ML19319C412

Petition of American Municipal Power-OH Inc to Intervene

ML19319C412
Person / Time
Site:	Davis Besse
Issue date:	04/04/1973
From:	Ardery P AMP, INC., BROWN, ARDERY, TODD & DUDLEY
To:	US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19319C410	List: ML19319C409 ML19319C412
References
NUDOCS 8002140793
Download: ML19319C412 (5)

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O UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION IN THE MATTER OF ~

TOLEDO EDISON COMPANY AND CLEVELAND )

ELECTRIC ILLUMINATING COMPANY - ) DOCKi::T No. 50-456- A DAVIS-BESSE NUCLEAR POWER STATION )

PETITION OF AMERICAN MUNICIPAL POWER-OHIO, INC TO INTERVENE.

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The Petitioner, American Municipal Power-Ohio, Inc. (AMP-0),

pursuant to Section 189 of the Atomic Energy Act and Section 2.714 of the Commission Rules of Practice, hereby petitions to intervene in the above-captioned matter and states as follows:

1. Correspondence, notices, orders and other pcpers herein are to be directed to Philip P. Ardery Brown, Todd & Heyburn 1600 Citizens Plaza Louisville, Kentucky 40202 John C. Engle, President AMP-0, Inc.

Municipal Building, 20 High Street Hamilton, Ohio 45012 George B. Crosby Director of Utilities Piqua, Ohio 45350

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William M. Lewis, Jr.

W. M. Lewis & Associates P. O. Box 1383 Portsmouth, Ohio 45662

2. The purpose of AMP-0 is'to plan and provide future bulk power supply to its members who are forty two municipali-ties in the state of Ohio having municipal electric systems.

3. The .. ember systems of AKP-0 have 616 mw of generating

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capacity. They have a non-coincident peak load of approximately 750 mvs. They have no transmission ties between them.

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4. AMP-0 is desirous of obtaining a participating interest in the Davis-Besse Nuclear Power Station, or in the alternative, purchasing a block of power from said station by making a pre-payment on power. The present power requirement of AMP-0 has not yet been exactly determined since its marketi.?g study is not yet complete. Preliminary indications are that AMP-0 would need 50 to 100 megawatts from the Davis-Besse Station.

5. NTP-0 is the power supply representative of its members and has authority to negotiate on their behalf. It seeks in addi-tion to the capacity from the Davis-Besse Station access to the transmission systems of the applicants herein, as well as other transmission systems of investor owned utilities in Ohio for the transmission of said power.

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6. This petition to intervene is being submitted prior to completion of an engineering study of the combined requirements of all AHP-0 member systems which study will be complete not later than July 1, 1973.

7. AMP-0, in order to provide for future power needs of its I

members, to obtain a greater measure of control over the buik power supply of its members, to secure greater systems reliability, to 4

deal with environmental problems and obtain the benefits of scale in electric bulk power supply, needs to obtain the power from the Davis-Besse Station as aforesaid.

For this purpose it petitions intervention and requests permission to present the feasibility of its proposal to be con-sidered by the Commission as a condition to granting the request of the applicants herein.

! WHEREFORE, AMP-0 prays:

(1) That intervention herein be granted.

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(2) That the applicants herein mak' available such information as is necessary for AMP-O to make its proposal in greater detail, and (3) That the Commission order hearing on the anti-trust

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A aspects of the application herein.

i BR0" , TODD & HEYBURN By I 4h n C.tA Philip P. Ardery \

1600 Citizens Plaza Louisville, Kentucky 40202 for American Municipal Power-Ohio, Inc.

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)1 April 4, 1973 f

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o VERIFICATION Philip P. Ardery, being. duly sworn and pursuant to

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Section 2.714 of the Commission Rules of Practice, states that he is duly authorized as special counsel for American Municipal Power-Ohio, Inc. to file this Petition for Intervention, that

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he has read the foregoing and the statements of fact contained therein are true as he verily believes. He further states that this Petition to Intervene is r fi ed for dilatory purposes.

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YO . $ CLN Philit P. A'rdery \

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COMMONWEALTH OF KENTUCKY )

) Sct.

COUNTY OF JEFFERSON )

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Subscribed and sworn to before me by Philip P. Ardery i

this 4th day of April, 1973.

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My commission expires: /8- I/ O b

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