ML20235D099

Responds to Requesting Comments on Cincinnati Gas & Electric Co,Columbus & Southern Ohio Electric Co & Dayton Power & Light Co Application for CP for Proposed Wh Zimmer Nuclear Power Station

ML20235D099
Person / Time
Site:	05000000, Zimmer
Issue date:	08/05/1971
From:	INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20235B311	List: IA-87-111, Submits Rept on Plant,As Discussed in ACRS 150th Meeting on 721012-14.Listed Items Can Be Resolved During Const & Facility Can Be Constructed W/Reasonable Assurance for Operation W/O Undue Risk to Public Safety IR 05000254/1972009 IR 05000358/1972003 IR 05000358/1973001 IR 05000358/1973002 IR 05000358/1973003 IR 05000358/1973005 IR 05000358/1973006 IR 05000358/1973007 IR 05000358/1974001 IR 05000358/1974002 IR 05000358/1974003 IR 05000358/1975004 ML20235B308 ML20235B364 ML20235B401 ML20235B405 ML20235B424 ML20235B456 ML20235B461 ML20235B465 ML20235B477 ML20235B488 ML20235B507 ML20235B552 ML20235B582 ML20235B585 ML20235B588 ML20235B605 ML20235B618 ML20235B623 ML20235B649 ML20235B656 ML20235B662 ML20235B670 ML20235B679 ML20235B683 ML20235B687 ML20235B702 ML20235B708 ML20235B713 ML20235B714 ML20235B718 ML20235B720 ML20235B730 ML20235B734 ML20235B748 ML20235B754 ML20235B762 ML20235B764 ... further results
References
FOIA-87-111 NUDOCS 8709250117
Download: ML20235D099 (15)

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DEPARTMENT OF THE INTERIOR

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TISH AND Wil DLIFE SErvVICE cD g

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!!r. flarold L. Price i D(

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j .Lirector of Re:.;ulatico ADG 5 m 4 . 9'r I l

I U.C.' Atwie Yncrcj Cwr.lc,cion

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i Dear 12. Trices l

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This.ls in reply to !.r. Per./d's icLter of A;.rji 30, 1970, requestinc cur ev.;;cnt: on the a1911 cation t,y the Cir.cInt.ati Gas and Electric l

Cenpany, the Colu:.$u: ar ! Se,uthern Chlo Ihetric Ccnpery, and the Dayton Pcr.ict ar.d Licht Cce. par.y for a construction pernit for the I propo:cd 1111a:4 h. Zi i.cr !!ucicar power Station, Clerrwnt County,

(( Chio, Ahc Loc::et !!o $0-353.

We have reviewed the Frc11rinary Safety Ant. lysis Report and its a erd-sacrats thscraJi 1 o. */ pr:rtiued ty subsequent Actters. The ccr.t:.cnts of the ll1d-Atlantic Coastal Fisheries Bescarch Center,1:aticaml !!arine j Fisherles Servlee,11: pert. ment of Ccencree, were obtained and arc in-cluded as a part of this revicv. ,

The station vc41d to c:.r.structed on a SCV-serc tract of lar.d located on the Ohio chere of the Chio RJver 24 niles sca.thcest of Cincirmati.

The bollir. , vnter rcecter veuld be desifned to produ:e M/ reeCavatts electrical De ect.denscr vould be cocied 1y a closed circulative s water systen inecrperat'ns a ratural draft, hyperbelic coolics tover.

An averc e of E') e.f.n. of water 'for the station serviec systea and i s

coolitc tower ms.heup req 11renent vould te pu . ped frc- the Ohio River through an inth stru:ture with trash crille end travelir., sercens.

• Of this veter, O e.f.s. vould be used to replace evaporation e,nd drift losses frera the ecolin . tover. Ihc rentininc (4 c.f.s., in-caudinc four to be n:ed to b1v lo.in the tover, vould bc }s. ped to a j settlin*, basin then rettrr.ed to the river. Chlorine and sulfuric acid would be used in the circulatin rater syste.t to prevent biolecical Crovth cr.d scale fornatier.. '1he coolin; tower basin and the settlinc ba:In vould cer.tr:1 the he:t end chem.ical centent of the eff1'acnt vster to levels t .at vould not aficct aquatic life in the receivina vnter c' .nf ficct.tly.

The Ohlo itiver trovide: habitat for a variety of cc. :e end foodriches includits frenhunter dru., enry, buffalo fishes, catfishes, suckers, paddlefish, ercppie, enJ quillbach, cnd rast.els which support ecencr-cial cnd sp:,rt fisherles. ,

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The icver rr.ech (frcm L% i:ville, ).cr.tuc?y, to its corifjuence. with the l

[_ 1:1c:iscippi D D.. r incl tit.; its prjncipc1 trjiutaries) hos fr.9 cource:

of runicirci cid it.dar. trit.1 polluticr.. Althou,th so .c tair. tin; of fish i-- flesh frcn oil pollutice f.cc cecn reported, the water quality in this l-reach is relatively co n. 2.c hictorie land nr.d water conditicn have been altered by the con:truction of det.z, chans.cl deeper.in; proJeets, and other work that ha:. created a serie: cf alach-water navf r,ation t

pools that in the a . rc; ate t. ave increcced turbidity ard =iltinc of the water, Despite this condition, the aquatic organia.c have adapted to the prescnt environ: ent and are naintaininc their populations.

_ 1:icrating writertw1 une the Ohio }(Iver an a flyvay route. A small breedinc population of vocci ducks occurs in the projcet area. Upland Cano species inelwie cottcntail, squirrel, and qunil. Raccoons and red and crcy foxes are concen.

The applicant indicated that the release of radioactive vastes to the environ:wnt would be kept 'tell below allouable lirats. While these provisiens are considered adequate to safeguard r.an frm undue radi-ation expenure, the effects of radicoctivity on fish and wildlife or.'aniens is poorly understood. Acceptabic radiation doce rates and body burdens for fish and vildlife have not been established. Pendinc such establish.ent, it is inperative that the applicant conduct a d

radiological r.onitorinc pro:ran to detect possibic radiation buildups

$ in the fish and wildlife resources and the environment resulting treo i

plant operationc. .

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[ The cooling voter systen poses a potential hazard to the equatic re-

. E sources of the river an a substantial number of organicas nay be P attracted to or drawn into the intrue structure and destroyed.

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b The applicent proposes to initiate an envircrnental radiological F- nonitorinc pro;ran two years before the station becoues operctienni P on Jonunry 1,1975. Sanples of water, sedit.cnts, bottoa orcanisms, I alcce (periphyton), and fish will be collected at stations located b alonc the Caio River at Mcldahl Loch and Dan, the Cincinnati Wcter f

e Works, at the station site and local draina;cs, i=::cdiately below the site, and at the Ecchjord Generating Station. The exact locations of e- these stations and the orcanisms to be sanpled have not been identi-

_- fled. He.iever, the appliennt plans to coordinate its procran with local, State, and Federn1 ecencies. The selection of orcanis.s will be based on information fro.: the Ohio River Valley Sanitatien Co .tission and the Ohio and }:entuel:y Conservation Departr:ents. In order to assure odequate ca :plin;, we reccnnend that the provran be expanded to in-clude sanples of water sedi .:ents within $CO feet of the effluent out-

, fall, biota as close as possible to the outfall, aquatic pinnts and

_ both herbivorous and carnivorous fich, and that all biota be analy:cd 5:- for both beta and ca*.na radioactivity. Uith these additions, the f 2 s .

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proposed radioactivity s rychiar.cn prc;rce: ve>1d pry /ide for. the protectiori cf fish and wildlife resc,urces 12. tne pro,Jcct erca.

i Postoperational surveys also are necensary to deternine the extent of radiosetivity tuildup in the environ:ent frca plant cperations. This can be deterrined 'cy corporin; the results of the two studics, The applicant chould contir.ue to cocperate with the conectned Federal and State a!,encies in plannin; such studies. 7ac studies should be ade-

, quate to insure the protection of flah and vilcolite resources and the environment, 6thile'the project has the potentini of inf1Letinc sicnfficant adverse l'r. poet on the environ .ent of the ares, we believe that b/' the careful desicn and operation of the condenser coolinc water systc: and the utilization of adequate radinlocical and environmental r.onitorins pro.

Crans, stajor difficulties can be avoided. Therefore, we would have no objection to the issuance of the construction perr.it, j

Althouch the applicant has expressed assurance of full cooperation with the Bureau of Sport Fisheries and U11dlife, other Federal- a.c;encies, and State and local authorities in developin;; and' carrying out a procran ,

for the protection cf fish and v11011re resources and the environtient, I the details of the pro;ran are not availabic. Therefore, we recconend that the Cincinnati Gas and Elcetric Capany, the Colu . bus and Southern {

Chio Electric Company, and the Dayton Pcwcr and Licht Capanyt

1. Continue to cooperate with the Burea.s of sport Ticheries and Wildlife and other interested State and Federal a:;encies in the developicnt of the planned radiolc+;ical and ecolocical '

noni}orinc proCrans.

2. Conduct preeperational radiologieni and ecolo;ical surveys

,_ developed in cooperation with the above-nat:ed scencies. Pre-lj pare a report of these surveys, and provide six copies of each l to the Director, Bureau of Sport Fisheries and Wildlife, for ,

evaluation prior to project operation.

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j 3 Meet with the above-nnTed acencies at frequent intervals j to discuss any new or riodified rians and the pro;;ress of the .

ecolecical and radiolo;1 cal surveys. I

h. Conduct postoperational radiolo;ietti and ecolo;ical surveys '

i in accordance vith plans devcicped under Ecco_raendction No.1

'{ and as r.ny be nodified under Recomendction No. 3, above. Pre-g parc reports enntial]y or until it has been conclusively demonstro-ted that no sig1ificant adverse conditions exist, and subnit six copics of these reports to the Director, Burcsu of Sport i Fisheries and Ulldlife, for evaluation. l 3 )

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L.  !!al.o t.uch tv211rica tic t: In I,rso.. c t strt.c turec c::1 uj, era-tiens, iracladin ; Isrctect,!ve t.crec r.in , deviet-s , nr. r.ny t.c necc::ary to protect t;ac fi:h crul vildlife recources of the aren.

The opportunity for preser.tir.; car views ori this project is cpf.reciated.

Sincerely ycurz,

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APPLNDIX G

~ AEC Re gula t or y S ta f f 's E va lua t i on o f t he Fina nc ia l- Qua lifica t i ons of The Cinc inna ti Cas & Liec tric C&Mny .l

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Columbus and Southern Ohio.Llec tric Cmny, The De y ton Power and 1,1gh t ceny Docket No,50-35d We 'have reviewd the financial information presented in the appiscation sad Asuradments No. 3 and No. 20 thereto of The Cincinnati Gas & Electri Company, Columbus and Southern Ohio Llectric Company, and The Dayton Power 1 and Light Company to construct, as tenants in comanon, one nuclear -power k l

unit with an initial not electrical output of about 807 negawatts (2,436 Mart) to be located on the Ohio River in Idsshington Totawhip in Clermont County near Moscow, Ohio.

Based on this review, we have concluded that the applicants are financially que11(led to design and construct the pro-posed facility to be known as the len. N. 21samer Nuclear Power Station, ,

Unit 1.

1 Our conclusion is based on the following facts and considerations:

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1. i Applicants, through their agent The Cincinnati Gas 4 Electric Company, estimate the costs of construction of the plant, including transmission facilities and other associated costs will total about $307.7 million.

The details of these estinstes and the percentages to be borne by each applicant are contained in the application and are summarized below:

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Prior (dollars in saillions) 1971 to 1971 and af ter Total Ilucicar Production Plant Costa Cineinnat1 - (40%) $ 2,5 $112.3 $114.s

. Columbus (28,3%) 1,3 80,0 31,8 Dayton (31.5%)

2.0 _ 88,4 90,4 Total Plant W j_780,7 J2sy,o Tra: emission facilleles costa (33-1/3%

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Cincinnatt

$ 6.9 $ 6.9 Columbus 6.9 6.9 Dayton

_ 6. 9 6.9 Total Transmission M g '

Total Production and Transmission Cine inna t 1 -

$ 2.5 $119.2 $121.7 Columbus

, 1.8 86.9 38.7 Dayton _ 2,0 95.3 97.3 b kM Tbc Division of Reactor Licensing has reviewed the details of the estimated plant capital costs for construction and has found them to be reasonabic.

Applicants plan to obtain nuclear fuel under a lease arrangement. Accordingly, cost of fuel will be provided for as a normal operating cost.

Applicants estimate their total construction expenditures for the six-year period 1971-1976 will be approximately as follows:

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.-s 3-Cincinnati $ 834.2 million Columbu's 610.1 Dayton- 612.6 Total $2,056.9 million .

2. Construction of the nuclear plant will be financed by the applicants in the normal course of financing their plant construction program.

Such' financing is obtained from internally generated funds, principally unappropriated earnings and provision for depreciation, from sale of debt and/or equity securities, and from short-tern loans needed to meet requirements on a temporary basis.

Ba' sed on each applicant's record of earnings and provision for depreciation and other accruals over the past five years and on the reasonable assumption-

. of the continuation of these earning levels over the years 1971 through 1976, it in reasonable, in our opinion, to expect that internal sources -

can provide, af ter dividends, cumulative amounts for the six-year period as follows:

Cincinnati $ 231 million '

Columbus 110 Dayton 147

$ 488 nillion These amounts are more than adequate to cover the estimated costs of each applicant for constructing the Wm. II. Zuumer Station, Unit 1.

Furthermore, in view of each applicant 's resources, tbc strength of

.its financial position, the high regard held for its bond issues, and

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the proven ability of cach to borrow on a short-term basis, it- in our opinion that issuance of securitics can be relied upon with reasonable assurance to supply funds required to finance the design and construction k of additional generating espacity for each applicant, I

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.j 3. The applis ants will share. the engineering and construction costs an l

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j .in the. unit. Cincinnati is. responsible for the denign, construction and operation of the unit (and station) and will construct and operate

,. the station on its own behalf and as agent for Columbus and Dayton.

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, 4 Cincinnati Gas & Electric Company is soundly financed and has algnificant

[ resources at its coesnand. As of December 31, 1970, cash and net receivables totaled $29.8 million. long-term debt represented 54.6% of total capitali-sation and $1.4% of the net investment in utility plant. The applicant's Dun' and Bradstreet credit rating is $Al (the highest category) and Moody's Investors Service rates the company's first mortgage bonds as Aan (gilt-edge).

Operating revenue of $261.6 million for 1970 was up 43% over 1966, and net income, after taxes, of $36.9 niillion was up 27% over 1966.

.The volume of c1cetric energy sales over the same five years has increased 34% to 9,512 million kilowatt hours in 1970. The number of times interest earned on long-term debt has declined from 4.3 for 1968 to 3.2 for 1970. The pertinent financial ratios indicate a sound financial position, and thoso are in line with ratios of the cicetric 1

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utility induntry as a choic. Soaury an.41ydes reflet tle.g the ratios and

.other pc rt inent d.ita for each applicant are attached as appendixes.

In brici, these ' rat iot for Cincinnati Cas & Electric Company as of Ikeceber 31, 1970'ere:

. long-term debt to net utility plant .51; net plant to capitalization - 1.06; proprietary ratio 39; operating ratio '.82; rate of carnings (before inter 4 st) on total investment - .

7.1%; rate of net s.irnings on stockholders' equity - 12.4%; times interest earned on long term debt - 3.2; and retained earnings - $91.4 million.

Columbus and Southern Ohio E1cetric Co. is adequately financed and has

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significant resources at its command. As of December 31,1970, cash j l

and net receivables totaled $12.5 million. Iong-tere debt represented '

59.7% of total capitaliastion and 58.7% of the not investment in utility plant. The applicant's Dun and Bradstreet credit rating is 5A1 (the highest category). Hoody's Investors Service rates the company's first mortgage bonds. as Aa (high quality).

OperaLing revenue of $109.1 million for 1970 was up 36% over 1966, and

- net income, af ter taxes, of $15.5 million was up 6% over 1966. The volume of cicetric energy rales over the same five years has increased 41% to 5,929 million kilowatt hours in 1970. The number of times interest earned on long-term debt has decreased from 3.7 for 1968 to 2.3 for 1970. The pertinent financial ratios indicate on adequ.ite financial position; these are in line with ratios of the electric

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utility industry as a whoic. Summary analyses reficcting the ratios and other pcrtinent' data for each applicant are attached as appendixes.

In brief, these ratios for Columbus and Southern Ohio Electric Company as of December 31,1970 are: long-term debt to net utility plant .59;  ;

net plant' to capitalization - 1.02; proprietary ratio .35; operating i ratio .79; rate of earnings (before interest) on total investmcnt -  ;

6.4%; rate of net earnings on stockholders' equity - 9.6%; times interest earned on long-term debt - 2.3; and retained earnings .$75.8 million. , ,

The Dayton Power and Light Company is adequately financed and has significant resources at its command. As of December 31, 1970, cash and net receivables totaled $17.5 million. Long-term deht represented 54.8% of total capitaliza-tion and 51.7% of the net investment in utility plant. The applicant's Dun and Bradstreet credit rating is 5A1 (the highest category) and Hoody's Investors Service rates the company's first mortgage bonds as Aa (high quality).

Operating revenue of $180.7 million for 1970 was up 34% over 1966, and net income, af ter taxes, of $22.4 million was up 20% over 1966. The volume of electric energy sales over the same five years has increased 41% to 6,882 million kilowatt hours in 1970. The number of times interest earned on long-term debt has declined from 3.9 for 1968 to 3.1 for 1970. The pertinent financial ratios indicate an adequate h

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j- financial position, and these arc in line with ratios of the electric 1

utility industry as a whole. Summary analyses reflecting the ratios and other pertinent data 'for each applicant are attached as appendixes.

In brief, these ratios for Dayton Power and Light Company as of December 31,1970 are: long-term debt to net utility plant - .52; net plant to capitalization - 1.06; proprietary ratio .38; operating ratio .80; rate of earnings (before interest) on total investment -

s 7.1%; rate of net earnings on stockholders' equity - 10.4%; times interest earned on long-term debt - 3.1; and retained earnings - $82.4 q million.

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t Ti!E C]NCit:NATI GAS AND ELECTRIC COMPANY DOCKET No. 50 358 l.

FINANCIAL ANALYSIS

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(dollu: s in millions).  ?

Calendar Year Ended December 31 1970 1969 1968 long-term debt $ 357.4 $ 287.7 $ 238.0

. Utility plant.(not) . 695.6 611.9 546.8 47 .44

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Ratio - debt to fixed plant .51  ;

Utility plant (net) ,

695.6 '611.9 546.8 j

. Capitalization .

655.1 540.7 479.8 4 Ratio of ner. plant to capitalization 1.06 1.13 1.14

. Stockholders' equit); 297.7 253.0 241.8-  !

665.6 Total assets 759.3 595.4 Proprietary ratio.. .39 .38 .41  ;

--Earnings available,to common equity 33.7 33.3 30.7'  !

Comon equity - _ . . 222.7 213.0 201.8  !

Rate of carnings on. common equity 15.1% 15.6% 15.2% )

Net income- 36.9- 35.0 32.4 Stockholders' equity--

297.7 253.0 241.8 Rate of earnings on stockholders' equity 12.4% 13.8% 13.4%

Net income before interest 54.1 48.9 42.8  ;

Liabilities and capital .

759.3 665.6 595.4 l Rate of earnings on total investment 7.1% 7.3% 7.27.

Net' income before interest 54.1 48.9 42.8 Interest on long-term debt 16.9 , 13.3 9.9 l No. of times long-term interest earned 3.20 3.68 4.32 1

Net incores 36.9 35.0 32.4 Total revenues 261.6 247.3 225.0-Net income' ratio .14 .14 .14

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Total utility operating expenses 214.9 203.8 185.7 Total utility operating revenues 261.6 247.3 225.0 Operating ratio .82 .82 .82 Utility plant (gross) 935.7 834.3 754.6 Utility operating revenues 261.6 247.3 225.0 Ratio of plant investment to revenues 3.58 3.37 3.35 1970 1969 Capi ta li r.s t ion : Amount 7. of Total Amount  % of Total Long-term debt $357.4 54.6% $287.7 53.27.

Preferred stock 75.0 11.4 40.0 7.4 Common stock & surplus 222.7 34.0 213.0 39.4 Total $655.1 100.0% _$540.7 100.07.

Hoody's Bond Ratings: First Mortgage Aan Dun & Bradstreet Credit Rating: SA1

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i COLUMBUS AND SOLElU:RN 01110 ELECTRIC CO.

DOCKET No. 50-358 FINANCIAL ANALYSIS I

(dollars in millions)

Calendar Year Ended December 31 1970 1969 1968 Long-term debt $ 238.1 $ 183.8 $ 157.5 Utility plant (nct) ' 405.3 353.6 316.2 Ratio - debt.to fixed plant .59 .52 .50 Utility plant (nct) 405.3 353.6 316.2 Capitalization 399.0 323.0 292.0 Ratio of net plant to capitalization 1.02 1.09 1.08 Stockholders' equity 160.9 139.2 134.5 Total assets 454.8 399.6 358.8 Proprietary ratio .35 .35 .37 Earnings available to common equity 13.6 14.6 14.0 Common equity 123.5 119.8 115.1 Rate of carnings on common equity 11.0% 12.2% 12.2%

Net' income 15.5 15.4 14.8 Stockholders' equity 160.9 139.2 134.5 Rate of earnings on stockholders' equity 9.6% 11.1% 11.0%

Not income before interest 28.9 25.3 22.0 Liabuities and capital 454.8 399.6 358.8 Rate of earnings on total investment 6.6% 6.3% 6.1%

Net income before interest 28.9 25.3 22.0 Interest on long-term debt 12.3 8.3 6.0 No. of timer long-term interest earned 2.35 3.05 3.67 Net income 15.5 15.4 14.8 Total revenues 114.8 104.4 94.3 Net income ratio .14 .15 .16 Total utility operating expenses 85.9 79.1 72.3 Total utility operating revenues ,

109.1 100.4 91.8 Operating ratio .79 .79 .79 Utility plant (gross) 518.9 465.1 418.8 Utility operating revenues 109.1 100.4 91.8 Ratio of plant investment to revenues 4.76 4.63 4.56 1970 1959 Ca pi t ali za t ion: Amount 7. of Total _ Amount 7. of Total Long-term debt $ 238.1 59.77. $ ,183.8 56.97.

Iteferred stock 37.4 9.4 19.4 6.0 Cocenon stock & surplus 123.5 30.9 119.8 37.1 Total $ 399.0 100.07. S 323.0 100.0%

Moody's Bond Ratings: First Mortgage A,a Sinking Fund Debentures A Dun and Bradstreet Credit Rating: $Al

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DAYTON POWER AND LIGilT COMPANY D0dKET NO. 50-358

' FINANCIAL ANALYSIS ,

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, i (dollars in millions) I CalendarYearEndedDecember3[

1970 1969 1968?

Iong-term debt $ 261.8 - $ 226.8 $ 196.8

-Utility plant (net) 506.2 454.4 386.3

> Ratio:-l debt to fixed plant .52 .50 .51 Utility plant (neQ 506.2 454.4 386.3 Capitalization 477.5 413.3 360.8 Ratio of net plant to capitalization 1.06 1.10 1.07 j Stockholders' equicy 215.7 186.5 164.0 ,

Total assets 559.4 499.7 420.1 Proprietary ratio .38 .37 .39 Earnings, available to common equity 20.4 21.3 20.7  ;

Common equity -

177.9 148.7 141.1 l Rate of earnings on conmon equity 11.5% 14.3% 14.7%

l Net income.

y, 22.4 23.0 21.5 Stockholders' equity ( 215.7 186.5 164.0 Rote of earnings on stockholders' equity 10.4% 12.3% 13.1%

Wet income before' interest 39.8 34.9 30.4' Liabilities and capital 559,4 499.7 420.1 Rate of earnings on total investment 7.1% 7.0% 7.2%

Net income before interest 39.8 34.9 30.4 Interest on long-term debt 13.0 9.1 7.7 ,

No. of times long-term interest earned 3.06 3.64 3.95 Net income 22.4' 23.0 21.5 /

- Total revenues 185.4 166.5 153.2  %

Net income ratio .12 .14 .14 9 Total utility operating expenses 145.6 131.6 122.8 .

Total utility operating revenues 180.7 162.6 150.6 Operating ratio .80 .81 .82 Utility plant (gross) ,

656.8 590.1 511.3 Utility operating revenues 180.7 162.6 150.6 Ratio of plant investment to revenues 3.63 3.63 3.40 1970 1969 Capitalization: Amount  % of Total Amount  % of Totaj Long-term debt $ 261.8 54.87. $ 226.8 54.9%

Preferred stock 37.8 7.9 37.8 9.1 Common stock 6 surplus 177.9 37.3 148.7 36.0 Total _S 477.5 100.0*6 $ 413.3 _100.07.

Moody's Bond Ratings: First Mortgage Aa Dun and Bradstreet Credit Rating: SA1

. I'. S. COVI'RNW FNT PRINTlv. (IVIFF t.73 483-021/196

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