ML19329C391
| ML19329C391 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Perry  |
| Issue date: | 03/31/1975 |
| From: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8002130761 | |
| Download: ML19329C391 (19) | |
Text
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KITED FIATES OF AMERICA NUCLEAR REGULATORY CODMISSION a9 D-BEFORE THE ATOMIC SAFFffT AND LIcusimi BOARD In the Matter of
)
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THE TOLEDO EDISON COMPANY, and
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THE CLEVELAND ELECTRIC ILLUMINATING )
AEC Docket No. 50-346A COMPANY
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(Davis-Besse Nuclear Power Station)
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THE CLEVELAND ELECTRIC ILLUMINATDG )
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AEC Dockets Nos. 50 hh0A (Perry Nuclear Power Plant, Units 1 )
50 441A and 2)
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ANSWER OF THE CLEVELAND ELECTRIC ILLUMINATING CCMPANY TO THE SUPPLDE3TAL INTERROGATORIES OF THE DEPARTMENT OF JUSTICE Pursuant to Rule 2.740 of the Commission's Restructured Rules of Practice, The Cleveland Electric Illuminating Company ("Ccepany") submits the following responses to Supplemental Interrogatories 1 through 6 as pro-pounded by the Department of Justice.
31pplemental Interroaatory 1:
Since September 1,1965, has Company ever directly or indirectly transmitted electric power and/or energy (whether originating inside or outside Comparct's system) from its transmission system to the transmission system of any elec-tric utility (whether directly interconnected with Company or not) engaged in the utilization, sale or further transmission of that pcwer and/or energy?
If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amount of energy and/or power in WH involved annually, (d) the reason (s) for the transmission (s), (e) the date of and sig-natories to any agreement relating to each such situation, (f) the rate (s) at which the Company billed the other electric utility (s) for each transaction, and (g) the method and factors used to determine the rate (s) listed in response to part (f) above.
Fesponse:
The answer to Supplemental Interrogatory 1 is "yes".
(a) Since September 1,1965, the Company has transmitted electric power and/or energy from its transmission system to the transmission systems of the following utilities named in the following contracts:
(i) Ohio Power Company, contract dated June 14,1962 (Exhibit A);
(ii) Ohio Edison Cempany, contract dated July 29,1964 (Exhibit 3);
(iii) Ohio Edison Company, contract dated February 23,1965 (Exhibit C);
(iv)
Pennsylvania Electric Company, contract dated July 23, 1965 (Exhibit 0);
02 130 g
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and, since approximately the date of the contract, the Comparrf has transmitted electric power and/or energy from its transmission sys-tem to the transmission systems of the following utilities named in the following contracts:
(v) PJM Group (Public Service Electric and Gas Company, Philadel-phia Electric Company, Pennsylvania Power and Light Company, Baltimore Gas and Electric Company, Potomac Electric Pcwer Company, Pennsylvania Electric Company, Metropolitan Edison Company, New Jersey Power & Light Company, and Jersey Central Power and Light Company), contract dated September 30, 1965 (Exhibit E);
(vi) City of Cleveland, Ohio, contract dated January 20, 1970 and amendments dated March 17,1970, June 9,1970, and July 22, 1970) and FPC Order of May 30, 1972 in Docket E-7631, and FPC Order tocket E-9255 issued February 28, 1975, for lead transfer service (Exhibit F)
(see also Exhibit I);
(vii) Ohio Edison Company, The Toledo Edison Commy, ruquesne Light Ccmpany, and Pennsylvania Power Company, contract entitled "CAPCO Transmission Facilities Agreement", dated as of September 14, 1967, effective September 30, 1971 (Exhibits G, J, K, L);
(viii) Pennsylvania Electric Company, contract dated October 21, 1966 (Exhibit H); and (ix) City of Cleveland, Ohio, FPC Order No. 6hh, dated January 11, 1973, for 69 kV service (Exhibit I)
(see also Exhibit F);
and under cervice schedules attached to said contracts or supplements or amendments to said centracts. The Ccmpany has no actual knowledge as to whether power or energy so transmitted to transmission systems other than as set forth above was in turn resold to another transmis-sion system.
(b) The time periods involved in the transmission of pcwer and/cr energy to the parties, set forth in answer to paragraph (a) above, are set forth in contracts, amendments and supplements thereto, copies of which have been examined and identified by the Department of Justice, and have been transferred to Washington, D.C. for placement in the central depository in this proceeding. Copies are attached hereto as Exhibits A through L, including copies of relevant FPC Orders, and also are on file with the Federal Power Consnission. Of said con-tracts as set forth above, the following has expired or terminated as of the date indicated:
(i) Pennsylvania Electric company, contract dated July 23, 1965; terminated January 1,1967 (Exhibit D). I
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(c)* Year 1065 (12 months)
Ohio Edison Company, and 535,5h9 megawatt-hours total --
Ohio Power Company no breakdown between Companies available Year 1966 Pennsylvania Electr e) Company (l) 822,035 megawatt-hours 2
1,813 megawatt-hours Chio Edison Company Ohio Power Company 7,854 megawatt-hours PJM Group 20,833 megawatt-hours (1) Exhibit D (2) Exhibit B Year 1967 Chio Edison Company (l) h99 megawatt-hours Chio Power Company 3,151 megawatt-hours PJM Group 199,800 megawatt-hours (1) Exhibit B Year 1968 Chio Edison company (l) 5,h88 megawatt-hours Ohio Power Company 18,457 megawatt-hours PJM Group 134,841 megawatt-hours (1) Exhibit B Year 1060 Chio Edison Company (l) 7,307 megawatt-hours Chio Power company 109,293 megawatt-hours PJM Group 353,756 megawatt-hours Pennsylvania Electric Company (2) 52,264 megawatt-hours (1) Exhibit B (2) Exhibit H (pumpir4 power for Seneca Plant)
- Source: Annual Reports of Company to Federal IN:wer Comission (Form 1),
for applicable years.
Year 1970 City of Cleveland (l) 1,438 megawatt-hours Chio Edison Company (2) 135,620 megawatt-hours Chio Power Company 61,811 megawatt-hours PJM Group 72,956 megawatt-hours Pennsylvania Electric Company (3) 212,834 megawatt-hours (1) Exhibit F (2) Exhibit 3 (3) Exhibit H (pumping power for Seneca Plant)
Year 1971 city of Cleveland (1 127,733 megawatt-hours Ohio Edison Company (2) 33,98h megawatt-hours Ohio Edison Company 3) h65,865 megawatt-hours Ohio Power Company 68,567 megawatt-hours 350,153 megawatt-hours PJM Group Pennsylvania Electric Company (b) 627,600 megawatt-hours (1) Exhibit F (2) Exhibit B (3) Exhibit C (h) Exhibit H (pumpin6 power for Seneca Plant)
Year 1972 City of Cleveland (1) 138,082 megawatt-hours (2) 162,753 megawatt-hours Toledo Edison Comp Ohio Edison Company 147,115 megawatt-hours Ohio Edison Company 245,230 megawatt-hours Chio Power Company 77,608 megawatt-hours PJM Group 586,453 megavatt-hours Pennsylvani.t Electric Company (5) 557,677 megawatt-hours (1) Exhibit F (2) Exhibit G and Exhibit J
- 3) Exhibit a (k)
(
Exhibit C (5) Exhibit H (pumping power for Seneca Plant) l l
l
.4-
Year 1973 City of Cleveland (1) 81,368 megawatt-hours Duquesne Light Compa 177 megawatt-hours Toledo Edison Ccmp 2) 604,836 megawatt-hours 16,761 megawatt-hours Chio Edison Compsny(3)
Chio Edison Company 155,397 megawatt-hours Ohio Power Company 43,779 megawatt-hours PJM Group 306,492 megawatt-hours Pennsylvania Electric Ccmpany(4) 806,251 megawatt-hours (1) Exhibit ?
(2) Exhibit G and Exhibit J (3) Exhibit B and Exhibit C (4) Exhibit H (pumpin6 power for Seneca Plant)
(5) Exhibit G and Exhibit K Year 1974*
Ohio Edisen Company 1 238,066 megawatt-hours Ohio Edison Company (2 182,705 megawatt-hours Ohio Edison Company 7) 257,375 megawatt -heurs Ohio Power Company 22,92k megawatt-hours Duquesne Light C y(6) 25,678 megawatt-hours 161,616 megawatt-hours City of Cleveland /
PJM Group 8,669 megawatt-hours Toledo Edison Company (3) 523,469 megawatt -hours Pennsylvania Electric Company (5) 732,960 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Exhibit G and Exhibit J (k) Exhibit F and Exhibit I (5) Exhibit H (pumpin6 power for Seneca Plant)
(6) Exhibit G and Exhibit L (7) Exhibit G and Exhibit K
- (Best available figures, but not audited as of date of this answer.)
In further response to paragraph (c) of Supplemental Interrogatory 1, the Company has transmitted power and/or energy which originates inside the Company's system at the Company's Eastlake Plant in Eastlake, Ohio, to Duquesne Light Company, which owns a 31.21, tenant-in-commen interest in the Eastlake No. 5 cenerating Unit, with a nameplate rating of 680 m, located at said Plant. Eastlake Unit No. 5 went in commercial operation in October 1972. Electric power and/or energy from Duquesne Light's ownership share of the Unit is transmitted to Duquesne under the CAPCO Transmission Facilities Agreement (Exhibit E). Megawatt-hours so trans-mitted are not included in the data set forth above.
(d) The reason (s) for the transmission (s) as set forth above are set forth in the contract terms and/or service schedules between the Company and the recipient of the power and/or energy. The reasons for transmission to the named Company under the following contracts may consist of any one or more of the following:
(i) Ohio Power Company (Exhibit A page references): Emergency Service (p. 9-10); Coordination of Scheduled Maintenance of Generating Facilities (p.11-12); Energy Transfer (p.13-1h);
Interchange Power (Econo w Energy and Non-Displacement Energy)
(p. 15-16); Short Term Power (p. 17-18, 28-30, 33-34, 51-53);
Interim Power (p. 22-2h); Limited Term Power (p. 41 h2, 51-53).
(ii) Chio Edison Company (Exhibit 3 page references): On-Peak Interchange Power (p. 9); Off-Peak Interchange Power (p. 9);
Firm Power (p.10); Economy Interchange Power (p. 3); Short Term Power (p. 20-22).
(iii) Ohio Edison Company (Exhibit C, p. 25): Power supplied during outage of OE Sammis No. 6 Unit while Coc:pany's Avon No. 9 Unit is operating, under entual back-up agreement.
(iv) PJM Group (Exhibit E page references): Economy Power (p. 19);
Emergency Power (p.19); Inadvertent Interchange (p. 20); Short Term Power and Energy (p. 36-39).
(v) Pennsylvania Electric Company (Exhibit D): Firm Power.
(vi) City of Cleveland, Ohio (Exhibit F): Load Transfer Service to meet emergency on City's system (p. 6,11,16,32).
(vii) CAKO Companies (Exhibit E, p.13) utilizatien by CAKO Com-panies of capacity entitlements and obligations in generating units installed or acquired by CAPCO Companies to provide for equalization of generation reserves under CAKO generating capacity allocation procedures; Exhibit K, Unit Purchase Power.
(p. 5 4); Exhibit J, Unit Purchase Power (p. 5-6); Exhibit L, Unit Purchase Power (p. 5-6).
(viii) Pennsylvania Electric Company (Exhibit H, p.10-11): delivery of 80% pumping power and energy required for Seneca pumped power project of which Company is 80% owner.
(ix) City of Cleveland, Ohio (Exhibit I): 69 kv service to meet emergency on City's system, on a temporary basis pending com-l pletion of 138 kV interconnection.
(e) The dates of and signatories to the above agreements are set forth in l
the agreemer:ts themselves:
l l
1.
Exhibit A:
- p. 1, 8, 20, 21, 28, 30, 33, 34, 38, 40, 51, 53 Exhibit B:
- p. 1, 17, 20, 22.
Exhibit C:
- p. 12, 30, 33, 34 Exhibit D:
- p. 7, 11, 12.
Exhibit E:
- p. 4, 12, 13, 36, 38, 39 Exhibit F:
- p. 6, 10, 12, 14, 15, 24, 25, 26, 29, 30, 33 Exhibit G:
- p. 12, 51, 52.
Exhibit H:
- p. 4, 13 Exhibit I:
- p. 3, 12, 13, 15 Exhibit J:
- p. 4, 10.
Exhibit K:
- p. 4, 8.
Exhibit L: p.4,9 (f) The rate (s) at which the Company billed the other electric utility (s) for each transaction :nade pursuant to the agreements (or Order) identi-fied in paragraph (a) above are set forth in the agreements (or Order) themselves:
Exhibit A:
- p. 10, 12, 14, 15, 16, 17, 18, 23, 24, 28, 29, 33, 39, 41, 42, 52.
Exhibit B:
- p. 10, 11, 12, 21, 22.
Exhibit C:
- p. 25.
Exhibit D:
- p. 8.
Exhibit E:
- p. 17, 18, 19, 20, 37 Exhibit F:
- p. 7, 8, 13, 14, 22, 24, 28, 33, 35, 38.
Exhibit G: The obligations of the parties to this agreement to designate certain lines as "CAPC0" lines (p.18 and 19), and to construct additional lines (p.19-21 and 24-26), together with obligations to assu:ne invest-
- nent responsibility in said lines by ownership (p. 30) or payment of fixed charges and operating expense (p.
17, 23-24, 64-66) constitute the rate for transactions under this agreement.
Exhibit H:
- p. 8.
Exhibit I:
- p. 8-9 Exhibit J:
- p. 7-9 l
Exhibit K:
- p. 6-7, 8.
l Exhibit L:
- p. 7-8.
(g) The method and factors used to determine the rate (s) listed in response to paragraph (f) above in all cases were arrived at through arms-length negotiation between the Company and the party or parties with which the Company has entered into the agreement, except that the rates set forth in Exhibit I for service to the City of Cleveland were determined by Order of the Federal Power Consnissien, and, beginning May 30, 1972, the rates set forth in Exhibit ? were determined by Order of the Federal Power Cons:tission. The method and factors used to determine the rate (s) listed in response to paragraph (f) above are also set forth on the fol-lowing pages of the applicable Exhibits:
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Exhibit A:
- p. 25-26, 36-36, 43 49 Exhibit 3:
- p. 18-19 Exhibit C:
- p. 1-9, 31-32, 35-38.
Exhibit D: p. 1-3 Exhibit E:
- p. 1-2, 34-35 Exhibit F:
- p. 2-5,16-20, 28-29, 30-32, 34-53 Exhibit G:
p.1-2, 6-8, 67-73 Exhibit H: p. 1-3, 15-16.
Exhibit I:
- p. 6-9, 22-27.
Exhibit J:
- p. 1-3, 11-15 Exhibit K:
- p. 1-3, 9-15.
Exhibit L:
- p. 1-3, 11-17.
In responding to this Supplemental Interrogatory 1, the Company's Answer is made on the basis of delivery and receipt of power and/or energy as scheduled, it being recognized that in interconnected system operation it is physically impossible to determine the source of any power delivered to any point of utilization. Energy transmitted by the Company is not allocated in particulte amounts to specific delivery points.
Supolemental Interrogatory 2:
Since September 1,1965, has Company ever refused any request, either -lormal or informal, to transmit electric power and/or energy in the manner described above in Interrogatory No.17 If so, describe each such request by (a) the date of the request, (b) the party making the request, (c) the proposed sup-plying and receiving parties, (d) the requested transmission route, (e) the amount of power involved, (f) the time period involved, (g) the reasons for Compa:rf's decision with regard to this request, and (h) the identity by date, author (s) and subject matter of any documents relating thereto.
Response
The answer to Supplemental Interrogatory 2 is "no",
other than as follows:
(a) Date of Request: May 1,1973 (b) Party Making the Request: American Municipal Power-Chio, Inc.
(c) Supplying and Receiving Parties: Power Authority of the State of New York (Supplier); City of Cleveland, Ohio (Receiver).
(d) Requested Transmission Route: Power Authority of the State of New York (over lines of its New York wheeling s6ent) to a point of interconnee-tion with pennsylvania Electric Company, and over Pennsylvania Electric Company lines to a point of interconnection with CEI, and over CEI lines to a point of interconnection with the City of Cleveland, Ohio. i
(e) Amount of Power Involved: Thirty (30) megawatts.
(f) Time Period Involved: Not specified.
(g) Beasons for the company's recision with Regard to Request: CEI com-petes with the Cleveland Municipal Light Plant on a customer-to-customer and street-to-street basis in a sizeable portion of the City of Cleveland. This competitive situation is clearly unique. CEI by law is precluded from access to PASNY low-cost power. As a matter of sound business judgment, CEI determined, based on facts existir4 at the time CEI was called upon to make a decision, that use of its facil-ities to transmit PASNY pcuer to the City of Cleveland would provide City of Cleveland Municipal System with electric energy at a cost which would unfairly increase the ecmpetitive advantage in the City of Cleve-land already enjoyed by the Cleveland municipal system.
(h) Documents Relating to Said Request: Relevant documents have been made available previously to the repartment of Justice and to the NRC ( AEC) in this proceeding. However, for the convenience of the repartment of Justice attorneys, documents relating to the request are attached hereto as Exhibit P.
The Company has many times since September 1,1965 refused to transmit power and/or energy or interpreted or curtailed such transmission, under the agreements set forth in answer to Sup/plemental Ihterrogatory 1, under cir-cumstances where the requested power and or energy would, if transmitted by the Company, result in a shortage of power and/or energy en the Company's system. No records are kept by the Company of such instances.
Supolemental Interrogatory 3:
Since Feptember 1,1965, has Company had electric power and/or energy trsns-mitted to it either directly or indirectly from the transmission system of any other electric utility (whether or net said utility is directly inter-connected with Company)? If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amounts of energy and/or power in MWH involved annually, (d) the reason (s) for the transmis-sion(s), (e) the date of and signatories to any agreements relating to each such situation, and (f) the rate (s) at which Company was billed for each transaction.
Restonse:
The answer to Supplemental Interrogatory 3 is "yes".
(a) Since September 1, 1965, the Company has had electric pcwer and/or energy transmitted to it from the transmission systems of the follow-ing utilities named in the following contracts:
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(i) Chio Power Company, contract dated June ik,1962 (Exhibit A);
(ii) Ohio Edison Company, contract dated July 29,1964 (Exhibit a);
(iii) Chio Edisen Company, contract dated February 23,1965 (Exhibit C);
and, since approximately the date of the contract, the Company has had electric power and/or energy transmitted to it from the transmission systems of the following utilities named in the following contracts:
(iv) PJM croup (the companies comprising the same being named in the Company's answer to Supplemental Interrogatory 1, centract dated September 30,1965 (Exhibit E);
(v) Ohio Edison Company, The Toledo Edisen Company, Duquesne Light Company, and Pennsylvania Power Company, contract entitled, "CAPCO Transmission Facilities Agreement", dated as of Septem-ber 14, 1967, effective September 30,1971 (Exhibits c, M, N);
(vi) Pennsylvania Electric Company, contract dated October 21, 1966 (Exhibit H);
and under service schedules attached to said contracts or supplements or amendments to said centracts. The Company has no actual knowledge as to whether power or energy so transmitted to it from transmission systems other than as set forth above was purchased by such system from another transmission system.
(b) The time periods involved in the transsission of power and/or energy to the Company by the parties set forth in Answer to paragraph (a) above are set forth in the contracts, smendments and supplements thereto, copies of which have been examined and identified by the Department of Justice, and have been transferred to Washington, D.C. for placement in the central depository in this proceeding. Copies of said contracts, supplements and amendments are attached hereto as Exhibits, and said copies are also on file with the Federal Power Commission. All of said contracts are new in effect and have been since their respective effee-tive dates.
- (c) Year 1065 (12 Months)
Ohio Edison Company (1) h20,610 megawatt-hours Ohio Edison Company (1)
)
- and -
)
526,073 (total megawatt-hours, Ohio Power Company
)
no breakdown available)
(1)
Exhibit B bource: Annual Reports of Company to Federal Power Conunission (Form 1) for applicable years.
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Year 1966 355,584 megawatt-hours Chio Power Company (l)
Ohio Edison Company 574,460 :negawatt-hours (1) Exhibit B Year 1967 Ohio Power Company (l) 855,918 megawatt-hours Chio Edison Company 493,223 megawatt-hours PJM Group 5,755 :negawatt-hours (1) Exhibit B Year 1068 1,677,963 megawatt-hours Chio Power Company (1)
Ohio Edison Company 178,020 megawatt-hours PJM Group 5,828 :negawatt-hours (1) Exhibit B Year 1064 1
Chio Edison Compaw 653,13h megawatt-hours Ohio Edison Company 616,396 :negawatt-hours Ohio Power Ccmpany 1,126,882 :negawatt-hours 38,499 megawatt ours PJM Group Fennsylvania Electric Company (3) 35,903 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Output of Geneca Plant Year 1970 1
576,970 megawatt-hours Ohio Edison Company 2 Ohio Edison Company 1,181,711 megawatt-hours RTM Group 301,314 megawatt-hours Ohio Power Company 337,2h2 megawatt-hours Pennsylvania Electric Compaq(3) 159,527 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Output of Seneca Plant Year 1971 Chio Edison Company (1) 165,098 megawatt -hours ChioEdisoncompany(2) 573,699 megawatt-hours Ohio Power Company 135,177 megawatt-hours PJM Group 201,517 megawatt-hours Pennsylvania Electric Company (3) 460,556 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Output of '?eneca Plant Year 1972 Cl) 398,339 megawatt-hours Ohio Edison Company Chio Edison Company (2) 933,833 megawatt-hours Chio Power Company 355,013 megawatt-hours 230,792 megawatt-hours PJM Group Pennsylvania Electric Company (3) 415,437 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Output of Seneca Plant Year 1073 Ohio Edison Company 1,066,936 megawatt-hours
- Chio Power Company 921,241 =egawatt-hours PJM Group 68,955 megawatt-hours PennsylvaniaElectricr(ggpany(2) 595,277 megawatt-hours Nquesne Light Ccmpany /
775 mega'satt-hours (1) Exhibit B and Exhibit C (2) Output of Seneca Plant (3) Exhibit o and Exhibit M
- Includes 52 megawatt-hours purchased pursuant to an agreement among the CAPCO Companies dated May 29, 1969, as amended May 26, 1971, as its share of energy from the Michigan Companies (Exhibit 0).
(The purchase was by Toledo Edison Company; the point of receipt of this energy was at interconnection points between Ohio Edison Company and CEI.) This entitlement-terminated Povember 1, 1973
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Yeer 197h*
Chio Edison Company ((2) 1)
238,066 megawatt-hours Chio Edison Company 182,705 megawatt-hours Ohio Power Company 413,059 megawatt-hours PJM Group 67,601 megawatt-hours
- uquesne Light Company (3 57, lok megawatt-hours Tolede Edison Company N))
1,212 megawatt-hours Pennsylvania Electric Company (5) 536,757 megawatt-hours (1) Exhibit C (2) Exhibit B (3) Whibit E and Exhibit M (4) Exhibit E and Exhibit N (5) Output of Seneca Plant
- (Best available figures, but not audited as of date of this answer.)
(d) The reason (s) for the transmission (s) as set forth above are set forth in the contract terms and/or service schedules between the Commy and the company transmitting the power and/or energy. The reasons for transmission to the Company under the follcwing contracts may consist of any one or more of the following:
(i) Ohio Power Company (Exhibit A page references): Emergency Service (p. 9-10); Coordination of Schedule Maintenance of Generating Facilities (p.11-12); Energy Transfer (p.13-lk);
Interchange Power (Economy Energy and Non-Displace,ent Energy)
(p.15-16); Short Term Power (p. 17-18, 28-30. 33-34, 51-53);
Interim Power (p. 22-24); Limited Term Power (p. 41 h2, 51-53).
(ii) Ohio Edison Company (Exhibit B page references): On-Peak Inter-change Power (p. 9); Off-Peak Interchange Power (p. 9); Firm Power (p. 10); Economy Interchange Power (p. 3); Short Term Power (p. 20-22); Unit Purchase Pcwer (p. 28-32, 41-h6).
(iii) Ohio Edisen Company (Exhibit C page references): Purchase of one-half of output of CE Samis No. 6 Unit until ecmmercial operation of Company's Avon No. 9 Unit (p.15-16); and there-after power received during cutage of Company's kron No. 9 Unit while OE's Sammis No. 6 Unit is operating, under c:utual back-up agreement (p. 25).
(iv) PJM Group (Exhibit E page references): Econenar Pcwer (p.19);
Emergency Power (p.19); Inadvertent Interchange (p. 20);
Short Term Power and Energy (p. 36-39).
(v) CAPCO Companies (Exhibit E, p.13): Utilization by CAPCO Com-panies of capacity entitlements and obligations in generatir4 units installed by CAPCO Companies to provide for equalization of reserves under CAPCO genereting capacity allocation prece-dures; Exhibit M, Surplus Power (p. 5-6); Exhibit N, Surplus Power (p.4-5). j
(vi) Pennsylvania Electric Company (Exhibit H, p.10-11):
Delivery of 80% of output of Seneca pumped power project of which Company is 80% owner.
(vii)
" Michigan Purchase" (Exhibit 0): Firm power purchase.
(e) The dates of and signatories to the above a6reements are set forth in the a6reements themselves:
Exhibit A:
p.1, 8, 20, 21, 28, 30, 33, 3h, 38,14, 51, 53 Exhibit B:
- p. 1, 17, 20, 22, 28, 32, 41, 46.
Exhibit C:
- p. 12, 30, 33, 34 Exhibit E:
- p. k, 12, 13, 36, 38, 39 Exhibit G:
- p. 12, 51, 52.
Exhibit H:
- p. 4, 13 Exhibit M:
- p. 7.
Exhibit N:
- p. 6.
Exhibit 0:
- p. 1, 2, 13 (f) The rate (s) at which the Ccmpany was billed by the other utility (s) for each transaction made pursuant to the agreement identified in paragraph (a) above are set forth in the agreements themselves:
Exhibit A:
- p. 10, 12, 14, 15, 16, 17, 18, 23, 24, 28, 29, 33, 39, 41, 42, 52.
Exhibit B: p. 10, 11, 12, 21, 22, 30-31, 4h-45 Exhibit C:
- p. 17-24, 25 Exhibit E:
- p. 17, 16, 19, 20, 37 Exhibit G: The obligations of the parties to this agreement to designate certain lines as "CAPC0" lines (p.18 and 19), and to construct additional lines (p.19-21 and 24-26), together with obligations to assume investment responsibility in said lines by cwnership (p. 30) or payment of fixed charges and operating expenses (p. 17, 23-24, 64-66) constitute the rate for transactions under the agreement.
Exhibit H:
- p. 8.
Exhibit M:
- p. 6-7.
Exhibit N:
- p. 5-6.
Exhibit 0:
- p. 11-12, 14-15 In respending to this Supplemental Interrogatory 3, the Company's Answer is made on the basis of delivery and receipt of power and/or energy as scheduled, it being recognized that in interconnected system operation it is physically impossible to determine the scurce of any p w r delivered to any point of l
utilization. Energy received by the Ccapany is not allocated in particular amounts to specific delivery points.
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Supplemental Interrogatory 4:
State each request, either formal or informal, since September 1,1965 made by any electric utility to Company for a new or altered interconnection arrangement, giving (a) the name of the entity, (b) the date of the request, (c) the date of any agreement to interconnect, (d) the reasons for any refu-sal to interconnect, and (e) the date and author (s) of any document relating to any such refusal.
Response
The following requests by an electric utility for new or altered interconnec-tion arrangements with CEI were made since Septeser 1,1965, all of which were implemented:
(a) Pequest of the Pennsylvania Electric Company for conversion of the C::I-Pennsylvania Electric Company interconnection frem 230 kV to 345 ky, including the establishment of the Erie-West Substatien. This conver-sion was planned in the facilities' original agreement establishing the interconnection, dated July 23, 1965 The corriersion took place in October,1969 (see CEI ?. ate Schedule FPC No. 5, made available in response to Joint Document Request No. 3).
(b) Fequest of the Ohio Edison Company for the addition of the Ohio Edison 345 kv-138 kV transmission substation (Hanna Substation) on CSI's 345 kV line between the Juniper Substation and CEI's interconnection point with the Ohio Power Company, east of Ohio Power's Canton Central Substation located near East Canton, Ohio. The decision to i=plement this request is documented in the CAPCO Memorandum of Agreement dated Septe=ber lb, 1967, made available in response to Joint Document Request No.15. The Hanna Substation was put into service in April,1972. Facilities' agreements between CEI and each of the other two companies (Ohio Edison and Ohio Power) were appropriately modified to reflect this intercennec-tion change by documents dated March 21, 1972, cade available in response to Joint Document Request No.15 (c) P.equest of the Ohio Edison Company for the addition of a second 138 kV circuit between CEI's Lorain Substation in Aven, Ohio, and Ohio Edison's Johnson Substation in Elyria, Ohio. This addition was origirally planned for the spring of 1970, but due to a delay in acquiring the right-of-way, completion of the new interconnection did not take place until the spring of 1974. The agreement covering the new facility was signed on April 2, 1974, and is made available in response to Joint Document Request No.15 (d) The Fequest of the Pennsylvania Electric Company for the addition of a 3h5 kV-135 kV transformer at the Pennsylvania Electric Company's Erie-West Substation; this addition involved metering rearrangements at the ErieJiest end of the interconnection. The new transformer was discussed initially in April of 1972; CEI's letter concurring with the installation of the transformer is dated November 17, 1973, and is made available in response to Joint Document Request No.15. The transformer was energi::ed on February 27, 1974 i !
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(e) Ohio Edison Company also made requests for two additional intercon-nections between CEI and Ohio Edison. Both requests were made prior to September 1,1965, and the agreements to install the requested facilities were signed prior to said date; however, actual installa-tion occurred subsequent to September 1, 1965; These additional interconnections were the 345 kV Juniper-Star Line (put into service in June,1968), and the 345 kV Aven-Beaver (West Lorain) Line (put into service in May, 1970).
I (f) Requests leading to manbership by the Company in the power pool known as CAPCO have resulted in construction of transmission facilities and rew or altered interconnection arrangements, as set forth in Exhibit G, attached, and in the recently executed CAPCO Basic Operatin6 Agreement, Exhibit Q.
(g) Request of the City of Cleveland, Ohio for participation in the CAPCO pool, made on April 4,1973, followed by a request by the City for participation in the Perry Plant made on April 13, 1973, such requests being canbined and supplemented in a request for participation in the Perry Units, in Beaver Valley Unit No. 2, and in Davis-Besse Unit No.1 and for membership in CAPCO, made on August 3,1973 The Company, although having serious question as to the bona fides of such requests, has not refused such requests, and has offered to meet them (i) by vigorously pursuing negotiations with the City looking to culmination of a 138 kV interconnection with the City as called for by order of the Federal Power Commission (Opinion No. 6h4, dated January 11, 1975, Exhibit I) as further set forth in paragraph (b) below, and (ii) by having offered the City participation in the Perry Units, Beaver Valley Unit No. 2, and Davis-Besse Unit No.1, as well as participation in future units, as early as December 13, 1973 (h) Pequest of the City of Cleveland, Chio in late recember 1969 for eter-gency aid. This request was implemented by agreement between the Com-pany and the City dated January 20,1970 -(Exhibit F) under which the i
Company agreed to serve approximately 26,000 KVA of the City's load from five load transfer points on the Company's system. Service under this temporary agreement has been provided by the Company to the City since February 1970. Negotiations between the Company and the City fer a permanent interconnection between the systems were delayed because of failure of the City to pay for the load transfer service.
A tem-porary 69 kV intercennection between the Co=pany and the City was ordered by the FPC on January 11,1973 (Opinion No. 6hh, Exhibit I);
this Order farther directed construction of a 138 kV interconnection between the systems to be completed by January 11, 1975 The 69 kv temporary interconnection was completed and is in service. The 138 kV permanent intersonnection has not been ecupleted as of the date of this Answer. The proposals, responses and disputes relating to interconnec-tions between the Company and the City of Cleveland, Ohio are set forth as a matter of record in proceedings relating thereto before the Federal Pcwer Commission. See Exhibit I and Exhibit F. 1
s (i)
It is difficult to specify the dates of infor:nal requests by the City of Painesville, Ohio for interconnection with the Company; however, about ten years ago the Company proposed to provide an interconnection with the City which was refused. Since then, negotiations for inter-connection took place infonnally from time to ti:ne. Serious negotia-tions by the parties for interconnection began in 1973, and culminated in an interconnection agreement between the City and the Company dated January 13, 1975 Supolemental Interreaatory 5:
Since September 1,1%5, has Company ever purchased a discernible quantity of electric power and/or energy from another electric utility at one point on its system and, 'sithin about h8 hours, sold a comparable quantity of electric power and/or energy to that same electric utility at another point on the
ompany's system? If so, describe each situation, stating (a) the parties involved, (b) the time period (s) involved, (c) the amount of power and/or energy in MI involved annually, (d) the reason (s) for the transaction (s),
(e) the date of and signatories to any agreements relating to each situation, (f) the rate at which Company billed the other electric utility, (g) the rate at which the other electric utility billed the Company, and (b) the method and factors used to determine the rates listed in response to parts (f) and (g).
Response
The answer to Supplemental Interrogatory 5 is "no".
Surplemental Interrceatory 6:
Since September 1,1%5, has Company ever purchased a discernible quantity of electric pcwer and/or energy from another electric utility at one point on its system and, within about 148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br />, sold a comparable quantity of electric power and/or energy to another electric utility (or utilities) at another point (or points) in Company's system? If so, describe each situa-tion, stating (a) the parties involved, (b) the time period (s) involved, (c) the amount of power and/or energy in Mi involved annually, (d) the reason (s) for the transaction (s), (e) the date of and signatories to any agreements relating to each situation, (f) the rate at which Company billed the other electric utility (or utilities), (g) the rate at which the other electric utility billed the Company, and (h) the method and factors used to determine the rates listed in response to ;1rts (f) and (g).
Response
The answer to Supplemental Interrcgatory 6 is "yes".
(a) Parties (b) Time (c) Annual From 3
Period Mm (d) Reason (s) 1%5 None 1966 Ncne fl) PJM(2) 1967 21,235 Emergency OP OP PJM 1968 39,275 wergency PJM 1969 5,388 wergency OP(3)
OE PJM 1969 2,688 bergency OE PJM 1970 125 bergency OP PJM 19W 5,410 Emergency CE PJM 1971 99,277 Emergency CE OP 1971 900 Emergency PJM OE 1971 23,896 Emergency PJM OP 1971 13,153 Emergency OE OP 1972 935 Emergency PJM OP 1972 1,923 mergency PJM OE 1972 h2,764 bergency OP PJM 1972 1h8,655 Economy PJM OP 1973 1,h05 Emergency PJM OE 1973 1,833 Emergency OP PJM 19 73 220,350 Economy PJM OP 1974 377 Emergency PJM OE 197h 9,200 E=ergency OP OE 1974 200 Emergency (1)Chio Power Company (2)PJM Group (the companies comprising the same being named in the Co=pany's answer to Supplemental Interrogatory No. 1)
(3) Ohio Edison Company (e) The dates of and signatories to the agreements under which the above transactions took place are set forth in the agreements themselves between the Company and Ohio Power Company (Exhibit A, p. 1, 8, 20, 21, 28, 30, 33, 3h, 38, h0, 51 and 53); between the Company and the PJM orcup (Exhibit E, p. h, 12,13, 36, 38 and 39); and between the Ccmpany and Ohio Edison Company (Exhibit B, p. 1,17, 20, 22, 28, 32, h1 and 46).
(f) and (g) The rates at which the Company billed the utility to which power and/or energy was sold as set forth in pa: agraph (a) above, and the rate (s) at which the Ccmpany was billed by the utility from which pcwer and/or energy was purchased as set forth in paragraph (a) above, are set forth in the agreements themselves between the Company and Ohio Power Co=pany (Exhibit A, p. 10, 12, 14, 15, 16, 17, 18, 23, 24, 28, 29, 33, 39, kl, h2 and 52 ) ;
the Company and the PJM Group (Exhibit I, p. 17,18,19, 20 and 37); and the Company and Ohio Edison Company (Exhibit 3, p.10,11,12, 21, 22, 30-31 and hh h5).
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(h) The method and factors used to determine the rate (s) listed in response to paragraphs (f) and (g) above, in all cases were arrived at through. arms-length negotiation between the Company and the party or parties with which the Company has entered into the agreement. The method and factors used to determine the rate (s) listed in response to paragraphs (f) and (g) are also set forth on the following pages of the applicable Exhibits:
Exhibit A:
- p. 25-26, 35-36 and 43 h9 Exhibit E:
p.1-2 and 34-35.
Dthibit B:
- p. 18-19 In responding to this Supplemental Interrogatory 6, the Company's Answer is made on the basin of delivery and receipt of power and/or energy as scheduled, it being recognized that in interconnected system operation it is physically impossible to determine the source of any power delivered to any point of utilisation. hergy transmitted or received by the Company is not allocated in particular amounts to specific delivery points.
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