ML19338C201

NRC Interrogatories & Request for Production of Documents to Dow Chemical Co Re 770118 Presentation to Mi Air Pollution Control Commission.Certificate of Svc Encl

ML19338C201
Person / Time
Site:	Midland
Issue date:	01/27/1977
From:	Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8008050649
Download: ML19338C201 (11)

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1/27/77

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE-ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY Docket Nos. 50-3"9 50-330 (Midland Plant, Units 1 and 2) l NRC STAFF INTERR0GATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO DOW CHEMICAL COMPANY i-:7-17 i

Pursuant to 10 C.F.R. !2.740b and 10 C.F.R. 12.741, the following inter-l rogatories and requests for production of documents are directed to Dow f

Chemical Company.

Ea'ch interrogatory is to be answered separately and

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fully in writing, under oat!' or affirmation by an employee of Dow Chemical Company having personal knowledge of the answers. These responses to L

l interrogatories and requests for production of documents shall be served i

no later than 14 days after service of the interrogatories and request l-

~ for' production lof documents.

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' 1.. With' reference to-.Dow's " Presentation to Michigan Air Pollution I

. Control Commission"'of January 18, 1977:

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Describe the operation. and purpose of the Supplementary Control a

. System.(SCS).

.b..0flthe'$31 million'in expenditures required to permit reliable operation:of.your present facilities, how much has been' spent as of. December 31,119767 ~ Provide annual expenditures for the remainder.

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c.

Explain in reasonable detail the basic apreement reached between l

Dow and the MAPCC Staff on January 13, 1977 on those issues which needed to be clarified-in your present Consent Order.

See page 4 of the Presentation.

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d. -Explain in detail the basis for the Dow conclusion that the'only practical alternative available to Dow which would allow Dow to j

meet the emission' regulations of the State of Michigan is to

~ liminate coal as a fuel of the Michigan Division.

See page 4 l

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Will total elimina'.fon of coal as a fuel at the Michigan Division l

aleviate the need for the SCS? Explain.

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What will be Dow's : source of oil for the Michigan Division? Please

. identify suppliers, potential. suppliers, quantities to be supplied,

sulfur content, cost estimates (per barrel) and anticipated

.g escalation rates.-

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In. order to eliminate-coal as a fuel at the Michigan Division, you state you will need to spend $17.million on plant changes.

See L

page. 4'of the Presentation.

If Dow were required to make these plant modifications on an expedited basis, please provide estimates

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Lof'the ' capital-costs. if the modifications were required by January 19787 ' January;19797-t' k k

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h. 'Dow presently burns:about 50% oil at the liichigan Division.

See Chart 1 of the Presentation.

If Dow were required to go to 100%

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cil by_ January.1,1978, please identify Dow's source o oil as l

requestedinInterrogatory1(f)above'.

Provide the same infor-

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mation if Dow were required to go to 100% oil on January 1,1979 i

or January 1, 1980.

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If Dow were required to go to 100% oil as the fuel at the Michigan Division by. January 1,19.78, please provide the estimated yearly fuel cost through 1985. Also provide estimated yearly fuel costs I

for Dow's.present mode of operation through 1985.

Please provide l

the fuel. costs in terms of actual dollars.

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Please identify and quantify any other costs associated with going to=100% oil at the Michigan Division in addition to the p

reliability and _ capital costs and fuel costs identified in the

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. Presentation.

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Please' relate the substance of any meetings with the MAPCC'and/or its Staff and/or the Environmental Protection Agency occurring l-after January 21, 1977 to the NRC Staff on a continuing basis.

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If Dow were required' to go to.100% oil at its. Michigan Division as soon.as possible (before June 1, 1978) and so operate these-facilities through 1984, would Dow undertake to replace these-facilities with more economical fossil fired facilities. on an expeditediba: s? Explain.

2. -For the purpose cf this interrogatory, the steam and electric require--

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ments of Dow to be supplied by the Midland-Nuclear Facility should be taken asLfollows:

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Low pressure Steam (175 psig):-2 million 1bs/hr High pressure steam

-(600psig): 0.4 million lbs/hr Electricity 175 MWe If.these quantities ~ of steam and electricity differ from the quantities -

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1Dow~ intends to take, please indicate the correct quantities and base:your response on them.

a.. Assuming Unit l commenced operation in 1982 at a facility capital

. cost'of $1.67 billion, please-provide the costs to,Dow for steam

' and electricity-under the present contracts with Consumers.

Please-include'all costs to Dow under these contracts and: provide the data in 20 year levelized form separately fo; steam and electricity.

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LAlso include actual costs for the first full' year of operation..

!Ifia reportforJstudy-is relied upon in your response please attach a copy.

L b'., For the equivalent' steam and electric requirements stated above,-

please provide'the estimated costs'to Dow for steam and electrici.ty if:Dow were to construct its own coal. fired facilities for L-operation by 1982.

Indicate the type of facility and type of fuel.

. studied.. Cost components should include c'apital, operating.and maintenance and fuel costs.

Please provide the date for the first

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full year: of operation and in 20 year levelized -form and provide.

I D'ow's ' justification of its return on investment.

If a report or.

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study is relied upon in your response, pleas'e attach.a copy.

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In Dow's-response to.Intervenor's Interrogatory 10, Dow indicated that j

y a. fossil fueled facility to replace its currer.t facilities could be j

constructed by 1981:at a capital cost of $300 million.

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.Please provide in: reasonable detail the basis for these schedule-a.

an'd cost projections.

If. reports or studi_es were relied on,-

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iplease:attachL a copy.

,b. ;Please; provide Lthe~ estimated ' costs to Dow.for steam and electricity -

Fif Dow were to construct the facility-. described in its Answer to;

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iInterrogatory 10 by(1981.

Indicate '.he type' of facility and. type-

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type of fuelistudied.

Please provide the-data forithe firstl full' year.~of operation and in 20 year levelized form and provide Dow's justification -of its return on investment.

Cost components.should includeLcapital, operating and maintenance and fuel costs.

If reports or. studies were relied on, please attache a copy.

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c. -Provide the life Lof plantt1981 present worth cost of the $300 L

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million' fossil fueled facility. identified in response.to Interrogatory.

110.:-Cost components should include capital, operating and l

maintenance and fuel costs.

l Provide the yearly coal cost's used by-Dow'in developing its -

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a.

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. responses.to 2(b), 3(b), and 3(c) above.

Provide the basis for-those coal costs:and-any escalation assumed.

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Provide the yearly. nuclear fuel costs used by Dow in developing its response-to 2(a) above.

Provide the basis for those costs and any h

escalation' assumed.

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_S.:- Please provide in' chronological order. beginning January 1,1976:

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-a.1 A~ listing of!any studies'made bEorcon behalf of Dow regarding 1

I economic comparisons'of-nuclear steam and electricity'for Dow j

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fromthe' Midland

NuclearFacilityversussteam:andelectricity.

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from alternate generating sources.

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For each such study, provide the substance and conclusions of Lthe study.

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If such studiet-were formalized in memoranda or. reports, attach c

copies of'all such studies.

6.

State in reasonable. detail Dow's evaluation of the reliability of _the Midland Nuclear Unit as a steam and electric source vis-a-vis a fossil fueled facility.

7.. State.in' reasonable detail Dow's evaluation of the financial ability:

of Consumers Power Company to_ complete: construction of the Midland.

l-Nuclear Plant as currently' scheduled.

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~Has Dow undertaken any; formal efforts in initiating La project _to L

repla.ce the existing steam facilities with ~ fossil-fired facilities?

Explain.

Please~ inform the NRC Staff. on a continuing basis of any additional efforts or. initiatives taken by Dow to replace the existing-facilities.

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9.

State in reasonable detail Dow's. evaluation of the_ final capital cost.

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'.'for the Midland. Nuclear Facilit'y.

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State;in -reasonable 1 detail Dow's evaluation of the commercial operation

.l dateLfor/both> units'of the' Midland Nuclear. Facility.

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- ll. ; State'in reasonable detail Dow's evaluation of fuel availability for both nuclear fuel and coal.

12.

State'in~ reasonable detail.Dow's evaluation of any potential: adverse action by the Michigan Public Service Commission regarding electricity and steam sales to Dow from the Consumers Midland Nuclear Units.

13.

Provide Dow's evaluation of the analyses presented in Consumer's Environmental Report. Supplement of October 26, 1976 at page 9.5-1 which shows a~ considerable economic advantage to-Dow of taking nuclear steam.and electricity from Consumer's Midland Units.

Does Dow agree or disagree with.the Consumer's-analyses.

Explain.

If reports or-l-

- studies.are relied on in your response, please a+, tach copies.

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-14 ~.. If Dow were under no contractural obligation to-purchase steam an'd electricity from the Midland Nuclear Facility, would Dow still' choose to purchase' steam and electricity from that facility under ' current p

economics =andlcircumstances as perceived by Dow.

Explain.

15.: If.Dow-were assured of a reliable source-of steam and electricity from:

' the Midlan'd.Huclear Facility by the endi of-1984, in what circumstances would Dow consider construction of its-own fossil Lfuel generating

- facilities.

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-16. ' Please ~ provide a copy of-the formal bound report,: Item 8, identified ~

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'initheL0ctober 25, 1976 letter to'the Dow Chemical Company from Black & Veatch,; Consulting Engineers. Also, please provide-any supplements to-that report on a continuing basis.

Respectfully submitted',

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- Richard K. Hoefling Counsel for flRC Staff Dated a't Bethesda,' Maryland this 27th day 'of January,1977 l

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.m UNITED.5TATES OF AMERICA

NUCLEAR REGULATORY COMMISSION' BEFORE THE ATOMIC' SAFETY AND LICENSING BOARD' In the Matter of

)

CONSUMERS POWER COMPANY Docket Nos. 50-329

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50-330 (Midland Plant,: Units 1 and;2)

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CERTIFICATE OF SERVICE I. hereby. certify that copies ~ of '"NRC STAFF INTERR0GATORIES AND REQUEST FOR PRODUCTION 0F DOCUMENTS TO DOW CHEMICAL COMPANY," dated January 27,

.1977 in the above-captioned proceeding have been st;rved on. the. following by deposit in the United States mail, first class or air mail, this 27th

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day of. January. 197.7:

Freder.ic J. Coufal, Esq., Chairman ~

Honorable Curt T. Schneider Atomic Safety.and' Licensing Board Attorney General U. S. Nuclear Regulatory Commission State of Kansas Statehouse

. Washington, D.-C.

20555 Topeka, Kansas' 66612

- Dr. 'J. Venn Leeds,. Jr..

Ms. Mary Sinclair Atomic Safety?and Licensing Board

.5711 Summerset-Street 10807: Atwell -

Midland, Michigan 48640 ll Houston,l Texas 77096-

-l Harold F.1Reis,'Esq.

j Dr. Emmeth A. Luebke Robert Lowenstein, Esq.

Atomic' Safety: and Licensing Board Lowenstein,-Newman, Rais &

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' U.cS. Nuclear Regulatory Commission.

Axelraif

Washington, D. C.

20555

-1025 Conrecticut Avenue Washington, D. C..20036.

Myron M. Cherry, Esq.

. 1 IBM Plaza L F.~Nute, Esq..

Chicago : Illinois L60611' Dow Chemical, U.S.A.

Michigan Division Judd.L. Bacon,--Esqb Midland, Michigan 48640 Consumers' Power CompanyL

'212 West Michigan Avenue-Mr. Steve Gadler 4

Jackson,- Michigan 49201 2120-Carter Avenue St. Paul, Minnesota 55108 j

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1R. Rex-Renfrow, III, Esq..

Atomic Safety and_ Licensing

David J.'Rosso,.Esq..

Appeal Panel

. Isham,, Lincoln & Beale U. S. Nuclear; Regulatory Commission 4

One First -National Plaza

--Washington,.D. C.'~20555-

-Suite'4200 Chicago, Illinois. 60603 Docketing and Service-Section-

. Office of:the Secretary AtomicESafety and Licensing!

U. S. Nuclear Regulatory Commission Board Panel Washington, D. C.

20555.

U. S. Nuclear Reg'ilatory Commission Washington, D.~.C.

20555.

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/ M. v.:f Richard K. Hoefling..

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, Counsel for NRC Staff!

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