t 800 Cabin Hill Dr. Greensburg, PA 15601 John L. Munsch Attorney 724-838-62 IO Fax: 724-830-7737 November 22,201 1 FEDEX NEXT DAY Ms. Sandra Squire Executive Secretary Public Service Commission of West Virginia 201 Brooks St. PO Box 812 Charleston, WV 25323 Re: Rodney E. Steorts v. Monongahela Power Company Case No. 11-0442-E-C Dear Ms. Squire: Monongahela Power Company (“Mon Power”) responds to the Final Joint Staff Memorandum dated July 29, 201 1 in the above-captioned proceeding concerning inspection of surge arrestors. Mon Power believes that its inspection methods and intervals for surge arrestors comport with industry standards. In addition, Mon Power submits the attached report to the Commission Staff on the sufficiency of these practices. Sincerely, I, Attorney WV State Bar No. 9933 JLM:jss Attachment cc: Certificate of Service Rodney Steorts v. MP NO, 1 I-0442-E-C Surge Arrester Report Mon Power will submit a report to the Commission Staff on the sufficiency of these practices [inspection methods and intervals for surge arresters] by November 23, 201 1. Mon Power installs surge arresters on distribution circuits routinely to protect equipment from lightning or similar overvoltage events. Surge arresters are installed on distribution transformers, reclosers, regulators and other major pieces of distribution equipment. Mon Power’s practice of using surge arresters to protect utility equipment is consistent with the rest of the utility industry. Surge arresters are very simple devices; traditionally they were a set of spark gaps and a non-linear resistor inside a porcelain housing. Modern designs use varistor materials housed in a polymer housing. Both designs basically operate by diverting the surge current from a lightning strike to ground thereby protecting the piece of distribution equipment on which they are installed. Surge arresters are designed with an isolator on the bottom of the housing. If the arrester fails, the isolator will operate to clear the ground lead from the base of the arrester. Surge arrester maintenance is limited to visual inspection as part of the overhead and circuit inspection process. Surge arresters are very reliable devices and they are either fully operational or failed. A distribution arrester in the failed mode can usually be identified during a visual inspection by identifying the arrester’s ground lead is disconnected or the housing is damaged. Industry standards such as The Institute of Electrical and Electronics Engineers (IEEE) and Doble have recognized that there are really no effective maintenance practices that can be performed on distribution class surge arresters other than performing a visual inspection. Mon Power’s practice of performing overhead circuit and equipment inspections on a six year cycle is based on accepted electric utility practices and the experience of the FirstEnergy operating companies. National Electrical Safety Code (NESC) Rule 12. I2 I .A states, “lines and equipment shall be inspected at such intervals as experience has shown to be necessary.’’ Overhead circuit and equipment inspections have proven to be successful in addressing emergent problems in a timely manner, allowing for proper planning and remediation prior to the emergent problem having a negative impact on personal safety, equipment integrity or service reliability. Mon Power has experienced a very low failure rate of arresters when compared to the number of surge arresters on distribution circuits. The Company does not have abnormally high equipment failure that can be attributed to high voltage and the arresters appear to be very effective at preventing distribution transformer failures during lightning storms with out failure themselves. Therefore the Company’s experience indicates that arresters are a very reliable piece of equipment and are relatively maintenance free. w 1 Re: Case No. 11-0442-E-C CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of November', 20 1 1, a copy of the foregoing Rporte was sent by U.S. Mail, First Class, to: Rodney E. Steorts 249 Steorts Rd Sutton, WV 26601 John Auville, Staff Attorney Public Service Commission of WV 201 Brooks Street P.O. Box 812 Charleston, WV 25323