ML19289F029

Second Set of Interrogatories Submitted to Applicant. Certificate of Svc Encl

ML19289F029
Person / Time
Site:	Zimmer
Issue date:	03/19/1979
From:	Rigberg S MIAMI VALLEY POWER PROJECT
To:
References
NUDOCS 7906010119
Download: ML19289F029 (8)

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NRC PUBLIC DOCUMENT ROOM UNITED STATES OF AMERICA .

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% 1 P NUCLEAR RB3ULA'IDRY CO.D.!ISSION e 2; VW ,d*s /

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In the matter of )

The Cincinnati Gas & Electric ) Docket No. 50-358 Capany, et al. )

(William H. Zinmer Nuclear )

Power Station) )

MIAMI VALLEY POWER PROLJECT'S SECDND SET OF INTERROGATORIES 'IO APPLICANT Intervenor Miami Valley Power Project (MVPP) hereby propounds the following interrogatories to Applicant to be ans e red fully in writing, under oath, within fourteen (14) days after service hereof in accordance with the following instructions:

1. " Describe in detail" shall mean give all data calculations, infonnation, assumptions and documents used in formulating the anser.

2. These interrogatories request all knowledge or information in the possession of Applicant and/or in the possession of Applicant's agents, representatives, and, unicss privileged, attorneys.

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7906010f17 g

. Interrogatories

1. In view of the fact that the Zinmer Station is the lead plant for the General Electric Mark II BWR design, describe in detail how Applicant will finance changes, alterations, improvenents, and updates in the Mark II design required by the Nuclear Regulatory Cannission.

2. Describe in detail how the Applicant anticipates correcting problens inherent to General Electric BWRs, as described in the Reed Report.

3. Describe in detail why the Zinmer Station cost more than originally projected.

4. Describe in detail all plans which each of the Applicant's canpanies have considered for future developnent of electric generating capacity.

5. Describe in detail how the projected 97 percent reduction in -the use of electricity at the Portmouth fuel enrichnent facility affects Applicant's projections of electricity danand.

6. Describe in detail all estimations for the length of time and the frequency that the Zinmer Station will be down for refueling.

7. Describe in detail how periods of refueling and periodic maintenance affect Applicant's projected capacity factor.

8. Describe in detail sources and costs of electricity while the Zinmer Station is dosm.

9. Describe in detail the corporate affiliations of all persons T Sirt serving on-(ur(y df the'. Applicant's Boards of Directors.

10. Mr. James A. Wuenker, Manager of Public and Cmmunity Relations for. Cincinnati Gas and Electric, has written in a letter dated March 9, 1979:

"In response to your inquiry to us and to the Cincinnati 2234 124

Enquirer's Action Line colen, we have double checked with our engineers who prepared the study of ccmparative cost of the Mn. H. Zinmer Nuclear Power Station and a coal-fired power plant of the same size. We are informed that both the costs of deccnmissioning the Zinmer Plant and storing radioactive wastes frcm the plant have been included in their ccmputations. Zinmer Station will save custcmers about $400 million over the life of the plant, in terms of .present-day dollars.

Describe in detail the study prepared on ccmparativecosts, or attach a copy thereof. Include names of authors.

11. Describe in detail the projected costs of deccnmissioning and unste storage used in this study.

12. Describe in detail the way in which the Zinmer Station udll be safely deccmnissioned according to this study.

13. Describe in detail the wny in which Zinmer's radioactive wastes will be safely stored according to this study.

14. Describe in ' detail the estimated cost of the Zinmer Station that uns used in this study.

15. Describe in detail all cost overruns that affected the $400 million figure.

16. Describe in detail how much of the $400 million savings will be enjoyed by each of the Applicant's three ccmpanies.

17. Describe in detail the savings to Applicant's custcmers had not the Zinmer Station be constructed.

18. Describe in detail all deviations frcm this ccmparative cost study and reports filed with the NRC.

19. Describe in detail the costs associated with bringing the pipe sre s ,

suppgrt systems,into ccmpliance. 4 i

20. Describe in detail all moveable parts in the Zinmer Nuclear Power Station.

21. Describe in detail what each moveable part is used for and how much it cost.

22. Describe in detail how all costs associated with the Zinmer Station will be passed on to the constmer in terms of rate hikes.

23. Describe in detail how a 50 percent capacity factor will affect cost per kilowatt.

24. As quoted in the March,1979 issue of Power Line, (vol. 4, no.8; Utility Project, Environment Action Foundation, 724 DuPont Circle Building, Washington, D.C. 20036), one official of Cincinnati Gas and Electric Canpany has said: "If we knew then what we know now, we might never have gone into Zinmer I ." Identify the person who made that statenent, and his position within the canpany.

25. Describe in detail what that person meant by the phrase "if we knew then what we know now." What is knavnnow that would influence the decision not to construct Zinmer I?

26. Describe in detail all safety and econanic considerations that are known now which lead to the statenent quoted above.

27. Has Applicant subnitted an econanic impact statenent to the public Utilities Cannission of Ohio and/or the Nuclear Regulatory Catmission. If either, supply us a copy of the econanic impact statenent. Describe in detail the methodology and assuptions used, identify source material, and supply all pertinent data.

28. Describe in detail all existing plans for partial or reduced capacity operation at Zinmer.

29. Describe in detail all econanic or engineering circumstances which P""t* "-

"Tif"dR T P i" 2234 126

e - 30. Has the Zinner Station's long run cost been detennined using an econanic production function or were simple accounting procedures used?

If the fonner, please state the fonn and assumptions of this function; e.g. ,

fixed proportions, lxmogeneous, quasi-hcmogeneous, hanothetic, non-hanothetic, and express than precisely, as, for example, q =.M(AL*P+Bkf)~1kwhich is the classic C.E.S. function. In either case, please state the elesticity of factor input substitution in physical, r.ot monetary, tenns. Describe In all instances, please in detail any ccmputed expansion coefficients.

describe the methodology and assumptions used, identify source materials and supply all pertinent data and calculations. If any of the above said information does not exist, why has it been considered unnecessary?

31. Has the Applicant estimated the availability and costs of all operating and muntenance inputs for the Zinmer Station? Describe in detail the methodology and assuptions used, identify source material, and supply all pertinent data and calculations. If no such estimates exist, why have they been considered unnecessary?

32. Has the Applicant considered these supply and cost estimabes in detennining the Zinmer Station's long run econanic viability and profitability?

Would cost esculations be passed on to consumers as rate hikes? If so, has theiApplicant considered restraining such requests for rate hikes to the limit of Zinmer Station's productivity? If not, why not?

33. Has the Applicant estimated econanic return to capital across the life of the Zinmer Station? Describe in detail the methodology and assumptions used, identify source material, and supply all pertinent data and calculations.

If "present value", " marginal efficiency" or other discounting fonnulas have been used, please state the rationale and discounting factors and fonnulas, and all pertinent data and calculations for both the operating and the decan-missioning tenns. If such considerations have nct been made, why were they considered unnecessary? 22M l2[

34. Describe in detail the costs of constructing, operating and unintaining distribution systens for the electricity produced at the Zinmer Station.

35. Describe in detail the interplant substitution plans or possibilities which exist, and the cost and output elasticities for such modes of opertation.

36. What methodologies, assuptions, source material, calculations and data have the applicants used in conputing regional and national econanic growth and stability, and the impact of these factors upon the econanic viability and productivity the Zinmer Station'? If such considerations have not been made, describe in detail why they are considered unnecestm ,/.

37. Provide a schedule of adninistrative costs for Zinmer across the operating term of the Station.

March 19, 1979 Respectfully subnitted, khNO1 Saul Rigberg Menber, Miami Valley Power Project 2234 128 e6

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UNITED STATES OF AMERICA g -

NUCLEAR REGUIEITY ODtNISSION In the Matter of  : \

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'IHE CINCINNATI GAS & ELKTRIC  :

OCMPANY, et al. Docket No. 50-358 (Wrn. H. Zinmer Nuclear Station)  :

CERTIFICATE OF SERVICE I hereby certify that copies of " Miami Valley Power Project's Second Set of Interrogatories to Applicant", in the captioned matter, have been served upon the following be deposit in the UnitM States mail this

/f M day of Nore.[ , 1979:

Charles Bechhoefer, Esq. Michael C. Farrar, Esq.

Chaizunn, Atcmic Safety Atcmic Safety and Licensing and Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ccmnission Ocmnission ,

Washington, D.C. 20555 Washington, D.C. 20555 Dr. Frank F. Hooper, Manber Chairman, Atcmic Safety and Atcmic Safety and Licensing Licensing Board Panel Board U.S. Nuclear Regulatory School of Natural Resources Ccumission University of Michigan Washington, D.C. 20555

• Ann Arbor, Michigan 48109 ,'

Richard S. Salzman, Esq.

Mr. Glenn O. Bright,'y!bmb9 r' Chairman, Atanic Safety abd Atcmic Safety and Licensing Licensing Appeal Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Ccnnission Ccnmission Washington, D.C. 20555 Washington, D.C. 20555 Stephen M. Schinki, Esq.

Dr. Lawrence R. Quarles Counsel for the NRC Staff Atcmic Safety and Licensing Office of the Executive Appeal Board Legal Director U.S. Nuclear Regulatory U.S. Nucelar Regulatory Ccnmission Ccnmission Washington, D.C. 20555 Washington, D.C. 20555 2234 129-

a. >.

William J. Abran, Esq. William Peter Heile, Esq.

General Counsel Assistant City Solicitor Cincinnati Gas & Electric City of Cincinnati Co many Box 214 Post Office Box 960 Cincinnati, Ohio 45202 Cincinnati, Ohio 45201 h! ark J. Wetterhahn h!r. Chase R. Stephens 1747 Pennsylvania Avenue Docketing and Service Section N.W.

Office of-the Secretary Washingten, D.C. 20006 U.S. Nuclear Regulatory Cam 11ssion John D. Woliver, Esq.

Washington, D.C. 20555 Clennont County Comunity Council Chairman, Atanic Safety and Box 181 Licensing Batavia, Ohio 45103 Appeal Board Panel U.S. Nuclear Regulatory Camnission Washington, D.C. 20555 h!IAMI VALLEY POWER PROJECT E0k&c "

O BY: Saul Rigberg hianber, hiiami Valley Power Project 2234 130

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