ML20031E315
| ML20031E315 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/08/1981 |
| From: | Simpson J KANSANS FOR SENSIBLE ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8110150375 | |
| Download: ML20031E315 (4) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEN.MNG BOARD
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KANSA GAS AND E1.ECTRIC COMPANY, Docket No
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(Wolf Croak Generating Station,
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MOTION BY INTERVENOR, KANSANS FOR SENSIBLE ENf53GY, TO COMPEL DISCOVERY
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The intervenor, Kansans for Sensible Energy (hereiliaf ter referred cs to as "KASE"), moves that the Chairman of the, pandl of the Atomic Safety and
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Licensing Board in this matter compel each of he appI! cants to adequately respond _,
to Interrogatories Nos. 2, 4, 6; 8, 9,11,12,13, 20, An'd 21 (hereaf ter referred to as the " interrogatories") submitted to each of the applicants by KASE on August 19, 1931.
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Attached are the applicants' responses (dated September 24,1981 s
and Septe nber 29,1981) to these and other interrogatories. The responie sets forth
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s the interrogatories as submitted by K ASE.
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In support of this motion KASE states as follows:
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m (a) The answer of each of the interrogatories is no'. complete.
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- (b) Neither Kansas City Power & Light Company or Kansas Electric
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Power Co' operative, Inc. answered th'e interrogatories. The only answer provided for them was by Gene P. Rathbun, an employee of Kansas Gas & Electric s
a Company. An employee of Kansas Gas & Electric Company is not qualified to respond for Kansas City Po'wSr & l.ight Company or Kansas Electric Power Cooperative. inc. He does not havh (Efficient knowledge of their aff airs to ar.swer 3
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for them. Separate answers were requested by K ASE.
sN ek (c) The answer to each interrogatory is incomplete because reie-s vant and related information for one or more of the parts of each interrogatory
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Jm possession of or known to the applicant The applicants' responses as set forth in the attachments show the parts of each interrogatory that the applicants did
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askedqach applican,t to identify documents related to each interrogatory. In its request, K ASE defined documents as follows: " memorandums, finanhialitatements, schedules, exhibits, reports, letters, agreements, contracts, finarnpal'or other work papers, or"other writings in custody of or prepared by v
each of the app}icants or,its officers and.emp'loyees." Each applicant knows or should kn'ow of documents not icientified in the response to the interrogatories.
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Specifically, bat et exclusively', each applicant has financial and accounting work papers that rda\\tevo the interrogatories and make financial estimates for 3
>-l py future years.. These have not been disclosed.
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K ASE asks that the Chairman of the Licensing Board in this matter order each of the applicants to respond separately, adequately, and completely to the interrogatories and set forth the manner and date by which the applicant shall make such response. A proposed form of order is not attached; however, the undersigned will submit such an order if requested by the Chairman to do so.
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Mn M. Simpson Attorney for Intervenor, Kansans for Sensible Energy fr 4400 Johnson Drive, Suite 110 Shawnee Mission, Kansas 66205 Telephone: (913) 384-9144 October /4,1981 44 f
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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KANSAS GAS AND ELECTRIC COMPANY, )
Docket No. 50-482 et. al.
)
)
(Wolf Creek Generating Station,
)
Unit No.1)
)
I hereby certify that copies of Motion by Interveror, Kansans fo. Sensible Energy, to compel discovery (dated October 8,1931)in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, on October 8,1981.
SERVICE LIST James P. Gleason, Esq., Chairman Atomic Safety and Licensing 513 Gilmoure Drive Board Panel Silver Spring, MD 20901 U.S. Nuclear Regulatory Commission Washington, D.C.
20535 Dr. George C. Anderson Department of Oceanography Docketing and Service Section University of Washington Office af the Secretary Seattle, Washington 98195 U.S. Nuclear Regulatory Commission Washington, D. C.
20535 Dr. 3. Venn Leeds 10807 Atwell Eric A. Eisen, Esq.
Houston, Texas 77096 Birch, Horton, Bittner & Monroe 1140 Connecticut Avenue, N.W.
Treva 3. Hearne, Esq.
Washington, D.C.
20036 Assistant General Counsel P. O. Box 360 Kent M. Ragsdale Jefferson City, Mo.
65102 General Counsel Missouri Public Service Commission Jay Silberg, Esq.
P. O. Box 360 Shaw, Pittman,Potts & Trowbridge Jefferson City, Missouri 65102 1800 M Street, N.W.
Washington, D.C.
20006 Myron Karman Deputy Assistant Chief Hearing Counsel Office of the Executive Legal Director Nuclear Regulatory Commission Atomic Sfety and Licensing Washington, D.C.
20555 Appeal Board U.S. Nuclear Regulatory Commission C. Edward Peterson, Esq.
Washington, D.C.
20553 Assistant General Counsel Kansas Corporation Comrrission State Office Bldg.
Topeka, KS 66612
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" John M. Simpson
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September 29, 1 UNITED STATES OF AMEFICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
KANSAS GAS AND ELECTRIC CCMPANY
)
Docket No. 50-482 et al.
)
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
APPLICANTS' FURTHER RESPONSES TO FINANCIAL QUALIFICATIONS DISCOVERY REOUESTS-OF INTERVENOR KASE Interrogatory 6 6.
(a)
What are the applicant's estimetes of revenues, fuel costs, depreciation, income taxes, net income before and after taxes, new loans, loan payments, amounts and terms of bond issues, and amounts and terms of common and preferred stock issues for each of the following years: 1981, 1982, 1983, and 1984?
(b)
State if the applicant has any documents releting to (e) and identify them.
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Response
KG&E 6.
(a)
Estimates for these parameters are available for 1981 and 1982.
At this time, KG&E does not have similar projections for 1983 and 1984.
These values are as follows (in S000's):
1981 1982 Revenues
$304,395 5330,898 Fuel Expense 125,979 145,868 Depreciation 26,775 27,563 Income Tax 5,764 3,404 Net Income--Before Ta.7 66,640 76,757 Net Income--After Tax 60,876 73,353 The above estimates reflect conditions which were current as of the first quarter of 1981.
Circum-
- tances and assumptions may presently not be tFe same.
KG&E's new financing, to date hereof, for the year 1981 is as follows:
$25 million Banker's Acceptance Facility; $30 million $15.50 Serial Preferred Stock issuance; 2 million shares of Common Stock, representing $27.44 million; S30 million, 14 7/8% Series First Mortgage Bonds; S30 million Letter-of-Credit backed commercial paper fecility; and e $10 million, unsecured, 5 year promissory note at 18% per annum.
A loan redemption schedule for current indebtedness is attached.
As to other future financings, KG&E anticipates additional financing will be needed; however, the types, emounts and t m
4 timings of subsequent financings will depend on market conditions, adequacy of future rate relief and other factors effecting financial position and results of operations.
(b) 1981 and 1982 Budgets, approved as of February 14, 1981; Attached Preferred Stock and Bond Redemption Schedule; Closing documents perteining to new financing.
KCPL 6.
(a)
Estimates for these parameters are available for 1981 and 1982.
At tnis time, we do not have similar projections for 1983 and 1984.
These values are as follows (in $000's):
1981 1982
~~
Revenues
-$ 4 6 9,8 5 8
$502,664 Fuel Expense 157,506 171,603 Depreciation 45,568 46,621 26,133 18,420 Income Tax Net Income--Before Tax 80,614 69,126 Net Income--After Tax 54,481 50,706 Net Change in Bank Loens (7,500) 32,000 Bonds--Issued Anount 50,000 40,000
--Interest Rate 14%
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--Maturity 30 yr.
30 yr.
Com. con Stock--Issued Amount S 42,000
$ 42,000
--Dividend /Shere S
2.78 2.78
--Price / Share 20.00 21.34 Preferred Stock--Issued Amount None None
--Dividend / Share
--Price / Share (b)
Mr.
F.R.
Pendleton's Exhibit No. 11, Schedule 3 in Missouri Case No. ER-81-42 and Exhibit No. 11, Schedule 3, in Kansac Case No. 127,486-U.
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KEPCo 6.
(a)
Wolf Creek will be KEPCo's first generating plent and 4
it is scheduled for service in 1984.
Until thet time, KEPCo will have no fuel cost, deprecietion or other operating expenses associated with plant ownership.
Estimates of total revenue for KEPCo are not available.
Based on the assumption that Wolf Creek will commence commerciel operation on June 1, 1984, and KEPCo's ownership share will be 195.5 megawatts, KEPCo estimates that, for the calendar year 1984, depreciation will be S5,731,623 and fuel costs will be S4,452,583.
Estimeted income tex is not available.
Presently KEPCo has a loan appli-cation pending before REA for S443,600,000.
We do not anticipate any loan repeyments in 1984.
(b)
KEPCo's response is based on feesibility studies performed by Southern Engineering Company of Georgia in 1980, with the essumption that KEPCo would purchase a 17% interest in Wolf Creek Genereting Station, Unit No. 1, witi. a construction cost of 51.7 billion and an interest rete of 121.
Any deviation from the facts assumed in the studies will affect the applicability of the studies' findings.
An addi-tional feasibility study is now ongoing which will impact the responses to this interrogatory.
KEPCo Loen Application to REA.. _ -
Interrogatory 8 j
8.
(a)
Describe in detail for the applicant's corporetion the applicant's estimates for each of the yeers 1985
- 1995 of the following: (1) revenues from the sale of electricity;.(2,) cost of coal, naturel gas, and uranium fuels; (3) interest rates for new bonds to be issued by the applicant and interest rates for any I
loans made to finance operations or construction; -(4) operating costs other then fuel costs, interest, i
depreciation, and texes; (5) book depreciation and income tax deprecietion; (6) interest expenses; (7) income taxes; (8) net income before and after income taxes;~(9)* peak loads; (1.0) ennual rete of inflation used in prepering the estimates; (11) amount of i
electricity rate increase requests; (12) expenditures for new plent and transmission construction (List each plant); ' ' ?'
book value.of electric genereting facilities retired from service; ( 14,), cash proceeds
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t from common stock issue;, ({6 cesh proceeds'from issuance of bonds; (17) cash proceeds from loans; j
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payments to retire loans and bonds; (19) number of kilowatts of electricity sold.
(b)
Stete if the applicant has any documents releting to (a) and identify them.
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Response
KG&E 8.
(a)
With regard to 8(a)(1), (3) through (8), (10), (11),
(12), (14), (17), and (19), KG&E presently has no current estimates available due to rapidly changing circumste.nces and economic conditions.
KG&E is presently reevaluating these areas with regard to future forecasts.
At such time as the,information is available, it will be made available for review by counsel for Intervenor.
It is anticipated that such forecasts will not reflect conditions beyond approxi-mately 1990.
Certain information included in the forecasts may be proprietcry in nature and require appropriete protective orders.
l (2)
The costs of coal, natural gas, end uranium fuels for the years 1985 to 199b are found in ER
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lable 1.1-32.
(9)
KG&E peak load estimates for the years 1985 to 1990 are found in ER Table 1.1.-l.
(13) No generating facilities are scheduled for retirement during 1985 - 1990.
(18) As to redemption schedules for current indebtedness, see KG&E's response to Tnterrogatory 6.
(b)
Wolf Creek Generating Station, Unit No.
1, Environmentel Report (Operating License Stage) 6-
("ER"), a copy of which has been provided to counsel i
for Intervenor under separate cover.
Redemption schedule provided in response to Interrogetory 6 with regard to (e)(18).
See response to Interrogatory 18(b) with regard to (e)(13).
KCPL 8.
(a)
This data is presently undergoing revision.
At such i
time es estimates become avellable, they will be provided for review by counsel.,for Intervenor.
(b)
Not applicable..
KEPCO
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8.
(e)
(1)
Not availebic.
1, (2)
See Table 1, atteched.
(3)
Interest rates were estimated to range from 10 to 14 percent.
(4)
See Table,1.
(5)
See Table 1.
l (6)
See Table 1.
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(7)
Not avellable.
(8)
Not available.
(9)
See Table 4, e copy of which hes been provided
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to counsel for Intervenor under separate cover.
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-(10) Inflation rates were estimated to range from 6 to 15 percent.
l (11) Not evallable.
(12) Not available.,
(13) Not available.
(14) Not epplicable.
(15) Not applicable.
(36) Not available.
(17) S443,600,000.
o (18) See Table 1.
(19) See Table 3, a copy of which has.been provided to counsel for Intervenor under separate cover.
(b)
See KEPCo response to Interrogatory 6(b).
Interrogatory 9 9.
(e)
List the applicant's estimates of the following for the plant for each of the years 1985 - 1995:
(1) revenues from sales of electricity produced at the plant; (2) fuel costs for the plant; (3) a listing of the amounts of other operating costs of the plant; i
(4) kilowatts of electricity sold from electricity produced et the plant; (5) the percentege of cepacity the plant was operating; (6) the cost per kiJowatt of electricity produced at the plant; (7) the charges per kilowatt to customers for electricity produced et the plant.
(b)
State if the applicant has any documents relating to (a) and identify them.
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Response
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KG&E and KCPL 9.
(a)
Information developed for KG&E and KCPL only exists in the ER, for the year 1987, except as noted below.
Independent of the ER effort, KEPCo and its consult-i l
ents developed feasibility studies concerning its involvement in the Wolf Creek project which contained some of the information requested for the years 1985
- 1995.
The assumptions on which these two estimetes were based may not be consistent.
(1)
Estimated revenues are given in Tables 8.1-1 and 11.1-1 for KG&E, KCPL, and KEPCo.
(2)
Estimated Wolf Creek fuel costs in mils per kilowatt hour at 65 and 75% capacity factor are given in Tebles 8.2-2 and 13.2-2.
Projected nuclear fuel costs in cents per million ETU for KG&E and KCPl are given in Table 1.1-16 for 1985 and 1990, and Tab ~e 1.1-32 end 33 for 1985 through 1990.
These later costs are based on e 70% plant cepacity factor.
(3)
Estimated operating costs et Wolf Creek are given in Sections 8.2 end 11.2 and Tables 8.2-2 and 11.2-2.
(4)
Estimeted plent output over e renge of cepacity factors is given in Section 8.1 and Tables 8.1-1 and 11.1-1 for 1985, 1986, and 1987. _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
(5)
See responses to (2) and (4) ebove.
(6)
The estimated cost of producing electricity et Wolf Creek is discussed in Sections 8.2 end 11.2 and Tables 8.2-2 and 11.2-2.
(7)
The information requested is not available since such costs are not calculated on a per plent l
basis.
In addition, see the responses of KG&E end KCPL to Interrogatory 8(a).
('b )
The ER, which has been provided to counsel for s
Intervenor under separate cover.
KEPCo 9.
(a)
The 1980 feasibility study was updated to reflect current estimates.
Table 1, etteched, reflects the presently available information.
(1)
See KG&E ond KCPL's response.
(2)
See Table 1.
(3)
See Table 1.
(4)
See Table 1.
(5)
See KGGE end KCPL's response.
Table 1 values are based on a 75% capacity fector.
(6)
See KG&E and KCPL's response.
(7)
Not available.
(b)
The ER has been provided to counsel for Intervenor g.
under separete cover.
Table 1, ettached.,
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
KANSAS GAS AND ELECTRIC COMPANY
)
Docket No. 50-482 et al.
)
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
AFFIDAVIT OF GENE P.
RATHBUN State of Kansas
)
- ss County of Sedgwick
)
GENE P. RATHBUN, being duly sworn according to law, deposes and says that he is the Manager-Licensing of Kansas Gas and Electric Company, and that the information contained in
' Applicants' Further Responses To Financial Qualifications Dis-covery Requests of Intervenor KASE" is true and correct to the best of his knowledge and belief.
Gene P.
Rathnun Manager-Licensing Subscribed and sworn to before me this day of September, 1981.
Notary Public My Commission Expires:
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September 29, 1981 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 7n the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY
)
Docket No. 50-487 et al.
)
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Further Responses To Financial Qualifications Dis'covery Requests of Intervenor KASE" were served upon those persons on the ettached Service List by deposit in the United Stetes mail, postege prepaid, this 29th day of September, 1981.
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Dated:
September 29, 1981 2
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UNITED S"ATES OF AMERICA NUCLEAR REGULATORY COMMISSION Sefore the Atomic Safety and Licensing Board In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY, e_t _a_l.
)
Docket No. STN 50-482
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
SERVICE LIST James P.
Gleason, Esquire I
Kent M. Ragsdale Chairman General Counsel 513 Gilmourc Drive Missouri Public Service' Commission Silver Spring, Maryland 20901 P.O. Box 360 Jefferson City, Missouri 65102
.Dr.
George C.
Anderson Department of Oceanography Treva J. Hearne, Esquire University of Washington Assistant General Counsel Scattle, Washington 98195 Missouri Public Service Ccmmission P. O. Box 360 L_.
J. Venn Leeds Jefferson City, Missouri 65102 10807 Atwell Ecuston, Texas 77096 Eric A.
Eisen, Esquire Birch, Horton, Bittner & Monroe Myron Karman, Esquire 1140 Connecticut Avenue, N. W.
Deputy Assistant Chief Washington, D.
C.
20036 Hearing Counsel Office of the Executive C. Edward Peterson, Esquire Legal Director Assistant General Counsel U.
S. Nuclear Regulatory Commission Kansas Corporation Commission Washington, D.
C.
20555 State Office Building - 4th Floor Topeka, Kansas 66612 Atomic Safety and Licensing Board 15 U. S. Nuclear Regulatory Commission John M. Simpson, Esquire Washington, D.
C.
20555 4400 Johnson Drive Suite 110 Atomic Safety and ' Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Docketing and Service Section C ' ice of the Secretary L
- 3. Nuclear Regulatory Commission Washington, D.
C.
20555
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REDEMPT10f1 SCllEDULE -
Ref.
Ref.
Ref.
Year Preferred No.
Bonds N o'.
Other No.
To t.il
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(000,000)
(ob0,060)
(000,000)
(000,000) 1981 1
1 1
1982 1
1 12 10 13 1983 1
1 50.5 11 51.5 1984 1
1 1
1985 16 2
10 12 26 1986 3
3 7
13 10 1987 12 4
36 14 48 1988 8.5 5
6 15 14.5 1989 8.8 6
6 15 14.8 1990 7.3 7
6 15 13.3 1991 7.3 7
13 16 20.3 1992 1.3 8
1.3 1993 1.3 8
1.3 1994 1.3 8
1.3 1995 1.3 8
1.3 1996 1.3 8
16 17 17.3 1997 1.3 8
1.3 1998 1.3 8
1.3 1999 1.3 8
1.3 2000
.3 9
35 18 35.3 2001
.3 9
35 19 35.3 2002
.3 9
25 20 25.3
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2003
.3 9
.3 2004
.3 9
14.5 21 14.8 2005
.3 9
40 22 40.3 2006
.3 9
25 23 25.3 2007
.3 9
56.9 24 57.2 2008
.3 9
30 25-30.3 2009
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l REFERENCE INF0101AT10N FOR REDDtPTION SCllEDULE i
referred-1.
$?.42 Preferred Sinking Fund Redemption of 40,000 shares at $25/sharc 4
($1 million).
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2.
$2.42 Preferred Sinking Fund Redemption of 40,000 chares at $25/sharc
($1 million).
Total Redemption of $8.00 $crics Preferred ($15 million).
3.
$2.42 Preferred Sinking Fund Redemption of 40,000 shares at $25/sharc
($1 million).
Sinking Fund Redemption of 20,000 shares of the $S.25 Series Preferred ($2 million).
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4.
$2.42 Preferred Sinking Fund Redemption of 40,000 shares at.$25/sharc i
- ($1 million).
Sinking Fund Redemption of 50,000 shares of the $8.25 Scrics Preferred ($5 million).
Sinking Fund Redemption of 60,000 shares n
of.the $15.50 Series Preferred ($6 million).
5.
$2.4'2 Preferred Sinking Fund Redemption of 40,000 sharcs at $25/sha're
($1 million).
Sinking Fund Redemption of 15,000 shares of the $8.25 l
Series Preferred ($1.5 million).
Sinking Fund Redemption of 60,000 i
shares of the $15.50 Series Preferred ($6 million).
6.
$2.42 Preferred Sinking Fund Redemption of 40,000 shares at $25/ share i
($1 million).
Sinking Fund Redemption of 15,000 shares of the $8.25 Series Preferred ($1.5 million).
Sinking Fund Redemption of 60,000 1
sberes of the $15.50 Series Preferred ($6 million).. Sinklug Fund Redemption of 3,333 shares of $8.125 Series Preferred ($333,300).
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7.
$2.42 Pr ef erred Finking Fund Redemption of 40,000 shares at $25/sharc
($1 million). -Sinking Fund Redemption of 60,000 shares c f the $15.50 l
Scrics. Preferred ($6 million).
Sinking Fund Redemption of 3,333 shares of $8.125 Series Preferred ($333,300).
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8.
$2.42 Preferred Sinking Fund Redemption of 40,000 shares at $25/sharc
($1 million).
Sinking Fund Redenption of 3,333 shares of $8.125 Series j
Preferred ($333,300).
+
9.
Sinking Fund Redemption of 3,333 shares of $8.125 Scrics Preferred f
($333,300).
Bonds 10.
Retirement of 3 3/8% Series ($12 million).
11.
Retirement of 3 5/8% Series ($10 million).
Refunding of 11ur11a;; ton Pollution Control Bonds 7 1/4% Series should be reissued for 27 more i
years ($25.5 million.
Retirement of Wamego Pollution Control Bonds 6 1/2% Series may be able to be reissued for 27 more years (515.0 mittion).
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Bonds 12.
Retirement of 3 3/8% ScritIs ($10 million).
13.
Retirement of 3 3/8% Series ($7 million).
14.
Retirement of 16 1/4% Series ($30 million).
Sinking Fund Redemption of 14 7/8% Series ($6 million).
15.
Sinking Fund Redemption of 14 7/8% Series ($6 million).
16.
Sinking Fund Redemption of 14 7/8% Series ($6 million).
Retirement of 4 5/8% Series ($7 million).
17.
Retirement of 5 5/8% Series ($16 million).
18.
Retirement of 8 1/2% Series ($35 million).
19.
Retirement of 8 1/8% Series ($35 million).
20.
Retirement of 7 3/8% Series ($25 million).
21.
Retirement of 6.8% Series ($14.5 million).
22.
Retirement of 9 5/8% Series ($40 million).
23.
Retirement of 8 3/8% Series ($25 million).
24.
F.ctirement of 8 1/2% Series ($25 mf 111or.).
Re t irennen t of 6% Series
($10 million).
Retirement of 5 7/8% Series ($21.9 million).
25.
Retiremcat of 8 7/8% Series ($30 million).
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TABLE 1 KANSAS ELECTRIC ?OWER COOPERATIVE, INC.
Estimated Costs for Wolf Creek Unit #1 1985 1986 1987 1988 1989 Energy Generated - GWII 941.9 1,133.7 1,286.1 1,279.3 1,281.0 Interest Payment 12% $(000) 47,163.1 47,163.1 47,163.1 47.163.1 47,163.1 f
Principal Payment $ (000) 0, 0
0 0
0 Depreciation $(000) 15,721.0 15,721.0 15,721.0 15,721.0 15,721.0 Insurance $(000) 2,004.4 2,004.4 2,004.4 2,004.4 2,004.4 Taxes $(000) 6,760.0 6,760.0 6,760.0 6,760.0 6,760.0 Fixed 0 & M $ (000) 1,208.0 1,292.0 1,382.0 1,478.0 1,582.0 A& G Expense $(000) 705.0 783.0 839.0 899.0 962.0 f
Working Capital $ (000) 135.7 169.4 199.9 211.2 228.3 Materials & Supplies $(000) 599.6 599.6 599.6 599.6 599.6 Fuel Cost $(000) 6,819.0 8,809.0 10,597.0 11,155.0 72,093.0 Variable 0 & M $(000) 422.7 566.8 694.5 742.0 794.2 4
9 es
Pego 2
-t TABLE 1 KANSAS ELECTRIC POWER COOPERATIVE, INC.
Estimated Conts for Wolf Creek Unit il 1990 1991 1992 1093 1994 1995 Energy Generated - GWH 1,281.0 1,281.0 1,281.0 1,281.0 1,281.0 1,281.0 I
Interest Payment 12% $(000) 47,163.1 47,163.1 46.915.8 46,638.8 46,388.5 45,981.1 Principal Payment $(000)
G
-2,066.0 2,308.2 2,585.1 2,835.5 3,242.9 Depreciation $(000) 15,721.0 15,721.0 15,721.0 15,721.0 15,721.0 15,721.0 Insurance $ (000) 2,004.4 2,004.4 2,004.4 2,004.4 2,004.4 2,004.4 Taxes $(000) 6,760.0 6,760.0
'6,760.0-6,760.0 6,760.0 6,760.0 Fixed 0 & M Cost $(000) 1,693.0 1,812.0 1,939.0 2,074.0 2,219.0 2,373.0 A& G Expense $ (000) 1,027.0 1,102.0 1,179.0 1,260.0 1,349.0 1,443.0 Working Capital $ (000) 255.3 306.4 362.1 418.7 459.5 503.7 Materials & Supplies $(000) 599.6 599.6 599.6 599.6 599.6 599.6 Fuel Cost $(000) 13,694.0 16,781.0 20,381.0 23,289.0 s26,376.0 29,040.0 Variable 0 & M $(000) 845.5 909.5 973.6 1,037.6 1,114.5 1,191.3 i-r
4,. w..h
~w Sep r 24, 19 b6 h!
\\v i I6
, 'O g#
[p,Lgl9th-8C I
UNITED STATES OF AMERICA g+t a
-7 NUCLEAR REGULATORY COMMISSION 0
i s,aN' f
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
KANSAS GAS AND ELECTRIC COMPANY,
)
Docket No. 50-482 et. al.
)
)
(Wolf Creek Generating Station,
)
Unit No. 1)
)
l 1
I l'i APPLICANTS' RESPONSES TO FINANCIAL QUALIFICATIONS fl l
DISCOVERY REQUESTS OF INTERVENOR KASE b,I l
Interrogatory 1 1.
(a)
What is the current estimated date of completion for 1
+
the plant and the current estimated date it will be l
fully operational?
(b)
State if the applicant has any documents relating to t
(a) and. identify them.
Response
j' l.
(a)
The present estimated completion date and full operation date for the plant is mid-1984.
l' 1
i-i; ue o' n
I O
E W:
p s
- 1980, G. Koester to D. Eisenhut.
Letter of October 8, (b)
Letter of June 18, 1981, W. Cadman to B. Denton.
1981, W. Cadman to B. Denton.
j Letter of September 15, Interrogatory 2 What is the estimated final cost of the plant and how 2.
(a)
Explain in detail.
is this amount calculated?
i if the applicant has any documents relating to
/
(b)
State (a) and identify them.
Response _
The present estimated final construction cost of the 2.
(a) is approximately 1.7 billion dollars.
plant t
The above-estimated cost is based upon current budge estimates and calculated in conformity with Sections 1
of the Wolf Creek Generating Station,
')
g and 11 Environmental Report (Operating License Unit No.
1, a copy of which is being provided to Stage)("ER"),
counsel for Intervenors under separata cover.
l 1,
Wolf Creek Generating Station, Unit No.
(b)
Stage).
Environmental Report (Operating License
~
for review by other documents will be made available f
fices.
counsel for intervenors in KG&E's Wichita of Interrogatory 3_
t and Provide a copy of your latest annual financial repor l
3.
interim financial report.
your latest Response _
Kansas City Kansas Gas and Electr ic Company ("KG&E"),
3.
3,j and Kansas Electric Power Light Company ("KCPL")
Power &
... T
y s
Cooperative, Inc. ("KEPCo") are providing their annual reports for'1980 to counsel for Intervenors under separate cover.
KG&E and KCPL are also providing their latest interim reports.
KEPCo does not have an interim report.
Interrogatory 4 4.
(a)
Do you contemplate the sale of all or any part of any electric generating facility in which you own an interest at the present time?
(b)
If the answer to (a) is yes, describe in detail any such contemplated sale.
(c)
State if the applicant has any documents relating to (a) and (b) and identify them.
Response
KG&E (a)
Yes.
(b)
(i)
KG&E and KCPL have agreed to sell KEPCo a 17%
(8.5% from each) ownership interest in Wolf Creek Unit No.
1.
The sale is subject to receipt of regulatory approvals and KEPCo's permanent financing.
(ii) KG&E and KCPL are presently negotiating with the Kansas Municipal Energy Agency, Inc. ("KMEA")
for the possible sale to KMEA of a 9% (4.5% from each) ownership interest in Wolf Creek Unit No.
1, and a 4% (2% from each) ownership interest in LaCygne Units #1 and #2.
These KMEA percentages i
l
/
represent up to 103.5 MW of Wolf Creek and up to 54.8 MW of LaCygne Station.
f (iii) Kansas Gas and Electric Company is present.ly i
negotiating the sale of KG&E's 20% ownership in
{
Jeffrey Energy Center, Unit 3 ("JEC 3"), with i
the other co-owners.
i (c)
(i)
Sale Memorandum dated April 19, 1979, bet. ween 8
KG&E and KCPL.
(ii) Letter from KG&E and KCPL to~KMEA dated November i
I 7, 1980, confirming intent of KG&E and KCPL to I
negotiate a sale.
(iii) Letter of June 11, 1981.
W.
Cadman to co-owners regarding intent to sell JEC 3.
(
KCPL 4.
(a)
Yes.
/
(b)
(i)
KG&E and KCP,L have agreed to sell KSFCo a 17%
(8.5% from each) ownership interest in Wolf I
Creek Unit No. 1.
The sale is subject to l
receipt of regulatory approvals and KEPCo's I
permanent financing.
l (ii) KG&E and KCPL are presently negotiating with l
KEMA for the possible sale to KMEA of a 9% (4.5%
from each) ownership interest in Wolf Creek Unit h
No. 1, and a 4% (2% from each) ownership interest in LaCygne Units #1 and #2.
These KMEA f
I percentages represent up to 103.5 MW of Wolf Creek and up to 54.8 of LaCygne Station.
4 -
l (c)
(i)
Sale Memorandum dated April 19, 1979 between KG&E and KCPL.
(ii) Letter from KG&E and KCPL to KMEA dated November 7,
1980 confirming Intent of Applicants to negotiate a sale.
KEPCO 4
4.
(a)
No.
i.
(b)
Not applicable.
(c)
Not applicable.
Interrogatory 5 5.
(a)
To what extent is the Kansas City Power and Light Company Iatan Plant now included in its rate base?
(b)
When will such plant be fully included in the rate base?
(c)
State if the applicant has any documents relating to (a) and (b) and,, identify them.
Response
5.
(a)
A complete description of the rate base treatment for Iatan is given in KCPL's most recent Missouri rate order.
This is being provided to counse' for Intervenors in connection with the response to Interrogatory 10.
(b)
KCPL does not know when Iatan will be fully included in its Missouri jurisdictional rate base.
(c)
See MPSC Rate Order for Case Docket No. ER-81-42.
Interrogatory 6 6.
(a)
What are the applicant's estimates of~ revenues, fuel costs, depreciation, inccme taxes, net income before 4
Y
/
a-
/'
. 'a'nd after taxes, new' loans, loan payments, amounts and terms of bond issues, and amounts and terms of common and preferred stock issues for each of the j
following years: 1981, 1982, 1983, and 19847 (b)
State if the applicant has any documents relating to (a) and identify them.
Response
6.
Applicants are in the process of preparing their response, which sill be provided in the near future.
Interrogatory 7 7.
(a)
When will the sale of the interest in the plant to Kansas Electric Power Cooperative, Inc. (KEPCo) be completed?
(b)
When will KEPCo have the funds available to complete the purchase?
(c)
What ef fect wi'll a failure of REPCo to complete the purchase of its interest in' the plant have upon the financial affairs of the applicant?
(d)
Describe any platic made to deal with the situation arising if KEPCo is not able to complete the purchase of the plant.
(e)
Describe the status of the efforts of KEPCo to meet each of the requirements for the purchase of the plant set forth in the Kansas Corporation Commission Order dated October 22, 1980, Docket No. 120,783-U.
(f)
State if the applicant has any documents relating to (a - e) and idenpify them..
~
Response
s KG&E
,.,j 7.
(a)
Completion of the sale to KEPCo is conditioned upon y
KEPCo acquiring necessary regulatory approvals and long-term financing.
No definitive date has been determined for the completion of the sale At this
.[
timp.,
(c)
The failure of KEPCo to complete the purchase would require KG&E to finance an additional 8-1/2% interest
~~
of the Wolf Creek Plant and would result in an
~
increase in 1982-1985 construction expenditures, including nuclear fuel, in the amount of approxi-mately $60 million as Et'ated on page 6 of the April 2,
1981 Common Stock Prospectus being provided in response to Interrogatory 15.
The Company would be required to repay the KEPCo advances plus interest which, as of August 31, 1981, amounts to approxi-raately $91. 6 million, including cash advances and
\\;
interest.
(d)
The obligation to repay KEPCo, should the 5 ale by KG&E to KEPCo not be completed, is secured by a $100 million banl: line which could be utilized to repay the, obligation..
(f)
KG&E's 1980 annual report to shareholders; 1981 10-K; 1981 10-Q; Loan Agreement dated October 3, 1978 and amended' October 1, 1980; Letter dated February 12, i
s, c
t
- 1981, B.
Hansen to Irving Trust Company regarding s
Loan Agreement as security.
KCPL s
7.
('c )
KCPL will have te>. finance another 8.5% of the Wolf Creyk Plant at ali estimated total cost of $134 e
.u.
N mil, lion including capitalized interest and property taxes.
An addjtional S17 million in nuclear fuel costs wi11 also have to be financed fo fuel expendi-turesh nd capitalized interest and property taxes
,,x J.
thrqogh 1985.
As of' August 31, 1981, the refund N
s.
li'abilI}.y amountis to $105 million including cash radvances and interest.
-( d )
KCPL has a loan agreen.dnt with Bankers Trust Company gudranteeing' the refund liability up to S113 million.
.~.
(f) }The Cankers TL)nt Company Loan Agreem5nt and 3
amendments.
i
-l KEPCO 2
7
'tb)
F.EPCo will have ' funds available to complete the (l
p:1rchase upon final approval of the necessary loans i!
's
>l by the REA.
\\
(e)
All recuirements contained in the referenced Kansas
^
l Corporation Commission Order have been appealed to ll the Shawnee County District Court.
Conditions (1),
(2) and (4) on page 41 of the referenced Order were eliminated or modified by the Kansas Legislature in Senate Bill 80.
As to condition (4) the 1
h'
/
Administrator of the REA has determin d that full
~
power requirement contracts are necessary to secure the loan through which KEPCo would finance an interest in Wolf Creek.
Condition (3) on page 41 of the referenced Order has been satisfied.
None of the other conditions in the referenced Order are condi-tions precedent to KEPCo's purchase of an interest in Wolf Creek.
(.f )
Yes, correspondence dated July 15, 1981, from Joe S.
Zoller, Assistant Administrator, REA, to Charles H.
Ellis.
" Kansas County Living", July, 1981, pp. 13-18.
Kansas Corporation Commi,ssion Order date6 July 13, 1981, Docket No. 120,783-U.
Certificate of Compliance filed with. Kansas I
Corporation Commission on August 14, 1981, in Docket I
l No. 120,783-U.
l i
Correspondence from Philip Kassebaum to R.
C.
Loux l
dated July 8, 1981.
Interrogatory 8 8.
(a)
Describe in detail for the applicant's corporation the applicant's estimates for each of the years 1985
- 1995 of the following: (1) revenues from the sale of electricity; (2) cost of coal, natural gas, and uranium fuel s ; (3) interest rates for new bonds to be issued by the applicant and interest rates for any i
I loans made to finance operations or construction; (4) operating costs other than fuel costs, interest, i
depreciation, and taxes; (5) book depreciation and income tax depreciation; (6) interest expenses: (7) income taxes; (8) net income before and after income
![
'.]:l i taxes; (9) peak loads; (10) annual rate of inflation used in preparing the estimates; (11) amount of
[:
l electricity rate increase requests; (12) expenditures for new plant and transmission construction (List l
each plant); (13) book value of electric generating
.lt Il!
facilities retired from service (14) cash proceeds i
from common stock issue; (15) cash proceeds from i
preferred stock issue; (16).' cash proceeds from l
issuance of bonds; (17) cash proceeds from loans; i
(18) payments to retire loans and bonds; (19) number l
of kilowatts of electricity sold.
j (b)
State if the applicant has any documents relating to (a) and identify thcm.
Response
8.
Applicants are in the process of preparing their response, which will be provied in the near future.
i.
Interrogatory 9 9.
(a)
List the applicant's estimates of the following for the plant for each of the years 1985 - 1995: (1) revenues frcm sales of electricity produced at the plaat: (2) fuel costs for the plant; (3) a listing of I l
1 the amounts of other operating costs of the plant; i
(4) kilowatts of electricity sold from electricity producea at the plant; (5) the percentage of capacity l
the plant was operating; (6, the cost per kilowatt of 1
electricity produced at the plant; (7) the charges per kilowatt to customers for electricity produced at the plant.
(b)
State if the applicant has any documents relating to (a) and identify them.
Response
9.
Applicants are in the process of preparing their reponse, which will be provided in the near future.
Interrogatory 10
'9.
(a)
Describe the nature and amount of the applicant's most recent rate relief actions before.any state or i
federal agency.
(b)
Provide copies of the rate order for the action described in (a).
(c)
State in detail the nature and amount of any pending rate relief actions before any federal or state agency.
1 l
(d)
Provide copies of any financial information submitted in connection with (a) or (c).
(e)
Describe in detail any contemplated rate increase l
request that will be filed with any federal or state I
agency between now and December 31, 1986 l
l l '
(f)
Describe in detail the applicant's planning process for current and long term rate increase requests.
(g)
State if the applicant has any documents relating to
-l
- i l!
I (a) - (f) and identify them.
Response
.KG&E 10.
(a)
Docket No. 121,460-U Kansas Corporation Commission Effective 6-1-81, the Company was granted an interim rate increase amounting to $13,872,537.
This is applicable to the Company's retail customars and is being collected subject to refund pending the Commission's final determination in the Company's permanent case which was assigned Docket No.
128,139-U.
Docket No. ER77-578 Federal Energy Regulatory Comminsion The Company received an increase of $1,908,247 l
effective 10-19-79 on its Rural Electric Cooperative customers.
Effective 1-2-81, the Company received an i
increase of $1,315,840 on it s full-requirements and par tidi--requirements municipalities.
(b)
The following orders are being provided to counsel for Intervenor under separate cover:
Docke t No. 121,460-U 5-28-80 ER77-578 letter dated 10-19-79 accepting settlement agreement with rural electric
}
l '
cooperatives 9 ________
O.
I h
ER77-578 Opinion No. 80 3-19-80 i
ER77-578 Opinion No. 80-A 8-21-80 l
ER77-578 Order Accepting Compliance Filing dated l
l-2-81 accepting rates for full-require-
[
t ments and partial requirements municipali-ties.
(c)
Docket No. 128,139-U Kansas Corporation Commission On May 11, 1981, the Company filed a request for an increase in rates to its retail customers of
$63,711,898.
This filing also requested tha t
$13,872,537 granted on an interim basis in Cocket No.
121,460-U be made permanent.
Docket No. ER80-259 Federal Energy Regulatory Commission On February 29, 1980, the Company filed.a request for
.ii' an increase in ra,tes to its municipal customers served at wholesale.
The amount requested was
$2,800,282 for full-requirements municipalities and S750,592 for partial-requirements municipalities.
(d)
Relevant financial information submitted to the KCC or FERC will be provided for Intervenors' coundel's review at KG&E's offices in Wichita.
(e)
A decision has been made to file a federal jurisdic-tional rate case in the last quarter of 1981.
The request will be applicable to the Company's full and partial requirements municipal customers and its i
ur o
l i
rural electric cooperative customers.
Certain of the
- l partial requirement's municipal customers have f) l established Section 206 of the Federal Power Act status with the additional Sierra / Mobile burden of proof and therefore no increase will be requested for those customers.
The amount of the increase to be requested and filing date have not been determined at this time.
(f)
KG&2 does not forecast', specifically, the amounts to be requested as rate increases for current and long term planning.
To date, rate increases filed by the l
i Company have largely been based on the placing in
}
service of high capital cost, coal-fired generation.
1 This type of substantial addition to the Company's l
rate base and the related operating costs, taxes, and depreciation caused an instant deficiency in revenues leading to an immediate need to file for rate relief.,
f For that reason, no detailed procedures for forecast-ing rate increases have been developed or have been necessary.
With the potential slow down in generat-ing capacity additions, future rate requests may be based upon other factors and at that time it is contemplated that procedures for forecasting rate increase requests will be developed.
i (g)
See responses to 10(b) and 10(d).
Relevant documents pertaining to 10(e) will be made available to
- 9. l
Intervenors' counsel for his review in KG&E's Wichita, Kansas offices.
No documents presently l
exist with regard to 10(f).
KG&E is unable to identify other responsive documents in the absence of a more specific request.
I KCPL 10.
(a)
By its Order dated June 17, 1981 in Case No.
ER 81-42, the Missouri Public Service Commission
("MPSC") granted KCPL an increase in retail electric revenue effective July 3, 1981 of approximately $17.2 million or 5.8% of test year (1980) basic revenue.
Of this amount approximately S4. 2 million or $.00068 per kilowatt-hour is subjget to revision pursuant to f
the Stipulation and Agreement on forecasted fuel
'i costs approved in the Report and Orderc (Appendix B).
By its Order dated May 28, 1980 in Docket No.
119,812-U the State Corporation Commission of the State of Kansas granted KCPL an increase in retail l
electric revenue effective June 1, 1980 of approxi-mately S24.5 million or 14.49% of basic revenue plus S.000618 per kilowatt-hour.
Hearings were concluded on September 10, 1981 on the Company's request to increase electric revenue on a permanent basis by
$49.1 million (which includes $24.5 million pre-L viously granted on an interim basis).
To date the Commission has not issued its Order relating to the l
< l l
l
Company's request in Docket No. 127,486-U.
By its Order dated March 10, 1981, the MPSC granted KCPL an increase in steam heat revenue effective March 20, 1981 of approximately S800,000 or 23.7% of (1980) test year revenue.
On January 6, 1981, new wholesale firm electric rates designed to incraase annual revenues by $4.7 million or 32.8%, went into effect, subject to refund, as authorized by the Federal Energy Regulatory Commission (FER:).
The Company's request, based on a test year endir:g May 31, 1981, was filed on June 6, 1981 and includes construction work in progress (CWIP) related to pollution control facilitias.
Also pending with FERC is a request for a $7.4 million increase, which combines the above amount and general CWIP.
Bearings,on these cases have been concluded but to date FERC has not issued an Order relating to these requests.
(b)
Copies are being provided to counsel for Intervenorn under separate cover.
(c)
Missouri -- See transmittal letter, being provided to counsel for Intervenors under separate cover.
I Kansas -- See (a) above.
FERC -- See (a) above.
(d)
These documents will be provided to counsel for Intervenors for review at KG&E's Wichita of fice.
l l
L q
6 9 l
1
,,~,
I (e)
This information cannot be determined at the present I
time.
(f)
See response to 10(e).
(g)
KCPL cannot identify " documents" unless a specific I
document related to a specific subject or topic is j
l requested.
j KEPCO 10.
(a)
On July 23, 1981, KEPCo filed a formal application with the Kansas Corporation Commission seeking approval of initial interim wholesale power rates for various member cooperatives at certain delivery points.
The Kansas Corporation Commission, by order dated July 31, 1981 and, mailed August 3,
- 1981, granted the application subject to certain findings.
(b)
Being _ provided to counsel for Intervenors under separate cover is a copy of this Order dated July 31, 1981 granting the initial interim wholesale power rates.
(c)
At the present, time, KEPCo has no pending rate relief actions before any federal or state agency.
(d)
The financial information submitted to the Kansas Corporation Commission is being provided-to counsel for Intervenors under separate cover.
l (e)
KEPCo is presently preparing wholesale power rates applicable to its member cooperatives.
When com-pleted, this rate case will be filed with the Kansas l
Corporation Commission.
l l
I '
s 8-
m I,
(f)
The Bot 2rd of Trustees of KEPCo at such intervals as l
it shall deem appropriate, but in any event not less l
frequently than once in each calendar year, shall review all applicable rate schedules and/or tariffs.
(g)
Financial information submitted to the Kansas Corporation Commission and the Order from the Kansas i
l Corporation Commission pertaining to the interim wholesale rate dated July 31, 1981.
i Interrogatory-11
(
i 11.
(a)
What is the applicant's estimated and its required I
rate of return on capital and on total assets for the years 1981-1995?
(b)
State if the applicant ha'.s any documents relating to (a) and identify them.
Response
i',
l KG&E
{
11.
(a)
Kansas Gas and Electric Compa~ny has requested a 17 i
1/4% rate of return on equity and an 11.93% rate of j
return on rate base in its current state rate case based upon the year 1980.
It is the Company's belief 1
1 that these rates of return to the Company would i,
continue to be valid, varying from year to year based I
upon then current economic conditions.
No year to g
year estimates are presently available.
The Company
}
cannot determine if and to what extent a regulatory j
body may adopt these rates of return.
i 1 L
r%/
(b)
State rate case filings for Docket No. 121,460-U.
KCPL 11.
(a) and (b)
This data is presently being revised and at
[
!l
[h such time as it is available, the responses will be provided to counsel for Intervenors.
[
t KEPCO
[
r 11.
(a)
KEPCo's estimated return on capital is not available.
KEPCo expects to set rates at least sufficient to pay all operating costs and debt service on loans.
Other f
than that-there is no required return on capital.
l (b)
REA mortgage.
Interrogatory 12 12.
(a)
What is the applicant's ' estimated cost of permanently i
shutting down the plant?
{
(b)
What are the specific costs and assumptions made in eestimating the, cost of the type of shutdown contem-plated, and what are the sources of funds to cover these costs?
(c)
State if the applicant has any documents relating to I
(a) and (b) and identify them.
Response
12.
(a)
Present plans for decommissioning (permanently shutting down the plant) are described in Section 5.8 of the ER.
(t; See (a) above.
l (c)
The ER is being provided to counsel for Intervenors under separate cover.
Other relevant documents are
H available for review by counsel for Intervenors at i
KG&E's Wichita office.
Interrogator'y 13
~
13.
(a)
What is the applicants estimate of 'the annual cost to maintain the shutdown of the plant?
(b)
What specific costs are included in the estimate asked for in (a)?
(c)
What is the source of funds to cover the costs estimated in (a)?
(d)
State if the applicant has any documents relating to (a)-(c) and identify them.
Response
13.
See response to Interrogatory l12.
Interrogatory 14 14.
Provide copies of any agreements the applicant has with other applicants or others settingsforth the procedure by which the applicants will share construction, operating, and decommissioning costs for the plant.
Response
14.
These documents are being provided under separate cover to counsel for Intervenors.
Interrogatory 15 15.
Provide copies of the following: (1) the applicant's most recent prospectus for its most recent bond, preferred stock, and common. stock issues: (2) a copy of the applicant's most recent Securities and Exchange Commission
- 1
Form 10-K; (3) copies of any preliminary prospectus for any pending bond, preferred stock, or common stock issue.
Response
KG&E 15.
KG&E is providing to counsel for Intervenor, under separate cover, documents responsive to (1) and (2).
KG&E has no pending bond, preferred stock, or common stock issue.
l 15.
KCPL KCPL is providing to counsel for Intervenor, under i
separate cover, documents responsive to (1) and (2).
KCPL is also providing, under separate cover, a copy of the prospectus for its pending bond issue.
KCPL has no pending preferred or common stock issue.
15.
KEPCO i
KEPCo does not have any of the requested documents.
{
l Interrogatory 16 16.
(a)
Provide a copy of the most recent Form 1 of the Federal Energy Regulatory Commission filed with that commission.
i.
(b)
Provide a copy of the most recent Form 12 of the i
Federal Energy Regulatory Commission filed with that
!j I:
i commission.
[l (c)
Provide a copy of the most recent Form 423 of the l;
Federal Energy Regulatory Commission filed with that al
{!l commission.
i (d)
Provide o copy of the latest company testimony and exhibits submitted to the Federal Energy Regulatory Commission relating to rate increases sought by the applicant before the Federal Energy Regulatory Commission.
Response
16.
(a)-(d)
KG&E and KCPL will make available the documents requested for review by counsel for Intervenors at KG&E's Wichita office.
KEPCo has no docu-il ments responsive to this request.
l i
Interrogatory 17 17.
(a)
Where are complete copies of the applicants' appli-cation for the operating license for the plant located?
(b)
Describe the information contained in the application for the operating license as required by 10 CFR 50.33 (f) which relates to the financial qualifications of I
the applicant.
(c)
Have the applicants filed all of the financial I
! i.
1 1
information required by 10 CFR 50.33(f) and other i [
regulations Of the Nuclear Regulatory Commission?
If I
not when and what else in connection with the I
operating license will be filed.
(d)
Provide copies of all financial information required by 10 CFR 50.33(f) and filed with the application for an operating license.
i N i3
Response
17.
(a)
Copies of the applic' ant's application for the operating license which are available for public inspection are located at the Local Public Document Room at the William Allen White Library, Empor ia State University, Emporia, Kansas and at the NRC Public Document Room, 1717 H Street, Washing ton,
D.C.
(b)
Information in the Wolf Creek Generating Station, Unit No.
1, Operating License Application which is required by 10 CFR 50.33(f) and relates to the financial qualifications of the applicants is provided in the following documents:
i 1.
The annual repo'rts of the Applicants filed
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I with the Operating License Application on February 19, 1980, and annually as required I
l by 10,CFR 50.71(b).
2.
Environmental Repor't (Operating License Stage) Sections 1.1, 1.3, 5.8, 8.:,
8.2, t
9.1, 11.1 and 11.2.
l I
(c)
No.
The NRC proposed in the August 18, 1981 Federal i
Reg is ter that financial qualifications reviews in
'l operating license proceedings be eliminated except in the decommissioning area.
With respect to decommis-I sioning, the proposed rule has two alternatives, one I
of which eliminates financial qualifications for decommissioning while the other does not.
Should the i
_____.____---_____-__mo
proposed rule be adopted prior to January 1982, Applicants plan to file in January 1982 whatever financial qualifications information is required under the rule as adopted.
Should the proposed rule be rejected or not adopted prior to January 1982, Applicants plan to file with the NRC that information currently required by 10 CFR 50.33(f).
(d)
All available responsive financial information is included in the ER and the annual reports being prcvided to counsel for Intervenors under separate Cover.
Interrogatory 18 l
18.
(a)
Provide a copy of the mos't recent annual report and related exhibits and schedules which has been filed i
with the Kansas Corporation Commission or the Missouri Public, Service Commission by the applicant.
(b)
If the applicant has filed within the past two years,
'l with the Kansas Corporation Commission or the Missouri Public Service Commission, any estimates of future electrical loads and power facility require-ments covering a period of three or more years, provide a copy of any such estimates.
Response
18.
(a)
FERC Form 1 represents the annual report filed by KG&E and KCPL.
These documents will be made available to Intervenor's counsel for review at e y l
KGTE's Wichita office.
KEPCo's annual report to 'the j
Kansas Corporation Commission is F
+..I provided to counsel for Intervenors under r
. rat, cover.
(b)
These documents are being provided to counsel for Intervenors under separate cover.
Interrogatory 19 19.
(a)
What is the most recent rating of the applicant's common stock, preferred stock, and bonds by Moody's and' Standard and Poor?
(b)
Furnish copies of any correspondence, or notices from Moody's and Standard and Poor's regarding such l
ratings.
(c)
State if the applicant has any documents relating to (a) or (b) and identify them.
Response
KG&E 19.
(a)
KG&E's preferred stock and First Mortgage Bonds are rated by Moody's and Standard and Poor's ("S&P") as follows:
Moody's S&P First Mortgage Bonds Baa BBB Preferred Stock ba BBB-B+
Common Stock i
(b)
Copies are being provided to counsel for Intervenors under separate coverr.
).
(c)
See response to (b) above..
r KCPL 19.
(a)
KCPL's most recent rating are as follows:
Moody's S&P First Mortgage Bonds A
A Unsecured Pollution Control Bonds Baa BBB Preferred Stock a
A-Common Stock A-(b)
Documents supporting these ratings are being provided to counsel for Intervenors under separate cover.
(c)
See response to (b) above.
KEPCO 19.
(a)-(c)
XEPCo has no such ratings or documents pertain-ing thereto.
Interrogatory 20 20.
(a)
Indicate the estimated cost of permanently shutting down the facility after five and fifteen years of operation.
(b)
Include a detailed list of the components of the total cost spacified in (a).
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(c)
What are the assumptions made in estimating the cost in (a) and (b)?
(d)
State if the applicant has any documents relating to (a)-(c) and identify them.
Response
20.
(a)-(c)
All present plans for decommissioning (perma-nently shutting down the plant) are described in Section 5.8 of ' Wolf Creek Generating Station, Unit No.
1, Environmental Report Operating License Stage".
(d)
See response to Interrogatory 12(c).
Interrogatory 21 21.
(a)
What is the applicant's estimate of costs to perma-nently shut down the plant because of an accident of the nature of Three Mile Island?
(b)
List in detail the components of the total cost specified in (a) and list the assumptions made in estimating such costs.
(c)
State if the applicant has any dumuments relating to (a) and (b) and identify them.
Response
21.
(a)-(b)
All present plans for decommissioning (perma-nently shutting down the plant) are described in Section 5.8 of the ER.
(c)
See response to Interrogatory 12(c).
Interrogatory 22 22.
The Kansas Corporation Commission has ordered the applicant, Kansas Electric Power Cooperative, Inc., to
submit to the Corporation Commission for its review and approval a plan for the establishment of a sinking fund sufficient to defray such applicant's portion of the expenses of decommissioning the plant based upon the projections of the applicant, Kansas Gas and Electric Company, submitted in connection with the hearings for the Kansas Corporation Commission Docket No. 120,783-U.
See page 35, of the Kansas Corporation Commission Order dated October 22, 1980.
the projections of the applicant, Kansas Gas (a)
What are and Electric Company, referred to in the order for said docket?
t (b)
What has the applicant, Kansas Electric Power Cooperative, Inc., done to comply with the order of the Corporation Commission?
(c)
State if the applicant has any documents relating to
( ;) or (b) and identify them.
Response
22.
(a)
All present plans for decommissioning are described in Section 5.8 of the ER.
(b)
The conditions in the order of the Kansas Corporation Commission have been appealed to the Shawnee County District Court.
KEPCo has prepared and sent out a prospectus.
KEPCo has obtained a determination from the Administrator of the Rural Electrification Administration as to the contracts necessary to __
gw secure the loan with which KEPCo will finance an interest in Wolf Creek.
(c)
With respect to (a) above, see response to In te r r og ato r-f 12(c).
With respect to (b) above, see KEPCo's response to Interrogatory 7(f).
Interrogatory 23 23.
(a)
State in detail the plans of the applicant for retiring or aLandoning all or any part of any electrical generating plant in which it owns an interest between now and 1995.
(b)
State if the applicant has any documents relating to (a) and identify them.
Response
KG&E 23.
(a)
KG&E currently,has plans developed through 1992; no retirements or abandonments of any electrical generating plant are currently contemplated.
See ER, Table 1.1-4b.
(b)
The ER is being provided to coundel for Intervenors under separate cover.
KCPL 23.
(a)
For planning purposes, KCPL projects the retirement of Northeast Station steam units (80 MW) by no later than 1984.
KCPL projects the retirement of Grand Avenue Station (70 MW) in two increments - 30 MW in 1982 and 40 MW in 1990.
The turbine-generators in N
question all exceed forty years of service, and in certain cases approach sixty years of service.
(b)
KCPL's Load and Capacity Planning Scenario, dated October 6, 1980.
KEPCO 23.
(a)
KEPCo presently has no generating facilities, and has no plans to retire any prior to 1995.
(b)
Not applicable.
Interrogatory 24 24.
(a)
What are the applicant's estimated costs of storing high and low level nuclear waste produced at the plant?
H (b)
What are the assumptions made by the applicant in i
determining the costs set forth in (a)?
(c)
State if the applicant has any documents relating to (a) and (b) and ; identify them.
Response
24.
(a)-(c)
Storage of primary and secondary nuclear waste (high and low level nuclear waste) is anticipated to be accomplishe,d by enclosing the material in suitable drums and storing them in a portion of the plant.
i The costs for that portion of the plant to be utilized for ' storage has not been estimated; accord-ingly, there are no related documents.
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