ML19330A072
| ML19330A072 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/29/1977 |
| From: | Pribila L DOW CHEMICAL CO. |
| To: | CHERRY, M.M./CHERRY, FLYNN & KANTER, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8007140880 | |
| Download: ML19330A072 (20) | |
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THIS DOCUMENT CONTAINS POOR QUALITY PAGES
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UNITED STATES OF AMERICA % $@$ ,"l,,
NUCLEAR' REGULATORY COMMISSION q, e;dV <
3 Before the Atomic Safety and Licensing Board In the Matter of )
CONSUMERS POWER COMPANY Docket No's20._3293 50-330 (Midland Plant, Units 1 and 2) 1 3-2ct- 7 7 SUPPLEMENTAL RESPONSES TO INTERR0GATORIES
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The Dow Chemical Company ("Dow") submits the following supplemental answers to Interrogatory 8 of Intervenors other than Dew andInterrogatory1(k)oftheNRCStaff. Since these Interrogatories request similar information, the answers to both have been combined in the statement set forth below.
- 8. State in detail the present status of your current
, facilities for generating electricity or steam in light of each of the following:
-(a) regulation, discussion, citation, demands or requests -
, by or from the United States Environmental Protection Agency regarding State or Federal air pollution requirements in Midland, Michigan.
(b) regulation, discussion, citation, demands or requests by or from the Michigan Air Pollution Authority regarding State or Federal air pollution requirements in Midland, Michigan. .
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, 2 Include within your answer to this interrogatory, separately for Federal and State regulatory authorities, whether you presently believe that each or both of them would permit you to operate your present generation facilities past 1980 and if so, under what circum-stances, explaining in detail any costs or capital changes in connec .
tion with such circumstances.
- 1. With reference to Dow's " Presentation to Michigan Air Pollution Control Commission" of January 18, 1977:
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- k. Please relate the substance of any meetings with the MAPCC. and/or its Staff and/or the Environmental Protection Agency occurring after January 21, 1977 to the NRC Staff on a continuing basis.
Antwer -
Subsequent to the Dow appearance on January 18, 1977 before the Michigan Air Pollution Control Commission (MAPCC), several meetings
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were held between Dow representatives and the Staff of the MAPCC (Staff).
The purpose of these meetings was to develop a new Consent Order incor-parating Dow's prcposal to meet all applicable Michigan emission regula-tions by converting from coal to oil as a fuel for its boilers. As a result of these meetings, Staff and 'Dow reached agreement on' a Proposed Resolution and a Stipulation for Entry of Consent Order and Final Order.
t On March 22, 1977 Dow appeared before the MAPCC at its regu-larly scheduled meeting and the Staff presented the MAPCC with the material attached hereto as Exhibit A. Exhibit A contains:
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3 a) Staff Activity Report dated March 22, 1977; b) Staff Activity Report dated January 18, 1977; c) Proposed Resolution dated March 11, 1977; d) Stipulation for Entry of Consent Order and Final Order dated March 11, 1977.
Dow did not make a prerentation to the MAPCC at the March 22, 1977 meeting but responded to questions of the various Commissioners.
At the conclusion of the meeting it was announced that public hearings on the Proposed Consent,0rder will be held in the Midland area prior to any action by the MAPCC. The Staff is presently proceeding with arrangements for this hearing.
The status of Dow's dispute with the EPA remains unchanged from that set forth in answer 1(k) of Dow's Further Response to Interrogatories dated February 28, 1977.
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L. W. Pribila, Attorney The Dow Chemical Company L. W. Pribila, being duly sworn, deposes and says that the foregoing Supplemental Responses to Interrogatories are true to the best of his knowledge and belief.
k L. W. Pribila STATE OF MICHIGAN )
ss.
COUNTY OF MIDLAND )
Subscribed and sworn to before me, a Notary Publ.ic, this
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29th day of March, 1977. "' '
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' EXHIBIT A
!!ICHIGA!! DEPARTME!!T OF f!ATURAL RESOURCES AIR QUALITY DIVISI0tl p w STAFF ACTIVITY REPORT s tiarch 22, 1977 gf8 q 6-f 0p Iy y
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Respondent --
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- f3 IN1 n i hg a comPEDENc3 f os &
January 18, 1977 Comission Meetino_
'Dow's most recent appearance before the Comission was on January 18, lo77.' i A copy of our staff report for that meeting is attached. At that time, the company requested permission to postpone compliance with the Comission's emission limits for particulate and sulfur dioxide frem July 1,1980 to July 1, 1982. Their stated reason for this request was econcmic, nnt technical. l Following discussion of the company's proposal, the Comission directed the l staff to evaluate the company's proposal in light of the Comission's guide- l lines for sulfur dioxide extensions beyond 1980 and to develop a proposed Consent Order for the Comission's consideration. ,
Present Status Since the January 18, 1977 Commission meeting, the company and staff have met on numerous occasions to carry out the Commission's directive. Recently, the company withdrew the request for an extension and agreed to a new order
- incorporating a compliance schedule that stipulates ccmpliance by July 1, 1980. This continuing comitment to comply by 1980 is made by the ccmpany with the understanding that they can at some time in the future again request an extension. -
The Proposed Order The proposed Consent Order upon which the staff and company have agreed incorporates a timetable with specific increments of progress for the con-version c* all their boilers to oil firing and the construction of large oil storage tanks and of a pipeline for oil transportation between !11dland and Bay. City. The proposed order also covers to staff's satisfaction those concerns regarding SCS expressed by staff at the January,1976 Comission meeting at which time a rehearing cn the SCS was ordered.
Recomendations Staff recomends that the Comission: (1) Adopt the attached resolution wt/ch eecognizes the recen': events and Dow's intention to return to the Comission in the future with tneir extension request; and (2) Adopt the proposed Consent Ordar.
Submicted by: Benjamin E. White Marca 11,1977 BEW: RPM mab Attachments (3) 1
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s * ,v REL4ED CoanESPONDENCEw MICHIGAtt DEPARTMENT OF NATURAL RESOURCES a *, s 1 Dl*
AIR QUALITY DIVISI0t! dd -
STAFF ACTIVITY REPORT /' / 7-1 January 18, 1977
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{3 Respondent
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Dow Chemical Company * '
flidland, Michigan History The Dow Chemical Company operates two large power plants to produce heat and process steam and electricity for its operations in tiidland, 'tichigan. Those power plants contain eight large boilers that burn coal durino some portion of . l the year. The sulfur content of the coal burned averages approximately four (4) percent. The Rule 49 limit for these boilers is one (1) percent. When burnino coal, each boiler emits quantities of particulate matter considerably in excess i of (3 to 10 times.) the Comission!s emission limits.- Of the eight boilers still '
burning coal, five are cyclone type boilers which burn crushed coal and have no 1 dust collectors. One burns crushed coal with a mechanical collector. Two others are pulverized coal-fired boilers with mechanical dust collectors. All of these boilers would need high efficiency particulate collectors such as electrostatic precipitators to meet the particuote emission limits while burning coal.
In October,1968, Dow requested a variance from the Comission's particulate emission limit. They believed it would be unreasonable to require the expenditure of five million dollars for controls when the use of the boilers was expected to be discontinued in three and one-half years. Dow had a contract to purchase their power from Consumers Power Company's flidland nuclear facility scheduled for completion in 1974-75. .
The Comission approved the first six month variance on June 17, 1969. Our records indicate that in 1972 the construction schedule for the nuclear plant was extended to 1977. Additional variances were approved by the Comission until January 30, 1973, when Voluntary Agreement No. 22-1973 was approved.
That agreement provided for the. construction of two 400-foot stacks for discer-sion of sulfur dioxide. This dispersion technique was proposed and approved to prevent the reoccurrence of violations of the health related air quality standards that had resulted from the use of high sulfur coal and short stacks.
In 1974, the agreement for the tall stacks was replaced by Consent Order No. 12-73-05. That order provides for the attainment and maintenance of the air quality standards through the use of a Supplementary control Systen (SCS).
An SCS is a system which limits the rate of nollutant emissions durino periods when meteorological conditions conducive to ground level concentrations in excess of the air auality standards are anticipated. The essential elements of an SCS include meteorolonical and air quality forecastinti, observation of real time air quality data and reducing emissions when necessary to prevent excessive ground level pollutant concentrations.
> - u v Dow Chemical Company .Tanuary 18, 1977 Present Status Under Consent Order No. 12-73-05 Late in 1975, sulfur dioxide levels occurred in Midland that were in excess of those allowed by Consent Order No. 12-73-05. The company's position was that the Consent Order allowed the company one excursion per year at each monitor and that no violation of the Consent Order or the air quality standards had occurred. Therefore, they were unwilling to negotiate a revised order.
1 The position of the Commission's staff was that the Consent Order and the air quality standards had been violated, that the excessive levels of sul' fur dioxide would have been prevented had the company implemented instructions received from its consultant, and that the Consent o rder should be modified to prevent similar future occurrences. nn January 20, 1976, the Comission entered an "nRDER FOR REHEARING" which required that Final nrder No. 12-73-05 be reconsidered.
At the same time, the Ccmmission expressed concern over the lead time that would be required to implement strategies to control particulates and sulfur dioxide in order to meet the deadline required by the order. The Consent Order states that: "By .luly 1,1980, Dow Chemical Ccmpany shall purchase its steam and power requirements in sufficient quantities or make other coerating modifications,~as aporopriate, to be approved in advance by the Ccmission, to ensure complete compliance with all applicable state and federal particulate and sulfur dioxide emission limitations, such limitations being published in the Administrative Code." The company has stated they would accomplish this by burning oil, if necessary.
Since the January 20, 1976 Commission meeting, it has been the staff's goal and preference to reach an agreement with the company without the formal rehearing ordered by the Comission. Such an agreement wculd include a detailed compliance nrogram and time schedule for meeting.the Comission's emission limitations in 1980. The exact ambient pollutant levels that are to be prevented during the interim would also be stipulated in that agreement. The company I has generally been agraeable to development of this new agreement; however, due to uncertainties relative to the proposed nuclear plant of Consumers Power Company, they have not until recently developed a compliance strategy.
That strategy was preserted to staff last Thursday, January 13, and will i be presented to the Commission today.
Air Quality in Midland in 1976 Early in 1976 three excursions of the sulfur dioxide air quality standard l occurred in Midland. Two sites each recorded one excursion of the 24-hour l standard and a 3-hour excursion of the secondary standard was recorded at ;
another stie. No excursions have been measured for approximately 11 nonths.
The company has made some changes in their SCS program which have made the system more conservative and more reliable.
%' w Dow Chemical Company Janua ry 18, 1977 The Company'. Fuel Switchino Canabilities When the company began operation of its SCS in 1975, two of their eight coal-fired boilers were capable of being switched to oil firing. Durino the summer of 1975, one additional boiler was provided with this capability. Late in 1976, oil switching equipment was installed in another boiler and two more are expected to have this equipment in the near future. In addition, one boiler which is not capable of daily fuel switching is seasonally converted to oil firing. Consequently, in the near future only one of the eight boilers will not have the ability to burn oil.
Future Actions If the company's plan, as presented to the Commission today, is acceptable to the Commission, staff will attempt to develop a Consent ne der snecifying the terms of the program. If an order can be agreed to by the staff and the company, a public hearing will be scheduled. If not agreed to, the matter will be returned for additional consideration by the Commission.
Submitted by: Benjamin E. White January 17, 1977 ,
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ORAFT - 3/11/77 PROPOSED RESOLUTION MICHIGAN AIR POLLUTION CONTROL C0litISSION WEREAS, The Dow Chemical Company appeared before the Michigan Air Pollution Control Comission on January 18, 1977 and requested pemission to extend the date by which it must achieve full compliance with State emission regulations until July 1,1982; and WEREAS, the Michigan Air Pollution Control Comission directed the staff of the Air Quality Division, Department of Natural Resources, to evaluate lhe Dow Chemical Company request in accordance with the Comission guidelines for extension of Rule 49 compliance dated June 15,1976 and to develop a proposed Consent Order for consideration by the Comission; and "
WEREAS, The Dow Chemical Company has demonstrated that at any time after July 1,1980 Dow can achieve compliance with R 336.41, R 336.44 and R 336.49 by fuel conversion; and WEREAS, The Dow Chemical Company is currently proceeding with all necessary modifications to achieve said compliance; and WEREAS, prior to 1980, under certain conditions, The Dow Chemical Company s may decide to proceed with the construction of new fossil fuel facilities and petition the !!ichigan Air Pollution Control Comission for authorization not to proceed with fuel conversion; and WEREAS, The Dow Chemical Company has decided to withdraw its extension request until its future energy plans are more clearly defined; HOW, THEREFORE, BE IT RESOLVED that the Michigan Air Pollution Control Comission accepts the withdrawal of The Dow Chemical Company extension request recognizing that Dow will in all probability apply for further relief at a future date because of Dow's stated need.
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AIR POLLUTION CONTROL COMMISSION 9 cg.h 9
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In the matter of administrative proceedings )
against THE 00W CHEMICAL C0ftPANY, a Delaware )
corporation, concerning particulate matter )
and sulfur dioxide emissions from fossil ) APC No.
fuel burning operations at the !!ichigan )
Division in the City of Midland, County of )
Midland, State of Michigan.
STIPULATION FOR ENTRY OF CONSEllT ORDER AND FINAL ORDEP.
This proceedino arises out of Final Order 12-73-05, an Order for
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Rehearing dated January 21, 1976 of the itichigan Air Pollution Control Comission [ hereinafter referred to as the " Commission"] and a proposal frem Tne Dow Chemical Company [ hereinafter referred to as "Dow"] for the continued operation of its South Side and West Side Power Plants at Dow's manufacturing location in itidland, Michigan, after July 1,1980.
One of the provisions of the existing Consent Order, flo. 12-73-05, is that the Company shall purchase its steam and power requirements after July 1,1980 or make other operating modifications, as appropriate, to be approved in advance by the Commission, to insure complete compliance with all applicable State particulate and sulfur dioxide emission limitations.
Because it is now apparent that Dow will not be able to purchase its steam by this date, Dow has proposed to comply with all applicable State emission limitations and regulations.by eliminating coal as a fuel in its PoWr Plants.
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Page 2 This Consent Order has been developed in order to incorporate provisions caused by the proposed complete conversion from coal to oil as a fuel. This Consent Order has also been developed because particulate matter and sulfur dioxide emissions from the Power Plants, if not abated, would be in excess of allowable limits according to the provisions of Michigan R 336.41, P 336.44-and R 336.49, Administrative Code,1973 AACS.
Dow and the staff of the Air Quality Division, Department of Natural Resources [ hereinafter referred to as the " Staff"] with the approval of the Comission, agree to the termination of this proceeding by entry of a final order of consent in accord with the stipulation recited below.. .
Dow and Staff hereby and herewith stipulate and agree as follows:
- 1. Dow acknowledges proper service of a notice of hearing and proposed order and expressly waives filing of an ansar. Dow agrees to the termination l of this matter by the entry of a final consent order incorporating the terms of this Stipulatien in the form attached to this Stipulation.
- 2. Dow acknowledges that it is presently the source of the emissions which results in all significant ambient air concentrations of sulfur dioxide in and around flidland, Michigan.
- 3. Dow has demonstrated to the satisfaction of the Comission that all constant emission reduction technology reasonably available to Dow and economically feasible to install between now and July 1,1980 has been applied and such constant emission reduction technology is insufficient to attain the Federal primary and secondary ambient air quality standards. Following .luly 1, 1980, the only constant emission reduction technology reasonably available to
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Page 3 Dow and economically feasible to install is fuel conversion. However, Dow has demonstrated the technical and operational feasiblity of its version of a Supple -
mentary Control System to achieve the Federal primary and secondary ambient air quality standards.
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4 Dow and the staff agree that the signing of this Stipulation is for settlement purposes only and does not constitute an admission by Dow that the law has been violated. However, both Staff and Dow do expressly agree that the particulate and sulfur dioxide emissions from Dow's South and West Side Power Plants in Midland, Michigan, should be abated; and, therefore, both Staff and Dow herewith and hereby stipulate and agree to the following time schedule and program for further affirmative action:
(a)CONTROLPROGRAM:
(i) By July 1,1980, Dow shall utilize fuel which when burn.ed will result 'a compliance with the State emission standards, R 336.41, R 336.44 and R 336.49, unless otherwise permitted by the Commission.
(ii) In order to meet the July 1,1980 date above, Dow shall meet the increments of progress noted in Attachment A. Deviation from Attachment A shall be permitted only to the extent that it does not interfere with meeting the July 1,1980 date and if Dow notifies the Staff in writing prior to such deviations.
(b) SUPPLEMENTARY CONTROL SYSTEM: Supplementary Control Systems (SCS) are systems which limit the rate of pollutant emissions during periods !
when meteorological conditions conducive to ground level concentrations 1
in excess of Federal ambient air quality standards are anticipated. In l order to maintain ambient air quality, Dow and Staff hereby and herewith
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.Page 4 agree to be bound by the following operational details of a Supplenentary Control System (SCS):
(i) On and after the effective date of this Order, Dow shall maintain the operation of eight (8) continuous sulfur dioxide monitors of a type and at locations approved by the Staff. The operation of these monitors shall continue until the Power Plants are in compliance with all applicable State sulfur dioxide emission limits and Dow has demonstrated to the satisfaction of the Commission !
that the potential for violations of the Federal ambient air quality standards has been eliminated.
(ii) On and after the effective. date of this Order, Dow shall submit to Staff the information referred to in Attachment B.
Attachment B may only be changed upon mutual agreement of Staff and Dow or upon order of the Commission. All monitoring, meteorological and boiler operating data mentioned fn Attachment B shall continue to be submitted until the Power Plants are in compliance with all applicable State sulfur dioxide emission limits and Dow has de=enstrated to the satisfaction of the Commission that the potential for violations of the Federal ambient air quality standards have been eliminated.
Dow retains full responsibility for the operation of its Power Plants.
The information released to the staff according to Attachment B shall be used by the Staff to evaluate Cow's operation of the SCS.
(iii) After the effective date of this Order and until the program mentioned in paragraph 4(a), above, beccmes fully operational, Dow shall prevent ambient sulfur dioxide concentrations in and around Midland, Michigan, from ever exceeding a running 24-hour average of
Page 5 0.14 ppm, an annual arithmetic mean of 0.03 ppm, or a running 3-hour average of 0.50 ppm. Dow shall utilize low sulfur fuel, load reduction, plant shutdown, or other means to maintain this air quality. Each excursion above the specified limit at the same monitor or at different monitors shall constitute a separate violation of this Order. Both Staff and Dow acknowledge that the requirements set forth in this paragraph are more stringent than would be required to satisfy the Federal ambient air quality standards.
(iv) Dow shall retain the services of a consultant (s) for air
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quality modeling and meteorological forecasting purposes (or otherwise provide such services) approved by the Chief, Air Quality Division.
Any change in any consultant requires written authnrization by the Chief, Air Ouality Division, following a demonstration by Dow that the necessary services can be satisfactorily performed by another party. .
(v) Dow shall provide the consultant (s) mentioned in paragraph 4(b)(iv), above, with a separate series of control strategies for each of the West Side and South Side Pover Plants. Those strategies shall be based upon the combinations of boilers which may be available for operations at any time in the future. Each strategy shall itemize consecutive steps that specify changing modes of boiler operations such that the power plant's sulfur dioxide emissions can be increnntally reduced. The consultant (s) shall regularly reccmend to Dow a strategy steo which the consultant (s) has determined will assure at all tines 1
the maintenance of air quality as described in paragraph 4(b)(iii),
above. .
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Page 6 (vi) After the effective date of this Order, and until the air pollution control program mentioned in paragraph 4(a), above, becomes fully operational, Dow shall operate its boilers in accordance with a strategy step which will result in sulfur dioxide ground level con-centrations at least as low as the ground level concentrations would be if the strategy step specified by the consultant mentioned in paragraph 4(b)(v), above, were followed.
(c) REPORTING: Annually from the date of final adoption of this Consent Order, Dow shall submit to Staff (and upon request to the Cenmission) a report of its progress towards complying with the provisions of this
- Control Program and Supplementary Control System (including Attachments A and B). Any significant developments which would preclude compliance by Dow with any provision of this Consent Order shall be imediately trans-mitted in writing to the Staff and the Comission.
- 5. Dow and the Staff agree that this Stipulation and Final Order, upon approval by the Cormiission, rescinds an agreement between the parties dated May 17, 1974, Final Order No. 12-73-05 6 Staff and Dow both acknowledge that a public hearing on this abate-ment program was held on . Both Staff and Dow hereby consent to enforcement of this Stipulation and Final Order in the same manner l
and by the same procedures for all final orders entered pursuant to Section 16 of Act 257 of the Public Acts of 1972, being Section 336.26 of the 'fichigan I
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Page 7 Compiled Laws, including but not limited to, enforcement by legal action brought under 1972 PA 257 and/or 1970 PA 127.
Approved as to Fom and Content:
THE DOW CHEMICAL COMPANY Dated:
Approved as to Content: Approved as to Fom:
Lee E. Jager, Chief ,
Air Quality Division Assistant Attorney General !
DEPARTNENT OF NATUPAL RESOURCES DEPARTMENT OF ATTORNEY GENEPAL l Dated: Dated: 1 1
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.Page 8 FINAL ORDER This Conmission having had opportunity to review the above-stated Stipulation for Entry of Consent Order, and having approved the terms thereof, and this Commission having authorized the Executive Secretary and the Assistant Executive Secretary of the Air Pollution Control Ccmmission as agents of the Commission to enter into Consent Orders, IT IS ORDERED that the Stipulation for Entry of Consent Order is approved and shall be entered in the record of this Commission as stated herein.
AIR POLLUTION CONTROL COMMISSION Lee E. Jager Acting Executive Secretary Dated :
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Attachment A- INTEGRATED B0ILER REHABILITATION AND OIL CONVERSION SCHEDULE ,
INTEGRATED BOILER REilADILITATION 1
813 REBUILD fd Legend 818 STACK 9//////[E"3 ENGINEERING 8 SHOP FABRICATION 8 20 REBUILD-OlL V////// M 3 OUTAGE FOR INSTALLATION 015 UPGRADE-Olt 7//////////f"'XDMGl
/ [b -il flELD CONSTRUCIl0N 09 UPGRADE 7//////////f4,M A AUTHORIZATION HONEY Bl4 UPGRADE 7/////////////gfffff//fg//fdifd2fGJ 0 UATERIALS ORDERED Bl2 MAINTENANCE % 2l R UATERIALS RECEIVED 818 OIL CONVERSION V//////ffff////////////////////////P WD Bl6 UPGRADE V/////////////////////////////FhI.0#B Bl9 0ILC0NVERSl0N V///////////////////////ffffff/////////////////////fAtUSWO 8l7 UPGRADE V/////////////////////////AD M ll R M J B18 UPGRADE (7) 1981 :
B 20 UPGR ADE B 218 22 UAINT. 1981---+ ,
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100 % OIL CONVERSION ENGlNEERlNG WS//////$//////////////////////// A 0.C. TA NKS / PIPE O i!F Rl7#@ e W $ei.$is ' w sl PIPELINE O RhisN5+6i!@ W " J Wl UID. TANKS / PIPE O lRT ($d R [@5Mhiisfebs@sMs.sliigmfil iI l l t I ! I I i I i I I i i I iil I i I I i i I i iil i i ii i l I I I iI i 1 5,05?OE,d8.SynS5,$5E0E(BabMS5S"2"%gE,d,ESun,S$,$5"%gE,dg$gBg m2 3 - ~ m =o 2 < :n , <wowo .o o .= ,. =
3 iT. I 1978 1979 1980 l
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"L ATTACHMENT B SAR
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- 1) EVERY EIGHT (8) HOURS: L -
y os (1) Thirty (30) hour meteorological forecasts that the consul . se in the dispersion model(s), including wind direction, wind speed, stability and mixing heights.
(ii) Recomended control strategy steps for subsequent 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
(iii) Predicted 1-hour, 3-hour and 24-hour running averages of sulfur dioxide concentrations for each of the subsequent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at each monitoring station and the maximum predicted 1-hour, 3-hour and 24-hour running averages of sulfur dioxide concentrations and their location. It is understood that the predictions for the maximum concentrations shall also be for each of the subsequent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
- 2) DAILY:
(i) Summary of sulfur dioxide air quality data for previous day, including hourly averages and running 24-hour averages.
(ii) Boiler operation sumary specifying actual operation. When strategy step calls for reduced operation from any boiler, the boiler operation sumary r'1all include the boiler load-reported as a percentage of full c: nominal load. ,
(iii) "easured meteorological data, including wind speed, wind direction (including deviation), temperature, dew point temperature, and low level (10-91 meters) 1rpse rate as observed in Midland. Such data shall be submitted in an hourly format for the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and shall include 10, 60 and 90 meter observations.
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- 3) MONTHLY:
1 (1) Sulfur dioxide air quality data from all stations in SARGAD format. l
- 4) AS REQUESTED:
(t) All amendments to control strategies, including supplementary steps not normally defined by the consultant (s) and amended meteorological forecasts, appropriate steps as they occur, and other infor ation requested by staff relating to the operation of the SCS.
(ii) A report of all occurrences when the actual boiler coeration did not follow the recomended strateg'/, including a demonstration as to whether or not the actual operation was equivalent to the recomended strategy with respect to its air quality impact.
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UNITED STATES OF AMERICA [g#[nt:
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NUCLEAR REGULATORY COMMISSION g N &
'In the Matter of the Application of )
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CONSUMERS POWER COMPANY ) Docket Nos. 50-329 50-330 (Midland Plant, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of the attached " Supplemental Responses to Interrogatories" dated March 29, 1977, were served upon the individuals whose names appear on the attached service list by deposit in the United States mail, postage prepaid and properly addressed, on che 29th day of March, 1977.
. mE LWirne K. Mil 1er
. W 9Jw The Dow Chemical Compan{y Legal Department 47 Building Midland, MI 48640 March 29,1977
Attachment:
Service List n
T s
SERVICE LIST Mr. C. R. Stephens, Chief Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard K. Hoefling, Esquire Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Myron M. Cherry, Esquire Suite 4501 One IBM Plaza Chicago, Illinois 60611 David J. Rosso, Esquire Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 Frederic J. Coufal, Esquire, Chairman Atomic Safety and Licensing Board Panel .
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Enneth A. Luebke, Member Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. J. Venn Leeds, Jr. , Member 10807 Atwell Houston, Texas 77096 Ms. Mary Sinclair .
5711 Summerset Street Midland, Michigan 48640 Mr. Steve Gadler, P.E.
2120 Carter Avenue St. Paul, Minnesota 55108 Dr. Richard Timm 1038 Cascade Dr. , N.W.
Salem, Oregon 97304
.