it is necessary to recover CVPS's 7 fixed costs?
8 A. Taking each of the five conditions which I have just 9 described which tend to measure the necessity for a 10 ratchet provision to recover fixed costs, I found the i following:
ll 12 () Since the overall determination of the need for a 13 ratchet provision in a rate schedule is a cumulative 14 thing, the most prominant circumstance or condition 15 affecting it should be considered first. In the case 16 of the CVPS systcm in this filing, by far the most 17 Pronounced circumstance which tends to affect this 18 consideration is the fact that the fixed costs on the 19 CVPS system varios considerably on a monthly basis.
20 In those months of the year when the CVPS load is 21 highest, its fixed costs tend to be highest; and in 22 those months when the CVPS load is lowest, their fixed
_ 9_
1013 010-
1 costs tend to be lowest. My Exhibit (DAS-1),
2 entitled " Monthly Comparison of Total Available 3 Generation with Monthly Peak Loads for the Years 1970 4 and 1971", shows a bar graph by months of the total "5 generation capability and the monthly peak load of 6 the CVPS system for eacia month of both the Test Year 7 1970 and the year 1971. It will be noted that the 8 graphs show that the total generation capability 9 available to CVPS varies considerably thr3ughout the 10 year and also to a considerable extent follows the
'll Pattern of the monthly peak load. This is a result
. c.
, 12 of the fact that CVPS purchases a very large pei entage
(
13 of its total generation capability. For instanc2, in 14 December, 1970, it purchased approximately 73%, and 15 in June, 1970, it purchased approximately 60%. In 16 other words, in December of 1970, CVPS purchased 247 17 megawatts out of a total generation capability of 338 18 megawatts, and in June, 1970, CVPS purchased 141 19 megawatts out of a total generation capab'ility of 232 20 megawatts. Quite a large percentage of these purchases 21 are either short-term purchases or allow for wasonal 22 variations which result in the pattern shown in
... 1013 011 Jl.L s e
( 1 Exhibit (DAS-1).
2 O What is the source of CVPS 's purchased power?
3 A Theu: re many and varied sources throughout New England .
4 plus the Pcaer Authority of the State of New York plus 5 the New Brunswick system in Canada. A list of the 6 sources and a tabulation ot the amounts of the purchases 7 by months is shown on Witness Chayavadhanangkur's 8 Exhibit (JC-1) , pages 3 and 4.
9 O How is it possible that CVPS is able to tap such wide 10 and varied sources for purchased power?
11 A CV S obtains power over the interconnected transmission systems of New England and New York into the State of
( 12 13 Vermont and then over the VELCO system into CVPS, under 14 many varied contractual arrangements.
15 Q How is Central Vermont able to pattern its seasonal 16 purchases generally in accordance with its seasonal 17 needs?
18 A It is in prrt due to the coordinated planning of the 19 utilities in the entire area as to the scheduling of 20 new generation. It is also due in part to the fact 21 that the interconnected systems of New England and 22 New York are able to exchange capacity seasonally
~ -
1013 012 a
1 during the winter peaking months of upper New England
(
2 and the summer peaking months of New York City up into 3 Massachusetts. This is being done under a number of 4 varied contractual arrangements which I am personally 5 not fmmiliar wiVa, but the effect of it does reach up 6 into Vermont. A good e'xample of this is the contract 7 which CVPS has with the Boston Edison system (actually 8 purchased and brought into tl a State by tne VEICO 9 sys tem) which provides for the following seasonally .
10 varying capacity purchases:
1 11 July 1, 1970 to September 30, 1970 44,476 Kilowatts 12 October 1, 1970 to May 31, 1971 127,497 Kilowatts
(
13 June 1, 1971 to Septembar 30, 1971 8,903 Kilowatts 14 October 1, 1971 to May 31, 1972 44,605 Kilowatts 15 June 1, 1972 to September 30, 1972 8,903 Kilowatts 16 October 1, 1972 to May 31, 1973 44,605 Kilowatts 17 June 1, 1973 to September 30, 1973 8,903 Kilowatts 18 October 1, 1973 to May 31, 1974 44,605 Kilowatts 19 June 1, 1974 to September 30, 1974 8,903 Kilowatts 20 October 1, 1974 to May 31, 1975 118,602 Kilowatts 21 June 1, 1975 to September 30, 1975 44,605 Kilowatts 22 The varying seasonal availability is obvious.
~I ~
a .1 - t ;l 1013 013
( l Q What do you conclude from this?
2 A I conclude that CVPS through the purchasing agreements 3 it han .sith other utilities has been able successfully 4 to fairly closely match its total available generation
S capacity to its n.onthly peak load. There are occasional 6
excesses above needs to' meet loads from time to time, but the amount of excess has no consistent relationship 7
8 with previous system peaks. The monthly pattern itsel.
9 is not even consistent, as would be indicated by comparing 10 Sheets 1 and 2 of the Exhibit (DAS-1). This i certainly shows that a demand ratchet based upon the ll
( 12 P evious peak demand has very little place in the cost 13 patterns of CVPS. Incidentally, this shows very strongly 14 that the 12-month average coincidant demand method of 15 allocating fixed costs is the proper method..
16 Q Please continue with your analysis of CVPS's ratchet as 17 to each of your five criteria.
18 A Continuing with the second condition:
19 (2) A cursory review of delivery point m'etering data 20 within the wholesale for resale customer class indicates 21 there would be come but not a great deal of seasonal 22 diversity between the delivery points. I did not have
~ ~
1013 014
1 the time to make a detailed study here, but this
(
2 would be somewhere between 5;? and 10%. This would 3 tend to say that there is a doubling up on the sale 4 of capacity seasonally within the wholesale for resale 5 class, which would tend to reduce the need for a demand 6 ratchet by approximately 5% to 10%.
7 (3) The need for seasonally off-peak capacity to meet 8 scheduled maintenance is not obvious on the CVPS system.
9 This is duc, of course, to the fact that the CVPS 10 system has only a small amount of generating capacity
'll in its system. However, the same effect comes into
.c 12 P lay with the " unit purchases" of CVPS from the outside 13 which are not otherwise firmed. In effect, when these 14 unit purchases are from generating units which aro down 15 for maintenance purposes, they must be replaced by 16 CVPS with other capacity. Since it is normal for such 17 units to be scheduled for maintenance in the months of 18 the year when the area loads are lowest, in effect 19 these maintenance reserve kilowatts would have a 20 tendency to be used for this purpose and otherwise 21 not stand idle in the off-peak months on the CVPS 22 system.
( .
Ii 'fbr i: ti LaUl 1013 015
r' 1 (4) In my test of CVPS 's ability to exchange capacity 2 seasonally with other utilities, this is definitely 3 an effective consideration. However, it has been 4 accomplished in a round-about way to a considerable 5 extent through the seasonal purchases discussed under 6 Paragraph (1) above.
7 (5) A cursory review of the Operating Reports of CVPS 8 indicates that, in the month-to-month operation of its 9 system, it is able to sell considerable quantities of 10 capacity and energy either as emergency power or other-t wise. This would definitely have a tendency to make il
, 1; t least partial use of seasonally available capacity 13 v/nich would otherwise stand idle.
14 Q What conclusions have you reached from this analysis?
15 A M st of the conditions or circumstances discussed in 16 Paragraphs (1) through (5) above would tend to 17 indicate that a ratchet provision is not necessary to 18 recover CVPS's fixed costs and probably not even 19 desirable in the Resale Service Rate "R"' Schedule.
20 Taken together, they definitely show that a 90% demand 21 ratchet provision is much too stringent and is out of 22 place in this filing as a dev2cc to recover fixed costs.
1013 O!6
e Since the 90% demand ratchet is not necessary to
( l 2 recover CVPS's fixed costs, it would appear that it 3 has been included in the rate schedule as a devict 4 to levelize revenues from the demand component a"
5 the rate schedule over the summer and winter se sons.
6 Q IIave you analyzed CVPS 's 90% demand ratchet to determine 7 whether it is appropriate in this instance as a device 8 to levelize revenues?
9 A Yes. In some instances on a utility system, there is 10 consistent similarity in the seasonal load patterns of the customers in a given class. In this case, if all
'll uch customers have the same seasonal load patterns,
( 12 13 no customer is advantaged or disadvantaged with respect to the others in the class by the application of a 14 15 ratchet or the non-application of a ratchet. In such 16 cases, then, a ratchet may be used as an incentive to 17 improve load factor, or it may be applied in order to 18 levelize annual revenue. In this instance there is no 19 evidence that the primary purpose of CVPS 's ratchet is as 20 an incentive to improve load factor. As I indicated 21 above, the purpose of the 90% ratchet provision in the
-22 proposed resale Service Rate "R" Schedule appears to d[I, b$b
1013 017
1 be to 2av31ize revenues. TIowever, an analysis of 2 the seasonal load patterns of purchases by different 3 wholesale for resale customers to be served under 4 Rate "R" Schedule shows that the summer to winter 5 peak comparisons among these customers varies quite 6 widely, which will cause certain of them to be 7 unfairly disadvantaged by the application of a 8 ratcher for revenue levelizing purposes.
9 Q What is the effect of CVPS 's 90% demand ratchet as 10 applied beginning June 28, 1972, based upon demands 1
11 occurring during the winter 1971-1972?
.v 12 A Since the demand ratchet is not in this case a device 13 to recover actual fixed ' costs, but is instead a device 14 to levelize revenues, the effect is to spread a portion 15 f revenue related to CVPS's winter 1971-1972 sales over 16 to the summer 1972 period but at increased rates. In 17 other words, Vermont Electric Cooperative is paying 18 again, at increased rates, for services it received 19 from CVPS and paid for at then existing rates during 20 the 1971-1972 winter period.
21 O fir. Springs, I hand you Exhibit (DAS-2) consisting 22 of six pages, and entitled " Vermont Electric Cooperative,
_ 1, _
1013 018
1 Inc. Computation of Demand Charge Difference for 2 1972 Appl.ying Former Contract Ratchet Provisions, 3 versr.s 90% Ratchet, both Af ter June 28, 1972."
4 was this Exhibit prepared under your direct supervision?
5 A Yes, it was.
6 Q Would you describe the Exhibit, please.
7 A This Exhibit was prepared at the request of the 8 Cooperative, to show the very severe effect of the 9 application of a 90% demand ratchet during the year 10 1972; if made effective along with Resale Service Rate
'll "R" Schedule on June 28, 1972; and is based on previous
(
12 'heakdemandsregisteredinthewintermonthsprior to 13 the effective date of Ph'e new rate schedu._e. The 14 computations are presented in tabular form and are 15 based on actual billing data for the early part of 16 the year and estimated billing data through December, 17 1972. The computations are sin.ilar in overy way 18 except for the ratchet provisions assumed. In both 19 computations, the rates and charges of tlie proposed 20 Resale Service Rate "R" Schedule are assumed to be 21 in effect for the months of Ju.ly through December; 22 but in one case the demand billing computations are LlL' 013 019 1 based upon the 90% demand ratchet of Resale Service 2 Rate "R" Schedule, and in the othcr case, the demand 3 b_11ing computations are based on ratchet provisions 4 cxisting in previously applicable schedules. Page i 5 of the Exhibit is a summary page showing a comparison 6 of the computation b'ased on 90% demand ratchet shown 7 in Column (c) and the computation based upon the 8 former demand ratchet provisions shown in Column (d) 9 with the difference in resulting billing demands 10 shown on Line 1 under Column (e) and the dollar 11 difference shown on Line 2 in Column (e). Pages 2 12 and 3 show the dollar computations and the billing 13 demand determinations,respectively,for the 90% ratchet 14 assumption. Pages 4 and 5 show the dollar computation 15 and the billing demand determination, respectively, 16 utilizing the former contract demand ratchet provisions.
17 The total amount of the increase is $64,844.
18 O Could the retroactive application of this ratchet 19 have any other adverse effect on Vermont Electric _
20 Cooperative?
21 A Yes, definitely so. Assume that the Vermont Yankee 22 Nuclear plant goco into commercial operation on 1013 090 .
1 october 15, 1972 as contemplated by NEPEX as of 2 May 1, 1972. Vermont Electric Cooperative is 3 committed to purchase its 5,583 KN of Vermont Yankee 4 power from and af ter that date. When the Cooperative 5 starts taking its committed amount of power from 6 Vermont Yankee, this will reduce its required 7 capacity demand from CVES by the 5,583 131. Therefore, 8 it will be paying CVPS for the original amount of 9 unused ratcheted demand plus this additional 5,583 KN 10 demand v!hich is now excess to their needs. This is a 11 doubling up of cost on Vermont olectric Cooperative 12 which is unreasonable and uncalled for. CVPS, in
(
13 addition to collecting these sums from the Cooperative, 14 can now, through their access via VELCO and NEPEX, sell 15 this capacity to other utilities in New England. In 16 effect, CVPS is charging its customers for capacity 17 the customer can't use, and then selling this capacity 18 to others; thus collecting twice for the same item.
19 Incidentally, if commercial operation of Vermont 20 Yanhoe is further delayed until early 1973 and after 21 the Cooperative has established its new winter peak, 22 the above described circumstances will exist throughout
- r .
U (> l
- s. ,fi 1013 021
.- i' 1 the remainder of 1973.
(
2 The 90% ratchet is very punitive in this case 3 and is out of place.
4 5
6 7
8 9
1C 11 c 12 13 14 .
15 16 17 18 19 20 21 22 1013 022