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)

Text

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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.

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 8 0 02140 h3

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

-s 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 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.

(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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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 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 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.

6kv $(dfdW v ptaryPublic My commission expires: /8- I/ O b ll l

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