,
A unit ofAmerican Electric Power
Appalachian Power
P 0 Box 19813
Charleston, WV 25327-1986
AppalachianPower c o r n c
EXEC 6EC DIV
September 29,201 0
VIA HAND DELIVERY
Sandra Squire
Executive Secretary
Public Service Commission of West Virginia
201 Brooks St.
P.O. Box 812
Charleston, West Virginia 25323
Re:
v.
P.S.C. Case No. 10-1208-E-C
Dear Mrs. Squire:
Please find enclosed for filing in the above-styled case an original and twelve (12) copies of the DEFENDANT APPALACHIAN POWER'S
.
SET
INTERROGATORIES, DATA
REQUEST
REQUESTS FOR INFORMATION BY THE STAFF
THE PUBLIC SERVICE COMMISSION OF WEST VIRGINIA,
copy was mailed to Complainant Helene Farley on this date, and a copy was hand delivered to PSC staff attorney, Leslie Anderson, on this date.
Thank you for your attention to this matter.
Enclosures cc: Leslie Anderson, Staff Attorney
Donald Walker

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA
CASE NO. 10-1208-E-C
HELENE PARLEY,
Complainant,
V.
APPALACHIAN POWER COMPANY,
Defendant.
DEFENDANT APPALACHIAN POWER’S RESPONSE TO THE SECOND
SET OF INTERROGATORIES, DATA REQUEST OR REQUESTS FOR
INFORMATION BY THE STAFF OF THE PUBLIC SERVICE COMMISSION
OF WEST VIRGINIA
Appalachian Power Company (“APCo” or “the Company”), files the following as
Its response to the Staffs First Request for Information:

STAFF'S SECOND m Q U E S T FOR INFORMATION FROM
Appalachian Power Company
CASE NO. 10-1208-E-C
Helene Parley v. APCo
Request No. 2.1
Please define what is meant by "Zone" and indicate where these zones are located on the one-line map provided in Data Request 1.1. An additional map is not required if a description of the zones can be identified by a quadrant and device number or other means which can be translated to the map provided in Data Request 1.1.
Response No. 2.1
Zone One (1) is between the Stone Branch StatiodHarts Creek Circuit breaker and Viper
Triple-Single Recloser at pole #38820563C00087, but does not include primary voltage taps that are protected by fuses or other reclosers. Zone One also includes the short line section to DV reclosers at pole #38820588A20240 just outside the station.
The Station is shown on the map as:
Zone Two (2) is between the above Viper Recloser pole #87 and 2nd Viper Recloser at pole #38820538B00131, and also does not include protected taps. The Company did not include Zone Two looking back into the Town of Chapmanville as Complaints didn't involve that area.
Zone Three (3) is between Viper at pole #131, three DV reclosers at pole
#38820537C00088, #38820561C000089, #38820561C00145, and 3ph recloser at pole
#3882056 1 C00092, again not including protected taps.
If additional Zone's need identified, it becomes complicated as the circuit expands in many different directions and creates multiple Zone 4's, 5's, etc.
Responder: David Stillwell, Engineer I.
Witness: The Company has not determined who may be a witness.
Date: September 29,2010

STAFF’S SECOND REQUEST FOR INFORMATION FROM
Appalachian Power Company
CASE NO. 10-1208-E-C
Helene Farley
APCo
Request No. 2.2
Please indicate for this circuit, what the Company considers to be acceptable values or ranges of the Reliability Indices provided in Data Request 1.3 (SAIFI, SAIDI, CAIDI). If there are different ranges based on this circuit or any other criteria, please provide that information.
Response No. 2.2
The Company does not have targets at the circuit level and there are no reliability standards set by the WV PSC. In the General Investigation into the power outages that occurred during and after the winter storm on December 18 and 19, 2009, the
Commission initiated General Order 259 to establish a working group tasked with developing electric reliability rules. This working group is directed to file consensus
Responder:
Witness: The Company has not determined who may be a witness.
Date: September 29,20 10

STAFF'S SECOND REQUEST FOR INFORMATION FROM
Appalachian Power Company
CASE NO. 10-1208-E-C
Helene Farley v. APCo
Request No. 2.3
Regarding Data Request 1.5; Please provide the information as required by Commission
Rule 4.5.2. In part, the rule states,
"
... record shall show the name and address of the complaint, the date and character of the complaint, and the adjustment or disposal made thereof."
Response No. 2.3
See attachment 1, a list of the Complainants mentioned.
Responder:
Witness: The Companylhas not determined who may be a witness.
Date: September 29, 20 10

L Name F Name Address Date
NELSON LOWELL RT. 1 Box 38 Harts, 1/4/2008
WV
Complaint
Customer concerned about the stolen grounds / neutral wires in her area
Result
Customer advised we dld have crews working on the stolen neutrals in the area.
BELCHER SHARON RT 1 Box 372,
Harts, W
WORKMAN iRViN
8/11/2008 Frequenf outages, ROWconcerns
RT. 1 Box 38 Harts, 2/18/2009
WV
Customer advised the Company was presently working on the RW maintenance on the Harts Creek Circuit where this customer is located.
BBB Complaint - concern in regard to outage time and reliability due to ROW maintenance.
Appalachian Power personnel visually inspected the circuit serving the customefs location and determined the right of way was mostly clear with only minor exceptions. The customer was informed of the inspection and tree maintenance schedule to address potentai tree issues. An analysis of recent outages affecting the customer showed that significant distribution circuit improvements have been made to equipment and right of way.
Additional improvements to the distribution system are planned for 2009 that will improve reliability of service to the area
BRYANT Company discussed with customer forestry notified to review ROW
LUCAS
DONALD RR 1 Box 524
Harts, W
TERRY
Harts, VW
212012009
416 Greenshoai Rd 5/29/2009
Frequent outages, ROW concerns
Several dead oak trees needing trimmed 4 dead Oak trees were removed on 6/8/2009
~
FAMEY -THOMAS
FARLEY
POBOX 146 Harts, 6/24/2010 Tree trimming request, delayed response
WV
JENNINGS RT 1 Box515 Harts, 6/28/2010 Frequent Outages
WV
BRYANT
BOSTiC
DONALD
BESSiE
RR 1 Box 524
Harts, WV
6/30/2010 Frequent outages, ROW concerns
Rt 1 Box 571 Harts, 7/1/2010 wv
Frequent outages, ROW concerns
FERRELL SUSAN
BRUMFiELD RUBY
BRYANT
23 Thompson Br. 7/17/2010 Frequent outages, ROW concerns
Harts, WV
552 Harts Crk. 7/19/2010 Frequent outages, ROW concerns
Harts, WV
DONALD RR 1 Box 524 7/19/2010 Frequent outages, ROW concerns
S M T n
'ThOMPSOh
ROY
KEiTn
BROWh h G .C_RRY
STOhERS ' L SA
' MARY
Harts, WV
62 Canev Br. Harts. 7/19/2010 Freauent outages, ROW concams wv !
66 P n e j Fm. n a m 7/19/2010 Freqwento,tages, ROW concerns w
Rt 1 B ~ X IFreq-ent o-[ages wv
I
' 9 S p ' c ~ t Freo-ent oJtages wv
200 D.) d o 3 e Ra. '7/23*2010 Frequent o,iages, 20vY cor.cerns nans. WV
55 F o ~ Freq-ent odtages R O N concerns wv
VAKCE C- FFORD 133 Toney Ra nans, WV
7/27/2010 F:eq,ent outages ROW concerns
MEADE EMh'Ah.,E- PO Bow 21 nans, 7/28/2010 Freq-enr outages ROW concerns w
I~EADLEY MMY
MCCLO-D DAv 3
521 East Frd nans 7135201C
WV
RRI Box 490 nans 8/3/2010
MY
S-rges odtages reqdest to f e oamage c a m a,e to os1 fooo
Frequent oLtages ROW concerns
.LCAS ROBEQT Greensnoa Ra nans M ,
8/3/2010 Freo-ent oLtages, ROW concerns
Trace 816 2010 Freq-ent o.la3es
\
On 6/23 Company visited residence and used a bucket truck working trouble close by to trim trees in question.
Company spoke with Helene Fariey on 6/28/10, advised Company has had a lot of outages from trees out of RNV failing on power lines during storms and those could not be prevented. Also advised crews are hotspotting on the circuit at the present and we would look the cir. over good for any danger trees or trees that could cause any outages. She said she has a couple trees behind her house that is in the line and Co. informed her we would look at them. She said that would be OK.
Company informed Mr Bryan1 the Aspiundh tree crews were currently
Hotspotting on the rtw and informed him we would also look for any danger trees.
Compamy spoke with Ms. Bostic 7/6/10 and informed her a iot of outages from trees out of RNVfaIiing on power lines during storms and those could not be prevented. Also advised crews are hotspotting on the circuit at the present and we would look the cir. over good for any danger trees or trees that could cause any outages
Company contact customer 7/20/10 and discussed ROW and advised would be there soon to cut trees in the pnmafv line
7/22/10, Company called customer, no answer. On 7/21, Asplundh cut down 3 dying trees and 2 pine trees, on C u m Branch near Brumfieid.
7/2210 Company spoke with customer, discussed ROW, advised Aspiundh is cuttinq close by and would be there soon
7/22/70 ComDanv contacted Mr. NaDier by and discussed tree issues, adv sea companiwoLlafeia cnecd'as soon as
DOSS bie
7/22/10 Company spoke w i n c,stOmer, d sc4sseo ROV\ a3v seo
7/23/10 Company spode w m c-stomer aov se3 AS p m a n crews are a ready n tne area tr mm nq
07/20/10 Company spode w In .erry Broa fig ana expla nea to n m tree creas are itom ng on tne circ..
1
7/26/10 Company rret d to nave a
CreN n a r d a'ouna me rr.oJn of Trace early next wee< (08/02/10)
Asp man wordpianner met um Mary Fry on 7/28/2010 to nform ner of wordplann ng De ng aone n tne area w e r e she yes. He nformeo ne: we are work.ngon tne nans C r that sne s on n e infonneo her we w. i cdt me tap sne s on as soon as we can We expect to Stan word ng towards her from the station next weed Sne was od +v tn answer
7/29/10 Company spode witn cLstomer Majordy of oLtages oLe to trees of me ROW Tne Asp m a n work p anner was scnead.ea to go bacn over ponions of the c rcJ 1 st ana 2na protect ve Zones urnere i n s cJstomer is located on T-esday the 28tn
7/24/40 Company met H to a SCLSS trees in the r no! ON ana on o ~ t try to nave a crew wormg tn s not ovy some1:rr.e the fol ou ng week an0 CreNS were u o r m g v.sao y n the hans area
CJstomer aav sea to ca 1.800 to file aamage c a m. given nformation on work tnat has Deen aone recent v ana wow tnat s sche3,iea
On 8/19/10 AspLnan Aord Planner met w.tn Davia McC.0-a C-stomer naa 3 pme trees need ng remova and 3 smai sycanwre trees ruo neeo nc removea ano one blg sycamore to s ae tr,m Tn s work was oe ng
ScneaLlea as pari of ongo,ng r gnt-of-way ma ntenance of me c.rc- t
Wornp anner tolo Vr McC 0:o Asp m d n was c-rreitly aording n the area ana lookinqover m,ch of the c r c A
8/20/10 Company cadea cJstomer no ansuer 912110 Company v s.teo s te met w tn cstomer dectdeo on CJtt ng down 6 Sycamore trees s gned release 9/6/10 Company mardeo the 6 large sycamore trees to nave cLt aown in tne corn ng weeds (not contact ng pr rnary w'res yet) and d an t fnd any otner proD ems there n e a's0 patro e3 otner areas of me Green
Shoals-Abbot Brancn 2phase feeaer m1-a ng the ne over the mo,nta n ana notea some need for tr mm ng 0 no ma,or RM, issues
The Forester $v .nc ,ce tnis area .n n s f,!,re work pans for tne nans
Creek C rc:t
8/6/10 Corrpany contacted c a o m e r to o s c s s concerns. Aspi-nan c r e m have tr mrred past C,rry Brancn aroJnd Tnompson Brancn otier tnan some worn on B-cd Ford uh.cn tPe Text nollow past Trace Asp'ddn plans to nave a creh r ana aro-io tne If.o.tn of Trace early next aeed

STAFF'S FIRST REQUEST FOR INFORMATION FROM
Appalachian Power Company
CASE NO. 10-1208-E-C
Helene Farley v. APCo
Request No. 2.4
Regarding Data Request 1.8; Please provide by region, the number of Work Orders performed and the total money spent in each individual "Blanket Work Orders established to accumulate and account for the cost of such activities" for the previous 10 years according to Company documentation.
Response No. 2.4
Because the response to this question involves materials which are voluminous, the materials will be made available for inspection during regular business hours at
Appalachian Power Company, Charleston, by arrangement.
Responder:
Name of Person Who Could Testify: The Company has not determined who may testify.
Date: September 29,2010

STAFF'S FIRST REQUEST FOR INFORMATION FROM
Appalachian Power Company
CASE NO. 10-1208-E-C
Helene Farley v.
Request No.
Regarding Data Request 1.1 1; the Company answer indicates that it "does not have details of all inspections and repairs
...
'I.
Please provide the records that are available.
Response No. 2.5
Because the response to this question involves materials which are voluminous, the materials will be made available for inspection during regular business hours at
Appalachian Power Company, Charleston, by arrangement.
Responder:
Witness: The Company has not determined who may be a witness.
Date: September 29,20 10

Respectfully submitted,
APPALACHIAN POWER COMPANY
Defendant
By Counsel
Senior Counsel for Appalachian Power Company
Dated this 29th day of September, 2010.

STATE OF WEST VIRGINIA,
COUNTY OF KANAWHA, TO-WIT:
1
1
Steven H. Ferguson, Director, Regulatory Services for Appalachian Power
Company, after being duly sworn, states upon his information and belief that the facts and allegations contained in the foregoing Response are true.
Taken, subscribed and sworn to before me on the 29th day of September, 2010.
My commission expires:
(SEAL)
OFFICIAL SEAL
STATE OF WEST VIRGINIA
NOTARY PUBLIC
DOROTHY E.
APPALACHIAN POWER
PO BOX 198G
CHARLESTON, WV 25327-1986
Y OommIPsinn exniree Orlnher 9 9nla

CERTIFICATE OF SERVICE
I, Gina E. Mazzei-Smith, Counsel for Appalachian Power, do hereby certify that true copies of APCO’S RESPONSE, was served upon Complainant through the regular course of the United States Postal Service, postage prepaid, this 29th day of September, 2010 addressed as follows:
Helene Farley
Route 1 Box 5 15
Harts, West Virginia 25524
‘ and a copy of APCO’S RESPONSE was hand delivered, addressed to:
Leslie Anderson
Public Service Commission of WV
201 Brooks St.
Charleston, West Virginia 25323
VIA HAND DELLVERY