ML19350C629

Porter County Chapter Intervenors' First Set of Interrogatories Directed to Util Re Peak Load Demand,Energy Sales & Cost Estimates.Related Correspondence

ML19350C629
Person / Time
Site:	Bailly
Issue date:	03/20/1981
From:	Whicher J PORTER COUNTY CHAPTER INTERVENORS, VOLLEN, R.J. & WHICHER, J.M.
To:	NORTHERN INDIANA PUBLIC SERVICE CO.
References
NUDOCS 8104060484
Download: ML19350C629 (6)

Text

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NUCLEAR REGULATORY COMMISSION ~

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -

MAR 241981 P " l T C!nce ci the SecttEf7 .';

Dessths & Semte In the Matter of )

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NORTHERN INDIANA PUBLIC ) Docket No. 50-367 -l/f g SERVICE COMPANY ) (Construction Permit g '9 (Bailly Generating Station, ) Extension) g / j Nuclear-1) ) q S- Ia/ h APR O 31981 PORTER COUNTY CHAPTER INTERVENORS' FIRST SET OF INTERROGATORIES TO NIPSCO

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Porter County Chapter Intervenors, by their attorneys, %s \ '

pursuant to 10 CFR 52.740b, hereby serve upon Northern Indiana Public Service Company ("NIPSC0") the following Interrogatories

,to be answered separately and fully in writing under oath by its officer ot- agent, within 14 days of the date of service:

1. Please state NIPSCO's peak load demand and energy sales for each of the years 1973 through 1980.

2. For the year 1981, please state NIPSCO's actual energy ,

sales to date plus the projected sales for the remainder of the year, describing in detail on what NIPSCO bases its proj ected sales.

3. Please state NIPSCO's latest projections .of:

(a) annual peak demand, including adjustments due to scheduled outside purchases and sales; (b) energy sales; (c) capacity at time of system peak, including adjust-ments due to scheduled outside purchases and sales; (d) firm and non-firm sales and purchases at time of. peak demand; and 9so.9

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. (e) the resulting system reserve margin for the years 1981 until five years after the Bailly facility is scheduled to come on-line.

4. Please list each unit currently on-line in the NIPSCO system, and state for each unit its power rating (MWe),

primary fuel source, and operating mode (i.e., whether it is a base load, intermediate load or peaking load unit.)

5. Please describe all planned capacity changes on the NIPSCO system, including changes in ratings, retirements, and additions from 1980 until five years after the Bailly facility is . due on-line. .

6. For.each addition to NIPSCO's system identified in your' response to Interrogatory 5, please describe the status

of construction, the plant site, the energy. source, the percentage of completion and the total esticated cost.

7. Please state NIPSCO's estimate,and the basis therefor, of the' current and projected reserve margin requirements needed L

l t'o maintain mi.nimum system reliability.

8. Please state whether there is a need for L

the Bailly facility in the time _ frame proposed and, if so,

- , state'the basis for-the_ answer.

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9. Please give .the following informatio~n for the Bailly L facility:

(a) The sche'duled on-line, commercial operating date

l. and Uhether NIPSC0' expects to meetLthat date.

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. (b) The latest cost estimate, the date that estimate was made, and by whom it was made.

(c) The total expenditures to date, broken down into classifications of:

(1) construction expenses; (2) purchases of equipment;

. (3) engineering expenses; (4) licensing expenses; and (5) all other expenses, describing each expense.

-(d) Those elements of the total expenditures to date that would and those that would not be recovered if constr.uction.of

he Bailly facility. is permanently halted, and the bas is upon hich each element is so identified.

~(e) Estimates and the basis therefor, of the fuel, operation and maintenance costs for the first scheduled year of. operation, expressed in 1981 dollars.

10. For the year 1980, please give a-breakdown of NIPSCO's ^

energy generated by fuel type (l'.e. , coal, oil, gas, nuclear orhydroelectrhc).

11. For each year from 1959 through 1980, please state the total annual sales and revenues for the industrial sector as a 'whole, andLfor each of the industrial activitieg in NIPSCO's service area.

12; ' Please state NIPSCO's sales of electrical energy for each: major class of customer (e.g. , residential, commercial,

-industrial and others), giving the actual sales .for the latest

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available year (stating which year is being used) and the pro-j ected sales for the years 1985 and 1990.

13. Please list, in tabular form, by year, the construction work force required to complete construction of the Bailly facility.

14 Please state NIPSCO's estimate of the origin and the expected availability of the construction work . force.

15. . Please state the fraction of the work force, identified in your response to Interrogatory 14, which is expected to commute.from their permanent residences.

16. Please describe NIPSCO's estimate, and the basis -

, therefor, of the vehicular traffic impacts during the time period of the requested extension.

17. For _the estimated vehicular traffic impact stated -in your response to Interrogatory 16, please state:

(a) The roads and communities that would be affected by this vehicular traffic; and l .(b) .The number of estimated vehicles to and from 3 the Bailly site at the peak of construction activity, and L

[ at that shift change which produces the largest volume of traffic, including the time of that shift change.

18. 'For each road over which NIPSCO expects the vehicular traffic, identified'in your response to Interrogatories 16 and 17, to travel, please:

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. (a) identify the road; (b) state the present average daily traffic on the road; (c) state the capacity of the road and the basis for the estimate of the capacity; and (d) state the estimated average daily traffic for the peak const.ruction period.

19. Please describe NIPSCO's plans for re-routing of traffic, upgra' ding -of the present road capacity, and all other contemplated e.ctions which it will take.to account for the anticipated increase in traffic due to construction of the Bailly plant.

20. NIPSCO's 1980 Annual Report, at p. 26, states: .

"A new cost estimate for the 1989 in-service date will be completed in the spring of 1981." Please give the following information for that cost estimate:

(a) The date by.which NIPSCO expects that cost estimate to be completed; (b) The name and job title of each NIPSCO employee who'is or,will be participating in preparing the cost estimate; (c) For~each person who is or will be participating in_ preparing the cost estimate and who is not an employee of NIPSCO, the name, job title, and empl'ayer of that

-person. .

21. Pl' ease give the following information ' for the person swearing to the answers of these interrogatorie s :

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. (a) Name .

(b) Address (c) Title c (d) Capacity

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22. Please give the following information of each person who has provided or furnished information to the person identified in Interrogatory 21, consulted with that person in the preparation  !

of the responses to these Interrogatories, or otherwise aided j

- in the preparation of the responses :

(a) Name (b) Address .

, (c) Title (d) Number (including subpart) of each Interrogatory with respect to which that' person consulted, aided or provided or furnished information; and (e) the nature of the information or aid furnished.

Dated: March 20, 1981

' Respectfully submitted, Robert J. Vollen Jane M.'Whicher By: -

Jane M. Whicher Attorneys for Porter County Robert J. Vollen Chapter Intervenors Jane M. Whicher 109 North Dearborn Suite 1300-.

Chicago, Illinois 60602 (312) 641-5570

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