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Climate Challenge Participation Letter

DOE's Energy Partnerships for a Strong Economy

CLIMATE CHALLENGE PARTICIPATION ACCORD

This Participation Accord describes the commitments that Centerior Energy Corporation (Centerior) and the U.S. Department of Energy (DOE) have made to participate in the Climate Challenge Program in pursuit of the President's goals for reducing greenhouse gas emissions. The Climate Challenge Program is a joint, voluntary effort of DOE and the electric utility industry to reduce, avoid or sequester greenhouse gas emissions. The framework of the Climate Challenge Program was established in the Climate Challenge Program Memorandum of Understanding and Exhibits thereto dated April 20, 1994 (the Climate Challenge Program MOU) (see Attachment A to this Participation Accord).

Centerior is the parent corporation of its two operating companies, The Cleveland Electric Illuminating Company (CEI) and The Toledo Edison Company (TE). CEI and TE serve over 2.6 million people across 4,200 sq. miles of territory in northern Ohio. The system is comprised of 5925 megawatts of generating capacity, of which 61 percent is coal fired, 31 percent is nuclear and the remaining 8 percent is from other generation sources.

Centerior through its operating companies has made major commitments to environmental protection including the construction of the Davis-Besse Nuclear Power Station and the Perry Nuclear Power Plant. In addition, Centerior is a partial owner of Beaver Valley Nuclear Power Plant and Bruce Mansfield units #1,2, & 3 which installed a state of the art SO2 scrubber system in the mid-l970s.

I. Centerior Commitments

    A.
      Consistent with Paragraph II.B. 1 .a. and f. of the Climate Challenge Program MOU, Centerior has undertaken and plans to complete the following specific projects or actions, to reduce greenhouse gas emissions and contribute to at least one industry initiative:

      1997

      Bay Shore Unit #1 Controls
      Ashtabula Unit #9 Generator Tubes
      1998
      Eastlake Unit #5 Air Heater Baskets
      Avon Lake Unit #9 Burner Management
      Eastlake Units #1 & #2 Controls
      Ashtabula Unit #10, #11 Generator Tubes
      1999
      Eastlake Unit #5 1st & 8th Stage Blades
      Bay Shore Unit #3 Controls
      Eastlake Unit #4 Replace HP Rotor
      Eastlake Unit #4 L-0 Blades
      Ashtabula Unit #8 Generator Tubes
      2000
      Bay Shore Unit #4 Turbine Blades
      Ashtabula Unit #5 Boiler Controls
      Ashtabula Unit #5 L-0 Blades
      Bay Shore Unit #4 Controls
      It is estimated that about 50,000 tons of coal per year will not be burned due to the projects that have been completed and those anticipated to be completed from 1995 to 2000. Centerior's fossil plant efficiency projects are expected to reduce CO2 emissions by approximately 128,000 tons per year, based on estimated CO2 emissions of 205 Ibs. CO2/MMBtu and assuming 12,500 Btu/lb coal. This estimated reduction in CO2 is reflected in Table I.

    Transmission Line Improvements

      1997
      Rachel Transmission Line
      Pawnee Transmission Line
      The installation of substations and associated transmission lines will eliminate line losses at approximately 7.5 megawatts. The elimination of 7.5 megawatts of coal fired generation is estimated to reduce CO2 emitted by 67,342 tons per year using a CO2 factor of 2.05 lb. CO2/kWh. Assuming the projects are completed by the end of 1997, the total CO2 saved by the year 2000 would be about 134,700 as shown in Table I.


    Nuclear Plant Generation efficiency and reliability improvements

      The Perry and Davis-Besse Nuclear Power Plants have conducted numerous projects since 1990 to improve reliability and availability of the units. The following list provides some insight into those projects and a number of future projects scheduled for 1995 and beyond. Additional projects may be added as they receive Board of Directors approval.

    Past Projects

      Davis-Besse Nuclear Power Station

      1991

      Replace PCB transformers
      Main Generator Sequential Tripping
      Isophase Bus Gas Analyzer
      Replace EDG Air Compressor
      Add Position Indication LIC 420-1
      Modify PCV-1910 for no crystallization
      Replace Drain Pumps P167-1, P167-2
      Replace Turbine Bypass Valves
      Install testing of 4160 Volt Busses Cl, Dl
      Install level switch for EA Cond. Pump
      Backup Protection Electrical Penetration Assembly

      1992

      Integrated Chemistry Sampling
      Air Dryer Modification
      Modify CVE Relay & Associated Circuits
      Inverter Low Voltage Dropout Setting

      1993

      Modify MSR High Level Trip
      ARC Suppr Across Induc Loads
      Upgrade MWE input to ICS
      Modify tripping functions of relays
      Enhance Feed & Bleed Phase II
      Replace Main Gen Core Monitoring System
      Add isolation valves MU59A, B, C, D
      Main Feedwater Nozzle Spray Replacement
      Removal of snubbers
      CRD Group Power Supply Replacement
      INCR Tap Range 4.16KV Ground Relays
      Gamma-Metrics Upgrade
      Modify Low Pressure Turbine B-Rotor

      1994

      Install Auto Transfer switch modcomp comp
      Modify ICS Circ Initiating RF
      Replace RC10
      7 RFO Fuel Modification
      Once Thru Steam Generator Tube Sleeving & Plugging
      Provide Breaker on Generator Lockout
      Replace Low Pressure Steam Turbine Rotors
      MU 6406,6407 Replacement
      Smart Auto Signal Selector Output
      Cooling Tower Efficiency Improvements

      Perry Nuclear Power Plant

      1991

      Change existing RWCU seal pump seal

      1992

      Reduce extensive temperatures caused by poor coolant flow
      Replace upper drywell cables
      Provide clean seal water for Amertap pump
      Add additional insulation to main steam lines
      Repair weld crack with tube insert
      Provide separate feed to main turbine, RF Pump turbine & Motor drive on feed pump control logic Provide reinforcement of the 36" circ water in the auxiliary
      condenser return line

      1993

      Implement Stress Improvement Process for nozzle to safe-end welds for various plant systems
      Replace electrical trip solenoid valve with improved reliability single coil design
      Provide new monitoring points in the recirc pumps speed control temperatures interlock
      Turbine generator power relay, etc. revisions

      1994

      New Air System, Preoperational Test Phase
      Modify MSIV's to improve LLRT performance
      Repair connection of vent for RMV Valves
      Correct defects in the P4l FRP Pipe; Service Water Return Piping
      Replace 5 thermocouples in upper drywell with more advanced more heat resistant thermocouples
      Upgrade jet pump beam-bolt assemblies
      Upgrade FRP piping to transport P41 water from the TBCCW return header

    Future Projects

      Davis-Besse Nuclear Power Station

      1995

      RFO Fuel Repairs/Modification

      1996

      Dry Fuel Storage
      Digital Fault Recorder
      RMVL of the Hard Stops - CTMT Purge

      1997

      No Outage Scheduled

      1998

      No Projects Identified

      1999 Replace EDG Air Valves (AS FAIL)
      Repair Cond Pit Hydramotors
      Replace Valve Actuators

      Perry Nuclear Power Plant

      1995+

      Replace existing 24" downcomer piping
      Fiberglass piping evaluation/repair/replacement

      1995+

      RF05 Inspection and Repairs to water and circulating water system

    Nuclear Generation Equivalent CO2 Reduction

    The projects listed above that have been completed or are anticipated to be completed by the year 2000 are conservatively expected to result in an average kilowatt-hours (kWh) generation from the nuclear power plants of

    3,796,920,000 kWh for Perry NPP
    6,136,020,000 kWh for Davis-Besse NPS
    The kWh listed reflect only Centerior's ownership share of the referenced units. The average baseline kWh for the 1987 to 1990 time period is
    2,757,381,750 kWh for Perry NPP
    4,440,854,250 kWh for Davis-Besse NPS

      Based on the above figures the kWh generation increase at the two nuclear power stations is conservatively estimated at 2,734,700,000 kWh per year. The primary alternate generation for Centerior is coal fired. Coal fired emissions are about 2.05 lbs CO2/kWh. The total reduction of CO2 from nuclear generation is estimated at 2,800,000 tons per year from 1995 through 1999 based on a 2.05 lb. CO2/kWh emission factor from coal fired generation.

      Demand Side Management

      1991  -     $ 468,977                 kWh Reduction       7,049,180
      
      
      
      1992  -     $1,847,464                kWh Reduction      11,129,536
      
      
      
      1993  -     $4,648,776                kWh Reduction      26,128,489
      
      
      
      1994  -     $2,629,589                kWh Reduction      19,024,982
      
      (first six months only)
      

      It is unlikely that DSM programs will be continued at the same level of funding that has occurred in the past. Centerior will implement DSM programs in the future consistent with its Integrated Resource planning process which is regulated by the Public Utilities Commission of Ohio. CO2 emissions were reduced by nearly 65,000 tons based on the kWh reduction noted above and a CO2 reduction factor of 2.05 lbs/kWh.

      Land Management Programs

      1993  -     Planted 836 trees at Westwood                $29,000
      
                  MTRP Grant Program                           $15,000
      
      
      
      1994  -     Planted 30 trees at Miles Service Center     $ 4,000
      
                  Planted 172 trees and 1276 shrubs at PNPP    $85,000
      
      
      

      Centerior will consider additional tree planting programs in the future based on present and future economic constraints. Tree planting to date has not been of sufficient quantity or age to generate a significant CO2 benefit yet.


      Miscellaneous

      Ash utilization in cement production and cement replacement

      1991 - 60,000 tons of ash utilized

      1992 - 70,000 tons of ash utilized

      1993 - 80,000 tons of ash utilized

      1994 - 90,000 tons of ash utilized

      l995 and beyond -

      Future projections on ash use in cement production and cement replacement are dependent on total cement use in the Northern Ohio area. Cement use is heavily tied to economic conditions and the level of construction. Centerior will continue its efforts to seek additional growth in the use of flyash as a cement replacement and in cement production. We would expect usage levels to be at or above historic levels of 60,000 to 90,000 tons or more barring a substantial downturn in the economy. Based on published offset values of 1 ton of CO2 for each ton of cement, the total CO2 saved since 1991 and projected to the year 2000 would approach a total of 700,000 tons of CO2 over this time period.

      CFC replacements

      1994 - 2200 lbs. R-11 changed to tri-chloroethylene at Perry Nuclear Power Plant

      1994 - 1500 lbs. R-12 changed to R-22 at Davis-Besse Nuclear Power Station

      1997-8 - 145 lbs. (290 ibs. total) R-12 to be changed to R-22 or other approved refrigerant in two Control Room Air conditioners at Davis-Besse Nuclear Power Station.

      The above CFC replacements are equivalent to a reduction of approximately 5,800 tons of CO2, based on a 2,900 to 1 CO2 factor for the change from R-11 and R-12 to R-22.


      Industry Initiatives

      Geothermal Industry Initiative -

      Centerior will participate and provide the required funding of $50,000 per year over the 5 year period of the program.

      Although each project has been carefully considered and best efforts have been made to estimate the effects on greenhouse gas emissions, conditions could change that would result in new projects being added or existing projects being deleted or modified based on economic, market or regulatory considerations. This could alter estimates and listed projects.

    B.
      Centerior will report annually on activities and achievements under the Climate Challenge Program. Results achieved during each year shall be reported in a clear and understandable manner that is consistent with the guidelines adopted pursuant to Subsection 1605(b) Energy Policy Act and the Climate Challenge accounting protocols in Exhibit B of the Climate Challenge Program MOU. The first such report may include a description of the activities and achievements of Centerior prior to its becoming a participant in the Program, expressed on an annual basis to the extent possible.

    C.
      Centerior will confer with DOE on or before July 1, 1997 to evaluate jointly the progress of Centerior in achieving its Climate Challenge Program goals and to discuss possible adjustments to its voluntary commitments.

    D.
      The Climate Challenge Program representative for Centerior will be:

      Elizabeth J. Shaw
      Centerior Energy Corporation
      6200 Oak Tree Blvd
      Independence, OH 44131

      Centerior agrees to notify DOE prior to or, in any event, no later than 30 days after any change in its representative.

II. DOE Commitments

    A.
      DOE's commitments to Centerior are those set out in Section III of the Climate Challenge Program MOU, which are hereby incorporated in this Participation Accord by reference.


    B.
      DOE will consider Centerior requests to intervene in regulatory proceedings of Federal, State and local commissions and boards on issues pertinent to the Climate Challenge Program. Before DOE intervenes in regulatory and other proceedings pertaining to Centerior for purposes of addressing Climate Challenge Program issues, it will provide notice to Centerior.

    C.

      DOE will provide an annual report to Centerior describing the actions that it has taken to fulfill its commitments under Section III and Exhibit C of the Climate Challenge Program MOU, and the results of those actions.

    D.

      The Climate Challenge Program representative for DOE, who will serve as liaison to Centerior, will be

      Larry Mansueti
      Director, Climate Challenge Program
      Office of Utility Technologies (EE-10)
      U. S. Department of the Energy
      1000 Independence Ave., S. W.
      Washington, D. C. 20585
      (202) 586-2588

      DOE agrees to notify Centerior prior to or, in any event, no later than 30 days after any change in liaison responsibilities or personnel.

III. General Provisions

    A.
      Use of DOE-developed materials by Centerior will be governed by the provisions of Section IV of the Climate Challenge Program MOU, which are hereby incorporated in this Participation Accord by reference.

    B.

      In addition to the foregoing provisions, DOE and Centerior agree to act in accordance with the principles set out in Section I of the Climate Challenge Program MOU and the general provisions set out in Subsections V.A-V.D, V.F and V.G of the Climate Challenge Program MOU, which are hereby incorporated by reference.

    C.

      Either party may withdraw from this Participation Accord or any of its activities under the Climate Challenge Program without penalty and without being subject to remedies at law or equity.




_________________________
President/CEO or designee
Centerior Energy Corporation

-------------------------[date]



-------------------------
Secretary of Energy or designee
U.S. Department of Energy
July 7, 1995 [date]

Attachment:


    Attachment A - Climate Challenge Program MOU and Exhibits

m: CAA\GHG\climacrd.wpd





Please send comments to:
Lawrence.Mansueti@hq.doe.gov