ML19329E642

Deposition of Gs Keeley (CPC) Re Project Status & Future Work Activities,Acrs Concerns,Delay Costs & Effects, & Cost Comparison of Operating V Abandoning of Plant

ML19329E642
Person / Time
Site:	Midland
Issue date:	11/05/1976
From:	Keeley G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19329E643	List: ML19329E642 ML19329E646 ML19329E648 ML19329E651 ML19329E652
References
NUDOCS 8006160423
Download: ML19329E642 (94)

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I-l G. S. IGELEY TESTIMONY My name is Gilbert S. Keeley. I reside at 6108 Crest Road in Jackson, Michi,gan and I am currently the Project Manager for Consumers Power Company's Midland nuclear plant. I was born in Lincoln, Nebraska on September 9, 1922. I obtained a Bachelor of Science degree in electrical engineering from the University of Missouri at Rolla in 1914. In addition, I have taken post-graduate courses in advanced engineering mathematics and design of electronic circuits from the University of Idaho. I am a member of the Institute . aec'trical and Electronic Engineers, and Tau Beta Phi, National Engineering Honorary Fraternity. Prior to joining Consumers Power Company I worked for the General Electric Company in Schenectady, New York; Pacific Gas & Electric Company in California and Westinghouse-Ato=ic Power Division in Idaho. I joined Consumers Power Ccmpany in 1961 and worked as a general nuclear engineer at the Big Rock Point nuclear plant until 1%3 From 1963 to 1971 I had nuclear engineering responsibilities in the Cc=pany's general office. In January 1971 I was named Director of Project Engineering Services and served in that position until October 1973 when I was named Director of Project Quality Assurance Services. I became Project Manager for Midland in August 1975. As the Midland Project Manager I have overall responsibility for engineering, licensing, construction, cost and scheduling for the Midland Project.

'Ibe following testimony is made up of four parts.

Part I describes the current project status and projected work activities.

j Part II describes ACRS concerns which appeared in the Midland ACES lettersdated6/8/70and9/23/73,andindicatesthestatusoftheseconcerns.

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o I-2 It also describes other ACRS concerns including express generic concerns prior to and after the issuance of the ACRS generic letter dated 12/18/72, and indicates the status of these concerns.

Part'III describes delay costs and the effects of delay that would be attributabls to a suspension period of 12/1/76 - 5/1/77 and 12/1/76 - 9/1/77 Part IV presents a comparison of the economic cost to complete and operate Midland to the cost of abandoning Midland and installing and operating an alternative generating facility.

I. CURPEIT PROJECT STAIUS AND PROJECTED WORK ACTr/ITIES A. Project Description and Status As of November 1,1976, the Midland Project was approximately 63% com-plete for engineering activities ahd 19% complete for construction activities. Ibese percentage ecmpletion figures are based upon a com-parison of engineering man-hours spent to date to estimated engineering man-hours to-go and a co=parison of construction man-hours ce=pleted to date to construction man-hotrs to-go. It is estimated that 300 major purchase orders and subco ttracts will have been issued before the project is completed. Approximately 170 have been issued to date, with fabrication of equipment either completed and on-site or in the process of being manufactured.

At present, there are approximately 280 Bechtel Engineering personnel located in the Ann Arbor-Engineering office who are working en the Midlend Project. At Midland there are approximately 900 craft personnel, 350 field engineers and supervisory personnel e= ployed by Eechtel,100 sub-contractor personnel, and 2l+ Consumers Power engineers.

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I-3 As of November 1,1976, an esticated 397 million dollars will have been spent on the project. 'Ihis 397 million dollar figure includes the following major cost ccmponents:

a. Bechtel (Engineering and Ecme Office, Field Labor, Materials, Subcontracts, Fee) $187 million

b. CP Co Directs (.?ngineering & Supervision) 8 mi' lion

c. CP Co Overheads (Allowance for Funds Used During Construction, Taxes & Insurance, Administration) 64 million

d. Nuclear Steam Supply System 99 m4111on

e. Tarbine Generator 25 million

f. Process Steam Evaporators 6 minion

g. Miscellaneous Other Work Orders (Land, Licensing) 8 million Consumers Power's proposed Exhibits 1, 2 and 3 vill be photographs showing the status of construction as of November 12, 1976. The auxiliary building, which lies between the two cylindrical containment buildings, houses auxiliary systems which are necessary to operate the nuclear steam supply systems. The walls for this building have been co=pleted to the 634' elevation which is grade level on the site.

The base of the auxiliary buildirg is at grade level 568' and win eventimlly rise to grade level 659' which is the operating floor level. Between elevation 568' and elevation 634' four distinct floors with each floor consisting of several rocms have been completed. Within these w :ms come of the larger pieces of equipment such as radvaste storage tanks, component cooling water heat exchangers, and decay heat coolers have been installed and piping installation has co=menced.

I4 Just south of the auxiliary building is the control tower building which houses switchgear, cable spreading rooms and the control room.

Se walls and ficor have been completed to the 634' elevation. This buildi'ng will eventually rise to elevation 659'.

Unit #2, the power only unit, is scheduled to be placed in service (commercial operation) in March 1981. Unit #1, the power unit plus process steam to Dow, is scheduled for service in March 1982. As a result, containment building #2 and turbine building #2 have more work completed on them than containment building #1 and turbine building #1.

Both containment buildings have the liner plate completely erected.

Se welding of the liner plate is co=plete on containment building #2 and welding on containment building #1 liner plate is underway. Me outside walls of the contaire.ent buildings have concrete in place up to elevation 683' on #2 and up to elevation 670' on #1.

The dome liner plate for containment building #2 has been asse= bled, welded and painted. Spray piping is currently being installed and the deme liner plate will be lifted and installed on top of the containment building before the first of the year. The dome liner plate for containment building #1 is also being assembled.

Se base slabs for both containment buildings have been poured, and the cover slab has been poured in #2 containment building. The cover slab for #1 containment building is in the process of being poured.

Me turbine pedestal concrete work is complete and the base slab has j l

been poured at elevation 614' with circulating water piping installed in the slab in turbine building #2. '1he main condenser for #2 turbine has I

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I-5 been assembled on-site and is in place. In addition some of the ex-terior walls have been completed from elevation 614' to elevation 634' .

Reinforcing steel is being installed for the base mat, turbine pedestal, and for exterior walls to elevation 634' for turbine building #1 and some c6ncrete has been poured in those areas.

With respect to yardwork and support facilities, two large warehouses have been completed and components are stored in it until withdrawn fbr use on the project. A combination shop building has been completed and is in service for assembling various pieces of pipe prior to their being installed in the plant structures. A construction office building houses offices and working areas for Field Engineering personnel.

Laydown areas have been graded and fenced to provide outside storage for large components. The building which was used for partial assembling of containment liner plates will be removed from the site.

The building which was used for sandblasting and painting the contain-ment liner plates is being relocated on the site and will serve as a painting and electri al shop. A railroad bridge and track which connects the site with a rail spur has been completed and is being used to trans-port materials to and from the site. A concrete batch plant with ad-Jacent storage areas for aggregate and sand is in service. Access roads and parking areas for construction personnel have been completed and the major access road.has been blacktopped. A meteorology tower has been in service for approximately two years. The dike work for the 880 acre cooling pond is complete except for the dikes immediately ad-jacent to the plant. Seeding, mulching and rip-rap of the dikes is virtually complete. The excavation for the emergency service water cooling section of the pond has been ecmpleted. The service water

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I-6 piping and the pond makeup line are ceing installed. Piping for potable water from the City of Midland is completed to the railroad bridge and is teing installed from the railroad bridge to the plant. Sani-tary system pipir- being installed. The piling which will serte as a cofferdam during the construction of the river intake structure and the pond makeup pump structure has been installed. Earthwork and concrete work for these structures is in progress.

B. Schedule of Work Act:,tties To Be Comoleted at the Site I have attached as Consumers Power Company's proposed Exhibit 4 a month-by-month breakdown of the work activities scheduled between 9/1/76 and 9/1/77atthesite. Ibe 9/1/76 date was chosen to provide a background of the work to be acecmplished between 12/1/76 and 9/1/77 The scheduled work activities are broken down into the following seven major categories:

1. Auxiliary building.

2. Containment building #1.

3. Conta h ant building #2.

4. Turbine building #1.

5. Turbine Building #2.

6. Yard structures and i=provements.

7. Subcontracts.

Themajoractivitiesthatwilloccuratthesitebetween12/1/76and 9/1/77 can be summarized as follows:

1. Auxiliary Building - The five major activities scheduled during this period are concrete placement (1) for the control tcwer area walls and alab; (2) for the fuel pool areas valls; (3) for the radwaste and equipment area walls and slabs; (4) for the solid radwaste addition; and (5) piping installation for auxiliary systems.

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2. Containment Building #1 - The four major activities scheduled during this period are concrete placement (1) for the interior concrete cover slab; (2) for the shield walls against the liner pl'ate; (3) for the containment exterior concrete and placement of' the dome cover; and (4) for the reactor vessel pedestal, primary and secondary shield walls and letdown cooler walls.

3 containment Building #2 - The three =ador activities scheduled during this period are concrete placement (1) for the centainment exterior concrete and dome cover slab; (2) for reactor vessel pedestal, prtnary and secondary shield walls; and (3) for the letdown cooler walls.

4. Turbine B"N4ng #1 'Ihe two major activities scheduled during this period are concrete placement (1) for the main and auxiliary bay; and (2) for exterior walls to grade.

5 Turbine Building #2 'Ihe major activities scheduled are concrete placement of the elevated slabs and installation of structural steel.

6. Yard and Miscellaneous Structural Work - The eight major activities in this category scheduled during this period are (1) earthwork associated with yard service water piping and electrical duct work; (2) etrthwork, concrete placement and dewatering for the circulating watet and serrice water building; (3) earthwork, associated with the site sewer lift .ation; (4) earthwork and concrete placement

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for the process steam tunnel and administrative building foundation; (5) eartiraork and concrete placement for the circulating water dis-charge structures and yard circulating water piping; (6) earthwork

, for the evaporator, auxiliary boiler and waste treatment buildings; (7) eartireork and devatering for the emergency pond serrice water return piping; and earthwork for plant backfi1Mng to grade.

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I-8 I have also attached as Consumers Power Company's proposed Exhibit 5 a table which can be used to establish the expenditures for the Midland project on a month-to-month basis until 9/1/77 assuming construction continues. These cash expendit,ures can be related to the work activities scheduled by comparing Exhibit 5 with Exhibit 4. As shown by Exhibit 5, as of December 1,1976, Consumers Power will have expended $412,363,000 for the construction of Midland. If con-struction were to continue from 12/1/76 to 5/1/77, the additional expenditure would be $87,377,000. If construction were to continue from 12/1/76 to 9/1/77, the additional expenditure would be $182,562,000.

The total expenditure at Midland, if construction were allowed to continue to 5/1/77 would equal $499,740,000 out of a projected project cost of $1,670,000,000. Likewise, if construction were allowed to continue to 9/1/77, total plant expenditure would be $594,925,000 out of a total project cost of $1,670,000,000s

II-1 II. C. ACRS IntheMidlandACRSlettersof6/18/70and9/23/70,theACRSstated that: "Other problems related to large water reactors have been iden-tified'by the Regulatory Staff and the ACRS and cited in previous ACRS reports. The Committee believes that resolution of these items should apply equally to the Midland Plant, Units 1 and 2." In its decision, the Court of Appeals requested the ACRS to clarify that statement.

Since the ACRS has not yet identified the "other problems" to which it referred, a review was made of the ACRS generic letters of 12/18/72, 2/13/74,3/12/75and4/16/76. Additionally, a review was made of ACRS letterspublishedbetween1967and12/18/72 to identify those generic items raised by ACRS which were not set forth in the 12/18/72 letter.

For those items in the 12/18/72,2/13/74,3/12/75and4/16/76ACRS generic letters which have been resolved, and for generic items raised prior to the 12/18/72 letter, a review was made to determine whether Midland ccmplies with the generic resolution, or with the resolution for items from the pre- 12/18/72 letter. If an item has been resolved and it has not yet been dete mined whether Midland ecmplies with the resolution, it has been listed as "open" and a review was made to de-termine whether completion of the construction activities set forth in Exhibit 1 would foreclose the adoption of the ACES resolution.

Items for which there have been no resolution by ACES have not been addressed in this testimony since no alternative to the resolution proposed by the Applicant has been identified by the ACRS and thus no detemination can be made as to whether an alternative would be fore-closed by continued construction.

II-2 In order to simmarize this review, I have attached as Consumers Power proposed Exhibits 6(a) - 6(e) matrixes setting forth the conclusions reached in our review. This section of the testimony will address those items which have been resolved by ACRS but which are still open.

Exhibit 6(a) is a matrix showing specific ACRS concerns identified in the June 18 and September 23, 1970 Midland ACRS Reports and indicates the stai'is of compliance by Midland for these items.

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II-3 Exhibit 6b is a matrix showing other concerns which we have been able to identify relating to large water reactors which were cited by the ACRS in its reports prior to the ACES generic letter of 12/18/72. This

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matrix is limited to items which do not appear in the Iddland ACRS letter or in any of the ACES generic letters dated 12/18/72,2/13/74, 3/12/75 and 4/16/76. The matrix does not include ite=s which are ap-plicable only to BWR plants.

Exhibit 6c is a matrix of items frcm the ACES' letter of December 18, 1972 entitled " Status of Generic Items Relating to Light Water Reactors."

Exhibit 6d is a matrix of additional items added by the ACRS letter dated February 13, 1974 entitled " Status of Generic Items Relating to Light Water Reactors."

Exhibi't 6e is a matrix of additional items added by the ACRS letter dated March 12, 1975 entitled " Status of Generic Items Relating to Light Water Reactors."

Exhibit 6f is a matrix of additional items added by the ACRS letter dated April 16, 1976 entitled " Status of Generic Items Relating co Light Water Reactors: Report Number 4."

In June 1974 Consumers Power initiated discussions with the Staff con-cerning implementation of Regulatory Guides (reg guides) from 1.1 to 1.75 At that time, it was agreed that reg guides after 1.75 would be reviewed with the Staff after issuance of the Final Safety Analysis Report (FSAR) scheduled for submittal in September 1977 Due to the length of time between issuance of the Construction Fermit and preparation of the FSAR and the number of reg guides issued and modified in this time period,

II h Consumers Power deemed it prudent to have an interim review by the Staff in order to finalize plant design. Consumers Power submitted reg guide positions, discussions were held with the Staff, written responses were made to questions issued by the Staff and written Staff positions were received. The results of this review have been included in the exhibits.

With respect to Exhibit 6a, Midland canpliance is currently assured for all items except for Items 8 and 12 which require additicnal discussion with the NRC Staff to establish compliance.

Item 8 concerns physical and electrical independence of the redundant portions of protection and emergency power systems.

The Staff ha.1 issued Reg Guide 1.75 which addresses this sub-ject. Consumers Powar has presented its position on Reg Guide 1.75 and bas !ad several discussions with the Staff on the reg guide. With the exception of the issues listed below, we are currently in full compliance and centinuation of construe'; ion would not foreclose the implementation of the final resolution of the issues.

A. There are three types of circuits discussed in Reg Guide 1.75.

These are Class lE, non-class 1E and associated circuits.

Class lE circuits are those which relate to systems and com-ponents that are safety related. For all of these cleases of circuits the Midland Balance-of-Plant (BOP) design will meet the requirements of Reg Guide 1.75. Non-Class 1E circuits are those circuits which relate to non-safety related components and do not have to meet separation criteria; however, they must be separated from Class lE and associated circuits. Associated circuits are those non-lE circuits that share power supplies, I i

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II-5 enclosures, or raceways with 13 circuits or are not physically separated from 1E circuits by acceptable sepa-ration distance or barriers.

In the Midland design, efforts are made to preclude the use of associated circuits. However, in some instances involving computer and annunciator inputs, the actual circuit design dictates the use of associated circuits. In such cases, asso-ciated circuits are treated in accordance with the requirements set forth in Reg Guide 1.75, which include as an acceptable approach, an analysis of associated circuits to demonstrate that lE circuits are not. degraded below an acceptable level.

'Ihese associated circuits are being analyzed at this time with results to be included in the FSAR. If the results indicate that scme Class lE circuits are degraded below acceptable levels, appropriate isolation devices will be installed between the Class 1E and the associated circuits. Continuation of con-struction through September 1977 vill not foreclose the capa-bility of installing these isolation devices.

B. With respect to NSS signals and panels, isolation devices within the cabinets are provided in accordance with Reg Guide 1.75 Reg Guide 1.75 requires that within cabinets there be six inches separation between 1E and non-lE wiring unless a lesser separa-tion can be demonstrated as acceptable by an analysis based on tests performed to determine the flame retardant character-istics of the wiring, wiring materials, equipnent, and other materials internal to the cabinet. Tests and analysis have been perfomed and the results permit less than six-inch physical

II-6 separation between IE ar.d non-15 wiring within the cabinet and do not require the use of barriers internal to the cabinet.

Noise rejection tests have also been run on B&W equipment (Reactor Protective System and Energency Core Cooling System Actuation Panels) to determine its capability to function when noise signals are tapressed. The results of these tests will be reviewed with the Staff for acceptability. If not considered acceptable, additional tests, modificatf ons or additions to the cabinets may be necessary; this would not be foreclosed by continuation of construction.

With respect to Item 12 (A1WS) the ACES considers this item resolved at this time by WASH-1270. WASH-1270 was published in September 1973 and there have been discussions between the Staff and B&W on imple-mentation and several B&W Topicals have been issued. B&W is presently doing an analysis in response to the Staff's request and a specific Midland B&W Report is scheduled for mid-1977. Until the B&W reports are completed, we will not be able to specifically identify the modifications which may result from the analyses. However, some or all of the following items may have to be utilized for Midland to comply with the Staff's implementation of WASH-1270.

1. ESFAS/RPS Diversity ihe present system of design for the Engineered Safeguards Features Actuation System (ESFAS) and the Reactor Protective Syste= (RPS) is made up of three separate systems. The B ergency Core Cooling Actuation System (ECCAS) is supplied by B&W and is a subsystem of the ESFAS system which will not be supplied by B&W. The RPS is also supplied s

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4 II-7 by B&W. If the Staff evaluation requires that there be ecmplete diversity between the ESFAS and the RPS, this could be accomolished by chang 4_ng system design or supplier of one of the systems. This would not be foreclosed by construction continuing.

2. Containment Purge It may be necessary to close the contnAn=ent purge valves to prevent the postulated release from going off-site. This can be accomplished by closing the purge valve on reactor trip or high containment radia-tion. Continuation of constntetion does not foreclose making this change.

3 Reactor Coolant Pumn Casing Thickness Adequacy for Handling Pressure Limit An analysis of the reactor coolant pumps may have to be perfor=ed to determine whether their casings are thich enough to handle the pres-sure transient. If the pressure transient cannot be handled by the casing design, reactor coolant system relief capacity may have to be increased. Continuation of construction does not foreclose increasing this capacity.

4 Turbine Trip on Loss of Main Feedwater Circuitry may have to be included in the BOP to trip the turbine generator on loss of main feedwater to the steam generators. Steam generator level instrumentation is presently installed to provide actuation for such a signal. This vill not be foreclosed by con-tinued construction.

5. Auxiliary Feedwater Initiation Rapid initiation of anvilina feedwater to the steam generators may be required on loss of main feedvater or off-site power. This

II-8 can be accomplished with existing instrument circuits. Bis will not be foreclosed by continued construction.

With respect to Exhibit 6b, Midland is meeting the specific con-cerns raised by the ACES by either complying with the appropriate regulations and reg guides or by design of the plant, or by analysis.

The only exception is: Item 10, Testing of Engineered Safety Features has been resolved by the issuance of a number of reg guides. Consumers will perform all tests required by the appropricte edition of ASME XI, Reg Guides 1.22, 1.52 and 1.68. However, there are additional reg guides, such as 1 79, which address testing of engineered safety fea-tures which have not yet been resolved with the Staff. However, since these reg guides only require testing, continuation of const2nction will not foreclose this resolution of this item.

With respect to Exhibit 6c, Midland complies with all items which have been resolved except for the following:

1. Item No 11 Quality Assurance. The Consumers Power Quality Assur-ance Program Manual (Topical Report No CPC-1A Revision 4) outlines the actions which are imple=ented by Consumers Power and its suppliers and indicates how Consumers Power will comply with the Quality Assurance requirements specified in NRC re ;ula-tions, reg guides and industry standards. The Staff has accepted this program except for the following minor ite=s:

a. A statement of effectivity dates for certain updated procedures rust be provided;

b. Se Consumers Quality Assurance Program Topical Report Revision Number and date must be identified; l

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c. A typographical error must be corrected with respect to Reg Guide 1.39 on Housekeeping Requirements;

d. Siitorial changes must be made with respect to Reg Guide 1.54 on Quality Assurance Requirements for Pro-tective Coatings and Reg Guide 1 94 on Concrete and Structural Steel;

e. A commitment must be made to ecmply with Section C.2.a of Reg Guide 1.55 on Concrete Placement; and

f. Exceptions to commitments in the program must be pro-vided for plant design, procurement, fabrication and construction which has alreedy taken place.

A submittal incorporating these requirements was provided to the Staff on November 3, 1976. Since these items have been effectively resolved and procedural changes are already being made, continua-tion of construction vill not foreclose their resolution.

2. Item No 13. An Independent Check of Stress Analysis was not performed on all NSSS components, since some of the com-ponents were designed to the requirements of the 1%8 edition of the ASIE Code, Summer 1968 Addenda which did not require an independent review. Continuation of construction would not preclude making an independent review if it is required.

The reactor coolant pu=ps, pressurizer safety valves, and letdown coolers were designed to the 1971 edition of the AS2E Code and, therefore, an independent review has been or will be performed on these co=ponents.

3 Item no 20. Capability of the pri=ary biological shield (reactor vessel cavity) to withstand a LOCA at the safe ends. The cavity design for Midland is based on preliminary mass energy release data which are not expected to charge significantly when the final calculations are performed.

'Ihe cavity is designed for 250 psi differential pressure

II-10 with all stresses ramining within elastic limits and for 1,000 psi differential pressure without exceeding ultimate strength. As required by the Midland ACRS letter, this design is comparable to those of the Zion and Indian Point 3 Plants. Additionally, since the cavity design incorporates cpecific features to limit blowdown into the cavity such as collars around the nozzles to direct blowdown outside of the cavity, the plant will comply with this item.

4. Item No 21. Although the construction of one unit while the other is in operation has not been fully resolved at this time, the construction and startup schedule for the Midland Plant has been planned so that all systems and struc-tures which are common for both units and which are necessary for operation of the first unit are scheduled to be com-pleted and tested before the first unit goes into service.

Access to plant areas such as the control room or other areas that contain common equipment will be under adminis.tra-tive control, or barriers will limit access of construction personnel into areas that effect the operating unit. There-fore, continuation of construction will not foreclose resolu-tion of this item.

5. Item No 24. Ultimate heat sink. The preli=inary analysis of the emergency pond ,(ulti= ate heat sink) based on Eeg Guide 1.27 assumptions indicates that the peak pond te::gera-ture could be 3 5 F above the service water system design temperature for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under the most ad-verse conditions. During the operating license review,

II-ll Consumers can either demonstrate that safety equipment design temperatures will not be exceeded or that all safety related equipment whose design temperature could be temporarily exceeded will be able to function for as long as needed. Finally, since safety related equipment

' could be protected by imposing a technical specification limit on plant operation when the ultimate heat sink reaches a predetemined temperature, continued construction does not foreclose resolution of this item.

6. Item No 32. Perfomance of critical components in post-IOCA' environments. The Midland Plant complies with all reg guides applicable to this item except for Reg Guide 1.89 which has not yet been discussed with the Staff.

Until the implementation of this reg guide is resolved with the Staff, exact modifications which may be necessary to comply with the resolution of this item cannot be identified. l l

However, continuation of construction will not foreclose implementation of Reg Guide 1.89 since equipment has been purchased with the requirement that it function under post-LOCA radiation and steam environments. If it is required that aging effects be factored into equip =ent already purchased or in the process of being purchased, this could be accomplished by conducting tests for on-going environmental effects on equipment after the plant goes, into service.

7. Item No 35. A1WS. Refer to the discussion of Ites No 12 in Exhibit 6a.

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8. Item No 36. Radwaste Management. This it s has been resolved by the issuance of Appendix I to 10 CFR 50. 'Ihe Midland analysis which shows compliance with the effluent discharge requirements of Appendix I is currently under review by the NRC Staff. Since redwaste treatment for Midland utilizes a recycle system, it is not expected that the Staff review will result in system modifications.

However, if changes are recommended, modifications to the radwaste system would not be foreclosed by continued con-struction.

With respect to Exhibit 6d, all items are unresolved except for Item 3 (Fuel Densification) with which Midland complies and Item 9 (Steam Generator Tube Leakage) which has been partialb resolved

- by Reg Guide 1.83. The primary ACRS concern with Item 9 is the effect of prior degradation on steam generator tube integrity in i

the unlikely event of a LOCA. Reg Guide 1.83 requires a base line and subsequent in-service inspections to detect tube degradation.

Midland will comply with this reg guide.

With respect to Exhibit 6e, the only item which is resolved is Item 4 on seismic Category I requirements for auxiliary systems.

The Midland Plant ecmplies with the reg guide which resolves this item.

With respect to Exhibit 6f, none of the items have been resolved by ACRS.

Thus, based on this review, continuation of construction will not foreclose the implementation of those generic items which have been resolved by the ACRS.

III-l III. EFFECTS OF DEIAY A. Delay Costs If it is assumed that, as a result of this hearing, the Construction Pennits are suspended from 12/1/76 to 5/1/77, then there would be a delay of 9 months in the commercial operation dates of the Project.

Unit 2 would have a commercial operation date of 12/1/81 instead of 3/1/81 and Unit I would have a commercial operation date of 12/1/82 instead of 3/1/82. The 5-month suspension period results in a 9-menth delay in the commercial operation date due to a combination of the following:

1. Uncovering, inspection, and cleaning of materials and building areas could not commence until May 1, 1977;

2. 21e recruitment, organization, training, qualification, and assignment of all manual labor workers to all work areas could not be completed until some of the activities set forth in

1. above are finished; and 3 The time required to increase manpower to the levels existing previously is contingent upon partial completion of 2.

Based on our experience of past remobilizations in 1973 and 1975, it would take at least the 4 additional months to acccmplish these tasks. In addition, this 9-month delay period cannot be reduced after restart of construction since the assu=ptions already include double shifts. Addition of another shift and hiring extra personnel are not feasible due to the limited number of available craftsmen, the limitation en the number of people who can work in a limited area and the decline in productivity for those workers already on site.

III-2 he resultant delay in commercial operation date of 9 months assumes that:

1. Unrestrained commercial reactivation will commence on May 1, 1977

2. Project activities will be oriented cowards minimizing the impact of the 5 months' suspension in order to minimize effects of schedule delay.

3 Design engineering will continue during the suspension period.

4 Home Office manpower levels will remain the same as if construc-tion were not suspended.

5 De delivery schedule for existing material and purchase orders will not change, but future equipment and material purchase order deliveries will be in accordance with the revised schedule.

6. no cash flow limitations will apply during the suspension period or beyond.

7 Field nonmanual personnel will be retained at the current level in order to support unrestrained reactivation on May 1, 1977.

8. me construction craft labor force, including subcontractors, will be reduced to a minimum level consistent with supporting only such activities as site maintenance, co=pletion of material laydown areas off-site, and receipt in storage of plant equipment and materials.

Se suspension would cause the manual labor force to be widely dispersed.

However, for the purpose of estimating delay costs it has been assumed that an unrestricted supply of labor is available due to extensive re-cruiting efforts to support the ccnstruction reactivation co==encing 5/1/77. ne suspension also cames higher peaits in =anual labor needed for the Project. However, it again has been assumed that these extra men will be available.

III-3 If it is assumed that as a result of this hearing, the Construction Permits are suspended from 12/1/76 to 9/1/77, then there would be a delay of 15 months in the comercial operation dates of the Project.

Unit 2 would have a comercial operation date of 6/1/82 instead of 3/1/81 and Unit 1 would have a commercial operation date of 6/1/83 instead'of3/1/82. Based on our experience of past remobilizations, the 9-month suspension period would result in a 15-month delay in comercial operation dates due to the combination of factors which were set forth for the 5-month suspension period. In addition, these factors would be complicated by having to rehire and retrain Field engineers and by starting up in the fall and early winter rather than the spring and early summer. This postulated suspension of the Conetruction Pemit for 9 months and the resultant delays in the commercial operation date of 15 conths assu=es the sa=e conditions occur as discussed above for the 5-month Construction Pemit sus-pension, except that Home Office manpower levels would be reduced during the suspension period in areas which are related to construction activities and field non-manual would also be selectively reduced.

The conditions and effects resulting from this 9-month suspension would be the same as discussed above for the 5 months suspension except that the effects would be even more traumatic.

Attached as Consumers Power's proposed Exhibit 16 is a table which sets forth costs that would be incurred if the Construction Permits were suspended for 5 months or for 9 months. Exhibit 16 demonstrates that the total plant cost would increase $115,000,000 4 if a 5-month suspension was ordered. If the resulting $7,1409,000 increase in the cost of nuclear fuel and the $210,900,000 increase in the purchase and/or differential power costs for the 9-month delay in the operating date is added to the

III-4 increased plant costs, the total delay costs attributable to a 5 month suspension period would be $363,309,000. For a suspension period of 9 months, the total plant cost would increase $250,000,000, the nuclear fuel cost would increase $12,365,000, and the purchase and/or dif-ferential power costs for the 15-month delay in com=ercial operation would be $381,400,000. Thus, the total delay costs which would be attributable to a 9-month suspension would be $643,765,000. Se fol-lowing explanatory notes apply to Exhibit 16:

1. Where escalation is noted as being applied, a 7% per year compounded rate is used;

2. Se B&W delay costs are based on a stretch-out in the performance of B&W startup services, operator training, Project Management and site representative services which results in additional man-hours. Since the man-hours occur during a later period of time, the charges for them are escalated;

3. The process steam evaporator delay costs are additional costs for storing and handling evaporators for a longer period of time than initially planned;

4. Be turbine generator delay costs are those resulting from in-surance and storage for the additional time period;

5. The Bechtel balance of plant delay costs are made up of several components:

a. The manual labor component is due to additional labor for mothballing, maintenance, and reactivating the site; pro-ductivity losses due to learning and retraining during re-mobilization, increased shiftwork congestion and overtime, '

premium pay costs due to shift work and overtime, and escala-tion.

III-5

b. The nonmanual labor component is due to retaining non:nanual personnel on-site for longer periods of time, for shift work and overtime allowances and escalation.

c. The distributable component is due to increased equip-ment rental, beating of buildings, materials for moth-balling, caterials for building maintenance, field office overheads, insurance and escalation.

d. The direct materials and subcontract component is due to deferring and cancellation of some subcontracts, equipment and material warranty extensions cad escalation.

e. The engineering and home office support component is due to added man-hours for contract negotiaticas on varranty extension, determination of storage requirements, retaining personnel on the project for longer periods of time and escalation.

f. The contingency component is the amount of money which was added to provide for uncertanties associated with the sus-pension activities and their related costs.

g. The escalation ecmponent represents the increased corts for

=aterials, subcontracts, and labor which were nor-Ally planned to be incurred in a time frame established prior to the suspension delay, and will now be incurred at a later date due to the suspension of construction.

III-6

~

-. The Consumers delay costs are made up of the following com-ponents: ,

a. Se " directs" cceponent includes an extension in duration of the performance of management, engineering, other adminis-trative functions and escalation.

J

b. Me " administrative" component includes an increase in man-hours for the performance of corporate administrative functions not included in a. above. It includes functions such as purchasing and corporate accounting. Bis cost is computed on a percentage of all directs.

c. he "other overhead" component includes an increase in prop-erty taxes due to the application of current tax rates to a higher tax base (due to cost effects of delay) over a longer period of time (due to extended completion date);

insurance is also included for this longer period of ti=e and is escalated.

d. We " allowance for funds used during construction (AFUDC)"

component is computed on the basis of a rate of 6% for the delay period through 1976 and at a rate of 6-1/25 thereafter.

The rates are applied to the cash flow schedule, taking the effect of the delay on cash flow into account. The increase in AFUDC also reflects the application of these rates to al-ready incurred costs for a longer period of time.

e. Ihe " miscellaneous work orders" component was ccmputed by:

(1) Increasing the land cost by adding to the land purchase price the AFUDC required for a longer period of time;

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J III-7 i

(2) Escalating the costs for spare parts, since their purchase will be made at a later date; i

l (3) Holding constant the cost of Electric R&D and the reloca-tion of the Bullock-Dow transmission line; and

~

(h) Increasing licensing costs to handle responses to the Appeals Court decision and applying AFUDC to this in-4 crease for the extended period of time.

7. 'Ibe exhibit also indicates the additional costs of nuclear itel resulting from the delay. This cost is based upon an evaluation i

of the fuel contracts. Delivery schedules in these contracts have been slipped where possible to the ==W== extent permitted.

For the fuel contracts, an 8% escalation rate was used. Where slippa6e is not permitted by the contracts, the item is assumed to be delivered on the initial schedule and AFUDC is applied i for the additional period of time.

8. Exhibit 16 also , includes the cost of replacement power and/or differential power to make up for the period of delay. The derivation of these costa is set forth in the testimony of Gordon L. Heins.

Although the added escalation for future construction craft labor contract negotiations has been included, a delay of the

magnitude which would Se caused by the suspension requires Consumers Power to face an additional round of contract negotia-tions with the craft unions employed on site. The impact of additional negotiations has not been factored into the delay l costs. However, experience has shown tnat work stoppages often

III-8 result during contract negotiations. For example, in the year 1976 between April 30 and July 16 there were 13 construction craft labor contracts negotiated and during the negotiation period there were 5 work stoppages. Some of the effects of short-term, ie, up to one month, work stoppa6es on the Project schedule might be rectified by working double shifts and putting more manpower on the job; however, this increases costs. Adding more manpower also causes hiring peaks which may not be capable of being supplied from the available labor fe.rce. ,

Since the Midland Project has already experienced previous shutdowns, additional shutdowns will have an effect on Project morale. Experience has shown that key people begin resigning for e=ployment on other jobs. In addition, when the Project is remobilized, prospective employees looking at the past his-tory of buildup and layoffs may refuse to take employment on the Midland Project if co= parable employment can be obtained elsewhere. Another factor not te. ken into account is the effect on warranties on equipment which are normally written to be in effect for a given period of time after deliver / of equipment on-site. While the cost of renegotiating and extending warranty covera 6e is included in the delay cost, the cost for self-insurance for those items for which extended warranties cannot be obtained is not included. No dollars have been factored into the cost of delay for any of the above items.

/

III-9 32e effect of delay on The Dow Chemical Ccepany is set forth in the testimony of Joseph G. Temple, Jr.

In addition to the previously described cost increases which would result from a postulated delay, it must be recognized that there are other short-term and long-term socio-eccnomic impacts if construction of the plant is stepped for any length of time. The largest short-term impact would be the immediate layoff at the site of approximately 700 construction craft personnel,100 nonmanual (professional, administrative, and executive), and approximately 100 subcontractor personnel.

While the socio-economic impacts of the loss of these jobs cannot be identified with certainty, it has been estimated that a loss of 1,200 jobs would impact the Midland community approximately as follows:

a. 4,308 less people.

b. 1,092 less school children.

c. $8,520,000 less personal income.

d. $2,748,000 less in bank deposits.

e. 36 fewer or reduced retail establishments.

f. 1,16h fewer passenger cars.

g. 780 less people employed in support jobs.

h. $3,972,000 less in retail sales per year.

Even if these impacts, which are based upon a U.S. Chamber of Cc=merce formula, are reduced to assume that only 900 employees at Midland are laid off and that a number of those laid off stay within the area, there would still be a significant i= pact on the Midland co== unity. This

III-10 impact would be compounded by the fact that there are no other large construction projects scheduled in the Midland area during the period that construction would be suspended.

Additionally, the economic cost of unemployment will include payment of unemployment compensation for those individuals who are laid off. It has been estimated by the Midland Chamber of Co==erce that if 1,200 workers were laid off at Midland a minim m expenditure of $3,206,000 would be required during the 26 week eligibility period. Assuming the mav4m"m allow.nce, this expenditure could be as high as $h,100,000.

Since the State of Michigan c1 ready owes the Federal Government $1.6 billion for funds borrowed to finance unemployment compensation, this figure, even when scaled down to reflect the loss of 900 jobs and some of the unemployed moving out of the State, it is still an enormous eco-nemic burden on employers, unemployment compensation insurance carriers, State and Federal Government.

Tax _evenues would also be lost by the City, County, State and Federal Gcvernments as well as school districtc in the form of personal property, sales and income taxes. Financial support for public schools in Michigan is based on a " taxing power equalization" principle under which the State guarantees a standard revenue return on the first 28 mills of tax levy.

Beyond 28 mills, the school district is empowered to collect whatever amount of tax its locally-voted tax rate, applied to its local evaluation per student, will produce. According to Midland Public Officials the Midland School District levy for operation this year is 32.6 mills of tax on an evaluation per student of $44,500. This is above both the State-equalized tax rate and the State-equalized evaluation per student.

Therefore, any diminution of taxable valuation in the school district would reduce the available tax revenue. If a suspension of nuclear plant

f III-11 construction occurs, the taxable valuation will not increase as planned.

Thus, the costs for other taxpayers would probably increase as Midland public officials have indicated that there would be no significant de-cline in the cost of education if a work force of 300 400 remains.

Taxpayers would also incur other added costs. County pay =ents for Gen-eral Assistance had been reduced 607,during the last year, and this fig-ure could not be kept down. Demand for and costs of cental health services would also be likely to increase. Spreading taxing requirements over a disproportionately smaller base would increase individual costs.

Decreased tax revenues would not change the fixed costs of governnent services, so that absent a large increase in tax rate or property valua-tion the number and quality of services would decrease.

Suspension of construction activities would also have a hamfbl effect on aspects of cnmrmmity planning. As pointed out by Midland public of-ficials, the quality of the educational atmosphere would be hamed not only by a loss of tax dollars, but by the disrupted and disorgani::cd climate under which teachers and students would have to exist. A Midlar.d city official also noted that it would beccme i=possible to project hous-ing needs, which in turn would prohibit decisions on when and how to in-prove or expand utility systems. The nu=ber of Midland Project workers havingMidlandaddresses,361,representsapproximately1-1/2yearsof housing starts at the current rate. The city is presently planning for possible construction of 7 miles of 48-inch water main for additional

III-12 deliveries of raw water at a cost <' $3 million. This planning would be seriously-i=peded by a s mension of construction.

Finally, the effect of a suspension of construction on co=ranity morale would be devastating, as was noted by a co::n:: unity religious leader. The crime rate has been related to that of unempicyment; in February 1975 when the unemployment rate was 15.2%, the Midland County jail was full.

Once une:::ployment declined to 10.2% in September of 1976, the number of arrests also decreased.

Thus, while the actual socio-econo.J.c L:: pacts cannot be specifically quantified, it is clear chat suspension of construction and the result-ing lay-off of 900 workers would have a significant adverse impact on the cc:nmunity.

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IV-1 IV. ECONOMIC COST OF ASArDOMET Consumers Power proposed Exhibit 16, attached hereto, sets forth estimates of abandonment cost data utilizing several cases. For each of these cases the data set forth were calculated as folu vn-

1. " Plant Expenditures to Date" were obtained by taking the actual costs through8/31/76andaddingtheestimatedexpendituresfortheperiod during which construction is continued. For the suspension cases, additional a=ounts which mast be expended assuming suspension of 'on-ssruction are also included. In order to obtain the salvage value of material already purchased, all material purchase orders and subcon-tracts of over $100,000 in value were reviewed. After review of the subcontracts it was decided that they had no salvage value. For the material orders, salvage values were determined based on whether the material eculd be utilized for resale to another utility or sold for scrap. The total value of materials and subcontracts whose individual.

value was less than $100,000, was assumed to be one-half for =aterials and one-half for subcontracts. No salvage was assumed for the sub-contracts. A d salvage value was assumed for the materials.

2. For materials and subcontracts cccmitted but not paid for, each indi-vidual order was analyzed on the basis of its completion status to estimate the cancellation costs as of the date of cancellation. This figure is not used in the cost of abandonment calculations, but is shown to indicate the value of ec==itted expenditures. Il a cancel-lation cost is paid, Consumers power would obtain ownership of the component and its built in value. Therefore, salvage value was

17-2 e::tfmated based on whether the cc:sponent could be resold or scrapped.

No salvage value was taken for subcontracts.

3. Expenditures for nuclear fuel were obtained by taking the booked costs through8/31/76andaddingtheexpendituresto 12/1/76,5/1/77and 9/1/77asapprepriate. Since scme of the mel contracts can be slipped, the additional fuel cost, if construction is suspended, was obtained by adding the cost of escalation where the contracts accom-modated a slippage and additional AFUDC for those contracts which can-not be slipped. " Fuel Cost Co::mitted, But Not Paid," is not used in the cost of abandonment calculations. The cancellation cost of the fuel is based on the fuel suppliers' costs included under the contract for which payment has not been made. The salvage value of the h el was obtained by assming that Consumers Power could sell its fixed commi+: ment enrichment contracts, and that it could sell the uranium concentrates for which it has ccmmit=ents at todays world :::arhet prices.

4. Since orders of the Midland Township Zoning Board of Appeals reqaire Consumers Power to re=ove the dikes and restore the area covered by the pond to its former condition if the site is abandoned as a gen-erating facility site, restoration costs for this work were calculated.

Copies of the orders are attached as Censumers Power proposed Ex-hibit 18(a) and (b), are attached hereto. In order to bring the site back to topographical conditions as near preconstruction status as possible, the site restoration costs also include re= oval of l

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1 i

IV-3 stmetures to original grade level. These costs were based on costs of similar type work activities '<hich Consumers Power has experienced at Karn and Iddland.

5. SincetheDov/ConsunersPowerSteamserviceContract, Exhibit 7(c),

includes a requirement fo:' Dow to reimburse Consumers Power for certain costs if the plant cannot be ecmpleted, this reimbursement cost was included as a credit in the costs of abandonment.

6. Since it is unrealistic to assume sufficient quantities of oil or gas would be available for an alternative plant the size of Iddland; and since long lead times on licensing and constmetion make it i=possible to construct a nuclear alternative at another site on a schedule which wculd allow Consumers Power to meet its projected leads; coal fired facilities are the only feasible alternative to Midland Units 1 and 2. These coal facilities could be fired by either high or low sulfur coal. In order to brir4 such units on line as soon as possible, thereby minimizing the costs of differen-tial and purchased power, it was assumed that each of two 800 We

-units would be constructed on a different existing Consumers Power site which is already partially developed. Using these assumptions, the earliest date on which these units could be in service is 1984.

The capital costs for the coal fired alternatives were based on 1976 dollars for the Consumers Power 800 We Campbell unit which is scheduled for operation in 1980. These Campbell 1976 capital costs were then escalated at 7% per year for 1984 operation.

7 Thepurchasedpowerand/ordifferentialpowercostswerecalculated using the period from the Midlend in-service dates of 1981 and 1982

IV-4 to the alternate units in-service date of 1984 These costs are based on expected loads during these years, upon use of the most economic dispatch procedures for the ecubined Consumers-Detroit Edison system and upon porchase of power from outside this system.

It is also assumed that Consumers Power's Palisades Nuclear Plant is on line but derated at 5% per year.

8. The Midland to-go capital costs are based on the current estimate of $1.67 billion less the plant expenditures shcvn "to date." For columns 3 and 5, which assume suspension of construction and sub-sequent abandonment of the plant, the to-go costs include the cost of suspension which is shown on Consumers Power Exhibit 15 9 The " Midland Operation Cost" includes fuel, operation and maintenance, nuclear insurance, and taxes. These costs are based on the plant being in service on the scheduled date and continuing in operation for 34 years. All the costs except nuclear fuel and taxes were escalated at 7% per year. Nuclear fuel costs were escalated at a co=posite escala-tion rate of 6-3/4%. The tax rate was held constant and applied to the estimated total capital cost for the particular case.

10 and 11. The " Alternate Plant Operation Cost" (low and high sulfur) include fuel, operation and maintenance, insurance and taxes. The costs are based on placing the plants in service 7 years after the date of abandonment and continuing to operate them for 34 years. The coal

. costs are based on 1976 costs which are escalated by 12% per year for 1977 through 1978 and then 10% per year for 1979 through 1983 Coal costs from 1984 on were escalated 9% per year. The operation

IV-5 and maintenance costs were escalated 7% per year frcm 198h on. The tax rate was held constant and applied to the capital cost of the coal units.

In order to prJvide a basis for comparison of costs of abandonment, three analyses using the above data have been provided.

Consumers Power proposed Exhibit 18, attached hereto, provides cost data which can be used to ec= pare cost of abandonment for 5 condi-tions. Thefirstconditionisabandonmentcostsat12/1/76. The secondconditionisabandonmentcostsat5/1/77assumingconstruction continues until that date. The third condition is abandenment costs at5/1/77assimingsuspensionofconstructionat12/1/76. The fourth condition is abandonment costs at 9/1/77 assuming construction con-tinues to that date. The fifth condition is abandonment costs at 9/1/77, ass'",4ng suspension of construction at 12/1/76 to 9/1/77 Analysis I show: thatforabandonmenton5/1/77,ifconstruction continues, there would only be $22 million more spent on plant ex-pendituresthanifconstructionwassuspendedbetween12/1/76and 5/1/77 In addition, the total cost figure for abandonment is only

$35millionmoreifconstructioncontinuesbetween12/1/76and5/1/77 than if construction is suspended for tha; period. The additional

$22 million is only 1 3% of the total estimated project cost and by spending this, $22 million dollars, a delay cost of $363 million is avoided. Therefore, it is more logical to spend the incremental $22 million, in order to avoid a potential delay cost of $363 million,

IV-6 than to suspend construction based on a potential increase in abandon-ment costs of only $35 million dollars. A similar conclusion can be reached for the )/1/77 abandonment case since an additional $60 mil-lion in plant expenditures, which is only 3.6% of total project cost, avoids a potential delay cost of $644 million, while suspension of construction results in a potential increase in abandonment cost of only $96 million.

Consumers Power proposed Exhibit 19, attached hereto, presents a ecm-parison of the cost to complete and operate Midland to the cost of aban-doning Midland and installing and operating an alternative source for the needed capacity (a low-sulfur coal unit) in the folicwing five cases:

1. If the decision were to be made at 12/1/76, costs are stated in terms of future value at the scheduled date of commercial operation of MidlandUnit2(3/1/81).

2. Ifthedecisionweretobemadeat5/1/77,assumingthatconst:uction continues until 5/1/77, costs are again stated in terms of future value at the scheduled date of commercial operation of Midland Unit 2(3/1/81).

3. Ifthedecisionweretobemadeat5/1/77,assumingthatconstruction wassuspendedfortheperiod12/1/76to5/1/77,costsarestatedin terms of future value at the then earliest possible date of commercial operation of Midland Unit 2(12/1/81), due to delays caused by sus-pension.

4. If the decision were to be made at 9/1/77, assuring that construction continues until 9/1/77, costs are stated in ter=s of future value at the scheduled date of ecmmercial operation of Midland Unit 2 (3/1/81).

rI-7

5. If the decision were to be made at 9/1/77, assuming that constntetion wassuspendedfortheperiod12/1/76to9/1/77,costsarestatedin terms of future value at the then earliest possible date of cc:::mercial operationofMidlandUnit2(6/1/82),duetodelayscausedbysus-pension.

This exhibit reflects the economic cost analysis which would have to be made, in each of the five assumed cases, in order to weigh whether cen-tinuation with Midland or abandonment of Midland and installation of an alternative is the preferred decision ors economic grounds at the point in time and under the conditions assumed. The analysis reflects all ap-propriate costs, including capital costs, taxes, operation and maintenance, insurance and fuel costs. Credit is given to the cost of the alternative for material salvageable frem Midland, reimbursement of certain capital costs by Dow and proceeds frem the sale of rights to nuclear fuel. Debits include the cancellation cosi, of material orders and subcontracts, net of salvage value, required site restoration costs at Midland and the pur-char i power and/or differential power costs incurred during the period between the scheduled cc:::mercial operation date of Midland and the earliest possible date of ec:::mercial operation of the alternate.

Consumers Power proposed Exhibit 20, attached hereto, presents the same ccmparison for a high-sulfur coal-fired unit alternative.

In each of the five cases, the cost of abandoning Midland and proceeding with the alternative far exceeds the cost of proceeding with Midland.

IV-8 Consumers Power proposed Exhibits 21 and 22 attached hereto reflect the fact that the cost ratio between abandoning ludland and proceeding with the assumed alternative on the one hand, and continuing with Midland ontheother,variesveryslightlyatthedecisionpointof5/1/77, whether construction has been suspended at 12/1/76 or continued to 5/1/77.

The same is also shown under the same assumptions for the decision point at9/1/77. consequently, these Exhibits establish that continued con-struction at Midland during the pendency of the remand proceedings will not alter the economic cost analysis between the alternatives of continuir4 with Midland, or abandoning Midland and installing an alternative, in any significant fashion.

For example, the economic cost ratio between abandoning Midland and con-tinuingwithMidlandat5/1/77assumingcontinuedconstructionis2.66 (forthelow-sulfurcoalalternative). This same ratio, assuming sus-pensionofconstructionat12/1/76,is2.59 consequently, the variation in the ratios is only 2.6%, which must be considered insignificant in view of the vast advantage of the nuclear alternative over one low-sulfur coal-fired alternative (over 250%).

i These analyses clearly establish that not only will continuation of cen-stzuction not tilt the balance away from the alternative of abandonment, l l

but it will not even affect the balance significantly.

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1

Exhibit 4 SCHEDULE OF WORK ACTIVITIES MONTH BY MONTH SEPTEMBER 1976 THROUGH SEPIDIBER 1977 Note: Components are listed in parentheses only where their installation is initially started in any given month. For subsequent months where installation of a component continues, the component is not listed again.

SEPTEMBER 1976 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, fomwork, embedded metal, conduit, process piping (radwaste drains) and concrete for the Control Tower area walls and slab to El. 632' .

2. Continue installation of reinforcing steel, formwork, embedded metal, conduit, process piping (fuel pool leak chase piping, fuel pool cooling piping) and concrete for the Fuel Pool area to El. 659'.

3 Continue installation of decking, reinforcing steel, formwork, embedded =etal, conduit, process piping and concrete for the Radwaste and Equipment area slabs and walls to El. 634' .

4. Continue installation of equipment (equignent drain tank, chemical vaste tank, decay heat removal heat exchangers, component cooling heat exchanger, radwaste decay tanks, laundry drain tank, boron recovery system receiver tank, liquid waste receiver and drain tank) and large piping (decay heat removal and component cooling) in the El. 568', 584' and 599' levels.

Facility: Containment Building #1

1. Continue Dome Liner final alignment and production welding.

2. Continue Liner Plate second lift align =ent and welding.

Facility: Containment Buildinst #2

1. Complete Dome Liner plate attachments assembly and welding, start sandblast and painting of internal plate.

2. Cbntinue installation of reinforcing steel, formwork, embeds '

and concrete for the Exterior Concrete to El. 683' .

3 Continue installation of decking, reinforcing steel, fomwork, embedded metal, conduit, process piping (drains and block outs) l l

2 Facility: Containment Building #2 (cont'd) ,

and concrete for the Secondary Shield Walls (cavity access air transfer ducting) and R. V. Pedestal and Primary Shield (primary coolant piping and in-core tubing block outs) Wall to El. 612' and Letdown Cooler Walls to El. 630'.

Facility

Turbine Building #1

1. Continue installation of reinforcing steel, formwork, embedded metal, conduit, process piping and concrete for the Main and -

Auxiliary Bay base mat at El. 614' .

2. Complete installation of reinforcing steel, formwork, e= bedded metal, conduit, process piping and concrete for the T/G Pedestal base mat at 614' and columns above 614' .

3 Begin installation of reinforcing steel, fomwork and concrete for the exterior wall to grade.

Facility: Turbine Building #2

l. Continue reinforcing steel, fomwork and concrete for exterior wall to grade and Feedwater Pump pedestals.

Facility: Yard Structures & Improvements

, 1. Begin installation of Service Water piping from Station E-325

'to Station E-500. (Earthwork).

2. Continue excavation and begin mud-mat concrete placement for the Circulating Water Building Sump base slab and walls and Service Water Building base slab and walls. (Earthwork and dewatering).

3 Continue installation of yard Sanitary System piping.

(Earthwork).

4. Continue installation of the Potable Water piping from the Midland City main to Station E-200. (Earthwork).

5 Continue installation of the Circulr. ting Water Pond Makeup and Service Water Cooling underground pipe between the Cooling l Tower and Station S-4850. (Earthwork).

Facility: Subcontracts

1. Continue plant backfill and construction of Plant Dikes.

(Earthwork). Include seeding, mulching and rip-rap.

2. Continue erection of the Unit #2 High and Iow Pressure Condensers.

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,A, .'

. 3 Facility: Subcentracts (cont'd) 3 Continue painting the Auxiliary Building interior.

4. Continue constructicn of the River Intake Structure and Pond Make-up Pu=p Struccure. (Earthvcrk).

OCTOBER 1976 Facility: Auxiliary Building

1. Continue installation of deckin6, reinforcing steel, for= work, edledded cetal, conduit and process piping and concrete for Control Tower area valls and slab to El. 646',

2. Continue instal 3stion of reinforcing steel,, for= work, embedded metal, conduit and process piping and concrete for the Fuel Pool area valls to El. 659' .

3 Continue installation cf decking, reinforcing steel, for= work, ebbedded netal, cenduit and precess' piping and concrete for the Radwaste and Equipment area valls north of the Fuel Fool to El. 646', ,

4. Continue installation of equipment and large piping in the elevation 568', 58h' and 599' levels. .

5 Begin installation of electrical equipment (motor control centers, lead centers, 4160 volt switchgear) at the 61k' level in the Cen-trol Tower.

Facility: Centainment Building 61

1. Continue De=e Liner final align =ent and production velding.

2. Continue Liner Plate second lift align = eat and velding.

3 Continue installation of the Equip =ent Hatch.

4. Continue installation of reinforcing steel, for= work, embedded metal, conduit and process piping and cencrete for the Cover Slab at El. 594'.

. Facility: Contair.=ent Building #2

1. Cenplete Dome Liner Plate sandblasting canipainting. Begin installatica of Do=e HVAC Ductverk and Spray and H, Vent Piping. Continue installation of Dcce Leakchase, Penetrations and Attach =cnts. .

e

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Facility: Containment Building #2 (cont'd)

2. Complete cutting Containment liner plate Construction Opening.

3 Continue installation of Containment liner plate Pipe Restraint Embeds.

4. Complete installation of reinforcing steel, fomwork, e= beds and concrete for the Contain.sent Exterior Concrete to elevation 693' .

5 Continue installation of reinforcing steel, fomwork, embedded metal (channels or blockouts), conduit and process piping (PLOCAP) for the Secondary Shield Walls to El. 605'.

6. Continue installation of reinforcing steel, fomwork, embedded metal, and process piping and concrete for the Primary Shield Walls to El. 612'.

7. Continue installation of reinforcing steel, fonverk, embedded metal, and process piping and concrete for the Ietdown Cooler Walls to El. 624'.

Facility: Turbine Building #1

1. Continue installation of reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Main and Auxiliary Bay base mat.

2. Begin installation of *.he T/G Pedestal Deck structural truss.

3 Continue installation of reinfarcing steel, fomwork, embedded metal; conduit and process piping and concrete for the Exterior Wall to grade.

Facility: Turbine Building #2

1. Begin erection of structural steel.

Facility: Yard and Miscellaneous Structures

1. Complete installing yard service water piping from the Auxiliary Building to Station E-325 (Earthwork).

2. Complete excavation for the Circulating and Service Water Buildings base slabs and begin installation of reinforcing steel, fomwork, embedded metal and concrete Circulating Water Building Sump base slab and the Service Water Building base slab. (Earthworkand dewatering).

3 Complete installation of Phase One of the yard Sanitary System piping. (Earthwork).

4. Complete installation of the Cooling Pond makeup and discharge piping from Station S-4550 to S-4870. (Earthwork).

.c

g. .

Facility: Subcontracts

1. Continue plant backfill as alleved by weather. (Earthwork).

2. Continue erection of the Unit 2 Condenscrs. Begin erection of the Unit 1 Condensers.

3 Continue civil constructicn of the yskeup Funghouse and River Intake Structurec. (Isrthwork).

4. Cc=plete painting Unit 3 de=e liner plate, begin installation of EVAC Dact.

NOVIM3IR 1976 Facility: Auxiliary Euildin:

1. Continue installation of decking, reinforcing steel, for=vork, e= bedded =etal, conduit and process piping and concrete for the Centrol Tcver area slab and valls to elevation 659'.

2. Centinue installa:icn cf decking, reinforcing cteel, for=verk, enbedded =etal, conduit and process piping and concrete for the Radvaste and Iquip=ent area slabs to elevation 646'.

3 Centinue installation of reinforcing steel, for=vork, enbedded

=etal, conduit and process piping and concrete for the Fuel Pool area valls to El. 639' .

4 Continue installation of equip =ent (decay heat pumps) and large piping in the elevation 563', 584' and 599' levels, 3egin installation of large pipe in the elevaticn 614' level.

5 Start installation of snall piping.

6. Continue installation of electrical equip =ent El. 614' level in the Centrol TcVer.

Facility: Contain=ent Building #1

1. Continue-De=e Liner final align =ent and production velding.

~

2.

Continue Liner Plate second lift alignment and velding.

3 Co=plete installation of the Iquipment Hatch.

4. Begin installation of reinforcing steel, for=vork Snd e= beds for the Iquip=ent Eatch pourback.

5 Continue the installation of reinforcing steel, formvork, embedded netal, conduit and process piping and concrete for the Cover Slab at elevatien 594'.

.+ '

. 6 Facility: Centain=ent Building 42

1. Cc=plete installation of Do=e HVAC Ductvork for contain=ent air coding. Cc=plete installation of Dc=e S, pray and H2 Purge Vent Piping.

2. Erect Polar Crane and Do=e Liner Plate.

3 Cc=plete installation of centain=ent liner plate Pipe Restraint Eibeds.

4. Continue installatica cf reinforcing steel, for= work, edbeds and concrete for the Centain=ent Exterior Concrete to elevatica 744'.

5 Continue installation of reinforcing steel, for= work, edbedded metal, conduit and process pipin6 for the Secondary Shield Walls to El. 605 ' .

6. Continue installation of reinforcing steel, for= work, edbedded metal and process piping and concrete for the Pri=ary Shield Walls to El. 612'.

7 Continue installation of reinforcing steel, for= work, edbedded metal and process piping and concrete for the Letdown Cooler Walls to elevation 631'.

Facility: Turbine Building 41 l 1. Centinue installation of reinforcing steel, for= work, e= bedded metal, conduit and process piping and cencrete for the Shin' and Auxiliary Bay base =at.

2. Cc=plete installation of the T/G Pedestal Deck structural truss, begin installation of reinforcing steel, for=vork, embedded =ctal, conduit and process pipin6

~

3 Continue installation of reinforcing steel, for= work, edoedded metal, conduit and process piping and concrete for the Exterior l Wall to grade. j Facility: Yard and Miscellanecus Structures i 1

1. Cortf/lue installation of reinforcing steel, for= work, e= bedded metal and concrete for the Circulating Water Building base =at and the Service Water Building base slab and valls to El. 600'.

Facility: Subcontra cts -

• l. Continue construction of the Pend Makeup Pu=phouse and River Intake Structures. (Ea rthwork). .

2. Continue erection of the Units 1,6 2 Condensers.

7 Facility: Subcontracts (cont'd) 3 3 Complete installation of Unit 2 Dome HVAC Duct.

DECD4BER 1976 Facility: Auxiliary Building

1. Continue instanation of decking, reinforcing steel, foz= work, embedded metal, conduit and process piping and concrete for the Control Tower area walls and slabs to El. 659'.

2. Continue installation of reinforcing steel, fomwork, embedded n ??,al, conduit and process piping and concrete for the Fuel leol area wans to elevation 659' .

3 Continue instanation of decking, reinforcing steel, fomwork, embedded metal, conduit and process piping and concrete foz the Radwaste and Equipment area walls north of the Fuel Pool to elevation 659'.

4. Continue installation of equipment (Boric Acid storage tank, degasifier decay tanks) and large piping in the El. 568' through 614' levels.

5 Continue installation of small piping.

6. Continue installation of electrical equipment in the elevatica 614' level, begin installation in the elevation 568' level.

Facility: Containment Building #1

1. Continue Dome Liner final alignment and production welding.

2. Continue Liner Plate second lift align =ent and welding.

3 Begin the instanation of the Air Purge and Main Steam Pipe Restraint embeds.

4. Complete the installation of reinforcing steel, for= work and embeds for the Equipment Hatch pourback.

5 Begin the installation of reinforcing steel, formwork and embeds for the Containment Exterior Concrete to El. 673'.

Facility: Containment Building #2

1. Complete Dome final attachment veld and leakchase.

2. Continue installation of reinforcing steel, for= work, embeds and concrete for the Containment Exterior Concrete to El. 74h' .

l l

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d. .

. 8 Facility: Contain=ent Building 42 (cont'd)

3. Continue installatien of reinforcinc steel, fonrvork, e= bedded metal, conduit and process pipin5 for the Secondary Shield Wells to El. 605'. -

k. Continue installation of reinforcing steel, for= work, enhedded metal and precess piping and cencrete for the Pri=ary Shield Wells to El. 630'.

5 Cc=plete installaticn of reinforcing steel, for= work, edbedled metal and process piping and concrete for the Letdown Cooler Walls to zl. 631' .

Facility: Turbine Euilding 41

1. Continue installatien of reinforcing steel, for=vork, embedded metal, corduit and process piping and ccncrete for the Main and Auxiliary 3ay base cat.

2. Continue installation cf reinforcing steel, for= work, enbedded metal, conduit and process piping for the T/G Pedestal Deck.

3 Continue installation of reinforcing steel, for= work, edbedded metal, conduit and process piping.and concrete for the Exterior Wall to grade.

Ebeility: Turbine Euildin? #2

1. Continue erection of structural steel.

Facility: Ya-d and tiiscellenecus Structures

1. Continue installation of reinforcing steel, for= work, e= bedded metal and concrete for the Circulating and Service Water Building lialls to El. 600'. (Earthwork) .

Facility: Subcentracts

1. Continue erectica of the Units 1 & 2 Condensers.

2. Continue construct 10n of the Pond Makeup Pu=pheuse and River Intake Structures. (Earthwork).

e

• d',' '

9 1 JAllUARY 1977 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, for= work, edbedded metal, cenduit and process piping and concretc for the Centrol Tower area valls and slabs tc EL 659'.

2. Continue installation of reinforcing steel, fer= work, edbedded metal, conduit and process piping and concrete for the Fuel

. Pool area valls to El. 659'.

3 Continue installation of decking, reinforcing steel, for= work, embedded =etal, conduit and process piping and concrete for the Rsdvaste and Equipment area valls north of the Fuel Fool l to El. 659'.

~

4. Continue installation of large piping (engineered safeguards

pump rec =) to approxi=stely 10% cc=plete.

5 Continue installation of equip =ent (reactor building spray

pumps, cc=ponent cooling water pumps, =akeup pu=ps, =akeup

tank, radvaste gas surge tank, decay heat pumps) and small piping in the El. 566' thrcush 614' levels.

6. Cc=plete. installation of electrical equip =ent in the elevation 614' icvel of the Centrol Tower.

Fucility: Containment Building 41

1. Co=plete Do=e Liner final align =ent and productien'velding.

2. Continue Liner Plate second lift align =ent and welding.

3.- Co=plete the installation of the Air Purge and 151n Stea=

Penetrations and continue insta._ation of Pipe Restraint eabeds.

4. Cc=plete the installatien of reinforcing steel, for=ucrk and

, cdbeds for the Containment Exterior Concrete to El. 673'.

5.' Centinue installation of reinfczeing steel, for= work, ed' edo c and concrete for the interior concrete cover slab at El. 593'.

6. Start pre-asse=bly of dc=e spray piping headers.

- - Fheility: Containment Building #2 -

1. Continue installatien of reinforcing steel, for= work, c= beds i

and concrete for the Containment Exterior Concrete to El. 744'.

2. Continue installation 'of reinforcing stocl, for= work, e= bedded

- metal, conduit and process piping for thc . Secondary Shield k' alls to El. 615'. ,.

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,- 10 Facility:

Containment].uildin- 52 (cont'd) 3 Continue installatica of reinforcing steel, for=vork, e= bedded metal and process piping and cenerete for the Prinary Shield Walla to El. 630' . -

Facility: Turbine 3ailding #1

1. Centinue installatien of reinforcins steel, for= work, edbedded metal, conduit and process pipin6 and concrete for the Fain and Auxiliary 3ay base mat.

2. for= work, edbedded Continue installatica

=ctal, conduit of reinforcing and process steel,/G piping for the T Pedestal Deck.

3 Continue installatten of reinforcing steel, for=uork, edbedded cctal, conduit and process piping and concrete for the Exterior Wall to grade.

Facility: Turbine 3uildin- 42

1. Continue erection of structural steel.

Facility: Yard and Mis-aa"=ous Structures

1. Cc=plete installation of reinforcing steel, for=vork, edbedded

=etal and cencrete for the Circulating and Service .iater Building Walls to El. 600' .

2. Begin installation of the site Sever Syste: Lift Station.

(Earthwork).

3 Begin installation of reinforcing steel, for=vork and concrete for the Process Stes: Tunnel and Ad=inistration Building foundatien. (Earthverk).

Facility: Subcentra cts

1. Centinue erection of the Units 1 & 2 Condensers.

2. Continue constructicn of the Pend "akeup Pu=pheuse and River Intake Structures. (Earthwork and devatering).

3 Continue de-conta=inative coatings in Auxiliary Building.

FEBRUARY 1977 .

Facility: Agilia: . Building

1. Continue installation of decking, reinforcing steel, for= work, enbedded cctal, conduit and process piping and concrete for the Control Tower area valls and slabs to El. 639' .

11 Facility: Auxiliary Building (cont'd)

2. Complete installation of reinforcing steel, for::raork, embedded metal, conduit and process piping and concrete for the Puel Pool area walls to El. 659'.

3 Continue installation of decking, reinforcing steel, foz= work, embedded metal, conduit and process piping and concrete for the Radwaste and Equipment area valls north of the /uel Pool to El. 659'.

4 Continue installation of equipment (spent resin storage tank),

large and small piping in El. 568' through 634' levels.

5 Begin installation of cable tray in the El. 6h6' level of the Control Tower.

6. Begin installation of in-line instrumentation.

Facility: Containment Building #1

1. Continue Liner Plate second lift align =ent and welding.

2. Complete pre-assembly of dc=e spray piping headers.

3 Continue the installation of Main Steam Pipe Restraint e= beds.

4. Complete the installation of reinforcing steel, for= work and embeds for the Containment Exterior Concrete to El. 683'.

5 Continue installation of reinforcing steel, for= work, embeds and concrete for the interior concrete cover slab at El. 593'.

Facility: Containment Building #2

1. Complete installation of reinforcing steel, for= work, embeds and concrete for the Containment Exterior Concrete to El. 744'.

2. Complete installation of reinforcing steel, for= work, embedded metal, condrit and process piping for the Secondary Shield Walls to El. 615'.

3 Continue installation of reinforcing steel, for= work, e= bedded metal, conduit and process piping and concrete for the Primary Shield Walls to El. 630'.

Facility: Turbine Building #1

1. Continue installation of reinforcing steel, for= work, e= bedded metal, conduit and process piping and concrete for the Main l and Auxiliary Bay base mat.

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• . 12 Facility: Tu,rbine Building fl (cont'd)

2. for= work, c= bedded Complete installation metal, conduit of reinforcing and process steel,/G piping for the T Pedestal Deck.

3 Continue installation of reinforcing steel, for=vork, e= bedded metal, conduit and process piping and concrete for .te Exterior Wall to grade.

Pacility: Turbine Buildin.~, 52 Co=plete erection of structural steel for Main Fra=e and l.

Auxiliary Bay to ##' '

Facility: Yard and Miscellanecus Structures

1. Continue installation of reinforcing steel, for=uork, e= bedded metal and concrete for the Circulating Water Building to El. 616'.

2. Complete installation of the site Sever System Lift Statien.

(Earthwork).

3 Centinue installetica of reinforcing steel, for=uork and concrete for the Process Steam Tunnel and Administration Buildint; foundation. (Earthwork).

Facility: Subcontracts

1. Continue erection of the Units 1 & 2 Condensers.

2. Continue construction of the Pond bbkeup Pu=phouse and River Intake Structures. (Earthwork).

3 Continue de-contaminative coatings in Auxiliary Building.

MARCH 1977 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, for=uork, embedded metal, conduit and process piping and concrete for the Control Tower area valls to El. 674' .

. 2. i Continue installation of decking, reinforcing steel, for= work, embedded cetal, conduit and process piping and concrete for the Radvaste end Equip =cnt aren valls north of the Fuel Pcol to El. 659'.

3 Continue installatien of equip =ent (spent fuel pool heat exchancer),

large and a=all piping and in-line instru=entation in the eleva-tion 563' throuch 634' levels.

)

13

)

Facility: Auxiliary Building (cont'd)

4. Continue installation of cable tray in the El. 646' level of the Control Tower and begin installation in the El. 568' through 634' level of the Radwaste and Equipment area.

5 Start exposed conduit in El. 634' level and below.

Facility: Containment Building #1

1. start installation of dome spray piping headers.

2. Continue Liner Plate second lift alignment and welding.

3 Continue the installation of Main Steam Pipe Restraint embeds.

4. Begin the installation of reinforcing steel, for= work and .

embeds for the Containment Exterior Concrete to El. 744'.

5. Ccmplete the instanation of reinforcing steel, for= work, embedded metal, conduit and process piping (radwaste drains) for the interior concrete cover slab at El. 593'.

Facility: Containment Building #2

1. Continue installation of reinforcing steel, formwork, embedded metal, conduit and process piping for the Secondary Shield Walls to El. 626'.

2. Continue installation of reinforcing steel, for= work, embedded metal, conduit and process piping and concrete for the Primary Shield Walls to El. 630'.

3 Start instanation of structural and miscellaneous steel to

~

El. 615'.

4 Begin installation of Flued Heads (for all pipes penetrating containment) and Electrical Penetration weld-neck flanges.

Facility: Turbine Building #1

1. Cec:plete installation of reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Main and Auxiliary Bay base mat.

2. Complete installation of reinforcing steel, for= work, embedded metal, conduit and process piping and concrete for the Extmior Wall to grade.

Facility: Turbine Building #2

1. Continue erection of miscellaneous structural steel framing ,

in Main Frame.

.o. 1g Facility: Turbine Building fG (cont'd)

2. Install H. P. Feedwater Heaters, Deaerator Stor36e Tanks and Descrators.

Facility: Yard and Miscellaneous Structures

1. Continue installation of reinforcing steel, for=vork, e= bedded metal and concrete for the Circulating k*ater Building Walls and Glab to El. 616'.

~

2. Continue installation of reinforcing steel, for= work and concrete for the Process Stea= Tunnel and Ad=inistration Building fcundation. (Earthwork).

Facility: Subcontracts

1. Continue erection of the Units 1 & 2 Condensers.

2. Continue construction of the Pond Makeup Pu=phouse and River Intake Structures. (Earthwork).

3 Continue de-conta=inative coatings in Auxiliary Building.

4. Install Reactor Sailding Unit 1 De=e Ductwork for heating, ventilating, and air cooling.

APRIL 1977 Facility: Auxiliary Buildinc,

1. Continue installation of decking, reinforcing steel, for= work, edbedded =etal, ccnduit and process piping and concrete for the Control Tcwer slabs to El. 674'.

2. Begin installation of reinforcinc steel, for= work and e= bedded metal for Solid Radwaste Additica basc=at at El. 634 '.

3 Continue installation of decking, reinforcinc steel, for= work, edbedded =etal, conduit and proccas piping und concrete for the Rodwaste and Equip =ent area walls north of the Fuel Pool to El. 659'.

I

h. Continue installatien of equipment (Auxiliary building air filtering unit, decasifier extraction pu=p), larco and s=all piping and in-line instrumentation in the El. 568' through 634' levels.

5 Continue installation of cable tray in the El. 6h6' level of the Centrol Tcwcr, continue installation of cable troy and exposed conduit in the El. 56S' through 634' icyc1 cf the Radwaste and Equip =cnt area. ,

)

i

• • ' s:

. 15 Fucility: Containment Building El

.l. Complete installation of dc=e spray piping headers.

2. Co=plete Liner Plate second lift align =ent and welding.

3 Complete the installation of Main Stesc Pipe Restraint cabeds.

4. Continue the installation of reinforcing steel, for=vork and embeds for the Contain=ent Exterior Concrete to El. 744'.

In ,

5 Begin the installation of reinforcing steel, for=uork, c= bedded metal, conduit and process piping for the R. V. Pedestal to elevation .602', the secondary shield valls to elevation 605' and the let-down cooler valls to elevation 605'.

6. Begin the installation of reinforcing steel, for=vork and concrete for the Shield Walls against the liner plate.

Facility: Containment Building #2

1. Begin installation of reinforcing steel, for=vork, embeds and concrete for the Ccntainment Exterior Concrete above elevation 744' and dc=e cover slab.

2. Continue installation of reinforcing steel, for=verk, e= bedded metal, conduit and process piping for the Secondary Shield Walls to Elevation 626'.

3 Continue installation of reinforcing steel, for=vork, e= bedded metal, conduit and process piping and concrete for the Pri=ary Shield Walls to elevation 630'.

4. Continue installation of structural and miscellaneous steel to elevation 615'.

5 Continue installation of Flued Heads and Electrical Penetration veld-neck flanges.

Facility: Turbine Building 61

1. Cc=plete installation of reinforcing steel, for=vork and e= bedded metal for the Feedvater Pu=p Pedestals.

Facility: Turbine Building #2

1. Continue crection of miscellaneous Structural Steel framing in the Pain Frc=e.

2. Continue erection of Auxiliary Bay structural steel above elevation 661'.

3. Begin installation of decking, reinforcing steel and e= beds for cicvated slabs.

r.

lh Facility: Yard and "iscellaneous Structures

1. Cc=plete installatien of reinforcing steel, for=uork, edbedded metal and concrete for the Circulating and Service Uater Building Walls to elevation 616'. .

2. Continue installation of reinforcing steel, for=vork and concrete for the Process Steam Tunnel and Administration

• Building foundation. (Earthwork).

3 Besin constructicn of Circulating Water discharce structures and installaticn of yard Circulating Water pipins. (Earthwork).

'4. Begin dewatering Energency Pcnd for Service Water return piping.

Facility: Subcontracts

1. Continue erection of the Units 1 & 2 Condensers.

2. Continue construction of the Pend F2keup Pumphouse and River Intake Structures.

3 Centinue de-contaminative coatings in Auxiliary Building.

MAY 1977 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, for=uork, e= bedded =ccal, conf uit and process piping and cencrete for the Control Cover area valls to elevation 685'.

2. Continue installation of reinforcing steel, for= work, edbedded metal, conduit and process piping and concrete for the Solid Radvaste Additica.

3 Continue installation of decking, reinforcing steel, for=werk, enbedded =ctal, conduit and process piping and cenerete for the Radwaste and Equipment area valls north of the Fuel Pcol to elevatien 659'.

4. Continue installaticn of equipment, large and small pipins and in-line instrc=entation in the elevation 568' through 646' levels.

5 Continue installation of cable troy and exposed conduit in the elevatica 568' level throuch 634' level of the Radvaste end Equip =ent area and through elevation 674' of the Centrol Tower.

?

. 17 Facility: Containment Buildin.q fl

1. Install the Polar Crane.

2. Co:clete the installation of reinforcing' steel, for=vork and emb'eds for the Centain=ent Exterior Concrete to elevation 744'.

3 Continue the installation of reinforcins steel, for=vork, embedded metal, conduit and proccas piping for the R. V.

Pedestal to elevation 602', the secondary shield valls to

- elevation 605' and the let-down cooler walls to elevaticn 605'.

4. Complete the insta11stien of reinforcing steel, for= work and concrete for the Shield Walls against the liner plate.

Fucility: Containment Building 52

l. Continue installation of reinforcing steel, for=vork, e= beds and concrete for the Containment Enterior Concrete above ele-vation 744' and dc=c cover slab.

2. Continue installatien of reinforcing steel, for= work, e: bedded metal, conduit and process piping for the Secondary Shield Walls to elevation 626' .

3 Complete installation of reinforcing steel, for= work, e: bedded metal, conduit and process piping and concrete for the Pri=ary Shield Walls to elevation 630'.

4. Continue installation of structurcl and miscellanccus steel to elevatien 615'.

5 Continue installatica of Flued Heads and Electrical Penetration veld-neck flanges.

Facility: Turbine Building #1

1. Complete installation of concrete for feedwater pu=p pedestals.

Facility: Turbine 3aildin:; @

1. Continue crection of miscellanecus structural steel framing and structural steel in Auxiliary 3ay.

2. Continue installation of decking, reinforcing steel, enbeds, for=vork and concrete for elevated slabs.

3 Begin blockwork for cc=puter reos.

Facility: Yard and Miscellaneous Structures ,

• 1. Continue installatien of reinforcing steel, for=vork, embedded metal and concrete for the Circulating and Service Water Euilding kbils to c1cvation 634' . (Earthscrk).

18 Facility: Yard and Miscellaneous Structures (cont'd)

2. Continue construction of Process Steam Tunnel, Administration Building foundation and Circulating Water discharge structures and piping. (Earthwork).

3 Begin installation of yard service water piping and electrical

-ductbank. (Earthwork).

4. Continuing dewatering Emergency Pond for Service Water return piping. (Earthwork and dewatering).

5 BeginEvaporator/AuxiliaryBoiler/WaterTreatmentBuilding foundations. (Earthwork).

6. Begin plant backfill to elevation 634'. (Earthwork).

Facility: Subcontracts

1. Continue erection of the Units 1 & 2 Condensers.

2. Continue construction of the Pond Makeup Pumphouse and River Intake Structures. (Earthwork).

3 Continue de-contaminative coatings in Auxiliary Buildir4 4 Begin plant area backfill and ccmpletion of cooling pond dike work.

JUNE 1977 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Control Tower area slab to elevation 685'.

2. Continue installation of reinforcing steel, forrsork, embedded metal, conduit and process piping and concrete for the Solid Radvaste Addition.

3. Complete installation of decking, reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Radwaste and Equipment area walls north of the Fuel Fool to El. 659'. Begin to elevation 687'.

4. Continue installation of equipment (Auxiliary feedwater pu=ps, fuel pool cooling pu=ps, heating, ventilating, and air cooling),

large piping to 251, cceplete and en11 piping to 104 co=plete in the elevation 568' through 646' levels.

I' '

. 19 Facility: Auxiliary Building (cent'd)

'5 Continue installation of cable troy and exposed conduit in the El. 56S' level throuch 634' level of the Radvaste and Equipment area and throuGh elevation 674' of the C'entrol Tower.

Facility: Centainment Building 01

1. Set Dome Liner plate and conplete final align =ent and prcduction velding.

2.. Begin the installation of flued heads.

3 Continue the installation of reinforcing steel, for=vork, embedded metal, conduit and process piping for the R. V.

i Pedestal to elevation 602', the secondary shield valls to elevaticn 615' and the let-down ecolor vulls to elevation 630'.

Facility: Contain=ent Sailding -52

1. Continue installation of reinforcing steel, for=vork, e= beds and concrete for the Centainment Er.terior Cenerete above El. 744' and the dc=e cover slab.,

2. Continue . installation of reinforcing steel, for=vork, e= bedded conduit and process piping for the Seccnda:7 Shield Walls metal, to-El. 626 ' . .

t 3 Continue installation of structural and miscellaneous steel to El. 615'.

4. Continue installation of Flued Heads and Electrical Penetration weld-neck flanges.

Facility: Turbine Building fl

1. Move condenser into place. Cc=plete installation of reinforcing steel, for=vork, and concrete for condenser construction opening in exteri'or subgrade vall.

Facility: Turbine 2uilding #2

1. Co=plete erection of Structural Steel and =iscellanecus framing.

2. Continued installation of decking, reinforcing steel, for= work and concrete for elevated slabs.

3. - Complete ec=puter rocs structure.

Facility: Yard and Miscellaneous Structures ,

1. Continue installation of reinfore,ing steel, for=vork, enhedded metal and cencrete for the Circulating and 60rvice Water Euilding Wdlls to clevation 634'. (Ea'thwork).

r

20 Facility: Yard and Miscellaneous Structures (cont'd)

2. Continue Process Steam Tunnel, Administration Building foundations, Circulating Water discharge structures and piping and Evaporator /

Auxiliary Boiler / Water Treat =ent Building foundations. (Earthwork).

3 Continue installation of yvd service water piping and electrical ductbank. (Earthwork).

4. Begin installation of Emergency Fond Service Water return piping.

(Earthwork).

5 Continue plant backfill to elevation 634'. (Earthwork).

Facility: Subcontracts

1. Complete erection of the Units 1 & 2 Condensers.

2. Continue construction of the Pond Makeup Ptunphouse and River Intake Structures. (Earthwork s.nd dewatering).

3 Continue de-contaminative coatings in Auxiliary Building.

4. Begin installation of Control Room seismic HVAC ductwork.

• 5 Continue plant area backfill and co=pletion of cooling pond dike work. (Earthwork).

JULY 1977 Facility: Auxiliary Building

1. Continue installation of decking, reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Control Tower area walls to elevation 704',

2. Continue installation of reinforcing steel, formwork, embedded metal, conduit and process piping and concrete for the Solid Radwaste Addition.

3 Continue installation of decking, reinforcing steel, formwo J.

embedded metal, conduit and process piping and concrete for the Radwaste and Equipment area walls north of the Fuel Pool to El. 687'.

4 Continue installation of equipment (purification demineralizers, safeguards rooms chillers), large and small piping in the El. 568' through 659' levels.

21 Facility: Auxiliary Building (cont'd) 5 Continue instanation of cable tray and exposed conduit in the elevation 568' level through 659' level of the Radwaste and Equipment area and through elevation 685' of the Control Tower.

Facility: Containment Building #1

1. Begin installation of reinforcing steel, for= work, embeds and concrete for the Containment exterior concrete above elevation

• iW' and the dome cover slab.

2. Continue the installation of flued heads.

3 Continue the installation of reinforcing steel, formwork, embedded metal, conduit and process piping for the R. V.

Pedestal to elevation 615', the secondary shield walls to elevation 615' and the let-down cooler vans to elevation 630'.

Facility: Containment Building #2

1. Continue insta n ation of reinforcing steel, formwork, embeds and concrete for the Containment Exterior Concrete above El. 7 W' and the dm e cover slab.

2. Co=plete installation of reinforcing steel, fo m rk, embedded metal, conduit and process piping for the Secondary Shield Wans to El. 626'.

3 Complete structural and miseenaneous steel to El. 615'.

4. Complete installation of flued heads and electrical penetration weld-neck flanges.

Facility: Turbine Building #1

1. Begin erection of structural steel.

Facility:' Turbine Building #2

1. Continue construction of elevated slabs and blockwork partitions.

2. Begin erection of pre-cast panels.

3 Begin instau ation of computer room HVAC package.

4 Begin setting 4.16 kV Switchgear.

Facility: Yard and Miscellaneous Structures

1. Continue installation of reinforcing steel, formwork, embedded I

metal and concrete for the Service Water Building Walls to elevati6n 634'.

<; ..

• 22 Facility: Yard and Miscellaneous Structures (cont'd)

2. Complete Circulating Water Pa=phouse sub-structure to elevation 634'. .

3. Continue Process steam Tunnel, Administration Building founda-tions, Circulating Water discharge structures and piping and Evaporator / Auxiliary Boiler / Water Treatment Buildin6 foundations.

(Earthwork).

4. Continue installation of yard piping and ductbank. (Earthwork).

5 Continue installation of Emergency Fond Service Water return piping. (Earthwork).

6. Continue plant backfill to elevation 634'. (Earthwork).

. Facility: Subcontracts

1. Continue construction of the Pond Makeup Pu=phouse and River Intake Structures. (Earthwork and devatering).

2. Continue de-contaminative coatings in Auxiliary Buildin6 3 Continue installation of Control Roca seismic HVAC ductwork.

~

4. Continue plant crea backfill and co=pletion of cooling pond dihe work. (Earthwork). ,

4

\

AUGUST 1977 Facility: Auxiliary Building

1. Continue installation of deckin6, reinforcing steel, for=vork,

, e= bedded metal, conduit and process piping and concrete for the

Control Tower area valls and slabs to elevation 704'.

2. Continue installation of reinforcing steel, for= work, edbedded metal, conduit and process piping and concrete for the Solid Radvaste Addition.

3 Continue installation of decking, reinforcing steel, for= work, embedded metal, conduit and process piping and conert:te for the Radvaste and Equipment area valls north of the Fuel Pool to elevation 687'.

4. Continue installation of equip =ent, larGe and snall piping in the elevation 568' through 659' levels.

l

, - , - - - - - -.,-w-

23 Facility: Auxiliary Building (cont'd)

5. Continue installation of cable tray and exposed conduit in the elevation 568' level through 659' level of the building north of the Control Tower and through elevation 685' in the Control Tower.

Facility: Containment Building #1

1. Continue installation of reinforcing steel, femwork, embeds and concrete for the Containment exterior concrete above elevations 7 W' and the dome cover slab.

2. Continue the installation of flued heads.

3 Complete the installation of reinforcing steel, for:mrk, embedded metal, conduit and process piping and concrete for the Prbary Pedestal and Secondary Shield Walls to elevation 615' and the let-down cooler walls to elevation 630'.

Facility: Containment Building #2

1. Continue installation of reinforcing steel, fomwork, embeds and concrete for the Containment Exterior Concrete above elevation 7W' and the done cover slab.

2. Continue installation of reinforcing steel, fomvork, e= bedded metal, conduit and process piping for the Secondary Shield Walls to elevation 6 W '.

3 Continue installation of structural and miscellaneous steel to elevation 626'.

h. Begin installation of electrical penetrations and junction boxes.

Facility: Turbine Building #1

1. Continue erection of structural steel.

Facility: Turbine Building #2

1. Continue construction of elevated slabs.

2. Continue erection of pre-cast panels.

3 Complete installation of co=puter room h'VAC package.

4. Continue setting 4.16 kV Switchgear.

Facility: Yard and Miscellaneous Structures

1. Continue installation of reinforcing steel, fomwork, embedded metal and concrete for the Service Water Building to elevation 634'.

. ,, . b.

. o 24 Facility: Yard and 141scellaneous structures (cont'd)

2. Continue Process Stes: Tunnel, Ad=inistration Building founda-tions, Circulating ilater discharca structures and piping and Evaporator /Au:ciliar/ Boiler /tlater Treat =ent Building founda-tions. (Earthwork).

3 Continue installation of yard pipin5 and ductbank. (Earthwork).

4. Cc=plete installatica of E=ergency Pen,1 Service Water return piping. (Earthwork).

5 Continue plant backfill to elevation 634' . (Earthwork).

Facility: Subcontra cts

1. Continue constructicn of the Pond Makeup Pa=pheuse ant River Intake Structures. (Earthwork and devatering).

2. - Continue de-conta=inative coatin6s in the Au:ciliar/ Suilding.

3 Cc=plete installation of Control Roc = seismic h7AC ductwork and seis=ic ceilins supports.

4. Continue plant area backfill and ec=pletion of coolin6 pond dike work. (Earthwork).

I o

e e

e

Exhibit 5 HTDIAND PfAtrr Booked Erpenditures and Fatimated Expenditurea

$1,0ff s Booked Total Total Tc.tal Thru Est'd Est'd Eat'd As of Eat'd Eat'd Eat'd Est*d Est*d Aa of Es t'd Eat'd Eat'd rat'd As Of c.2.r pts Aus. 76 9/76 10/76 11/76 12/1/76 12/76 1/n 2/77 3/77 4/77 5/1/77 5/n 6/n 7/77 8/n 9/i/n

- melear ttsam supply systee $98,195 $240 $260 $488 $99,183 $385 $30 $380 $530 $30 $100,538 $20 $101,41t

$520 $20 $320 Proctes Stian Eveporatore 4,066 1,111 1,162 661 7,000 728 591 667 757 666 10,409 0,0 895 11,4 9 789 699 Turitne cenerator 25,019 18 18 18 25.073 54 55 40 40 40 25,302 a.0 17,49a go go be,9m Bethts! (Dalance of Plant):

Engineirtag aa4 Hume Office %2,290 1,400 1, 1,600 47,190 1,900 2,000 1,500 2,000 2,000 56,590 1,500 2,000 1,500 1,(00 & ~,5'n Essid Imbor 39,030 2,300 2,p00

%00 2,600 46,330 3,(40 3,500  %,000  %,000  %,500 65,930 4,500 4,500 4,0n0 h.500 8 t,430 Hatsr21s 55,250 3,300 4,7c0 4,foo 67,f.50 5,700 5,500 5,000 5,000 8.,000 92,850 5,500 5,000 5,50) 6,000 114,6 9 entracts

- 2{,gy; 1,g 1,g 1,g 3g, g 1,g 1,g 1,8 29 1,g 1,g 35.818 I,g 1,g 1,=g 1,g t, ,

c.mttngene, --- f.6) 669 569 1,707 747 1,369 1,369 e/n h,' 1,169. 1,1(a 3,3(o 1,1(o

• p,yg WDWTA!. - sechtel 80P T6TU5T ' 0,k00 10,000 10,500 1M35$, 13,078 13,500 12,500 13,500 12,500 262, 33 14,000 14,000 14,000 14,500 319,131 Consu,ners Power Conrpany:

Dirsets ,

6,441 260 1,205 523 8,t.29 7fl4 295 295 325 413 10, % 1 413 f.43 590 590 12.5n Cons,smer's Ibwer Company Overheads:

Amc 52,f 22 2,095 2,175 2,263 58,555 2,357 2,612 2,716 2,824 2,930 71,994 3,036 3,233 3,391 3,50a g,5,11,2 Oth2r (Adelnistrative anJ Genstal, Teacs, insurance, ete) 7,h32 126 126 ,_126 ,1 38 126 ,_2%. 291 295 . PA, 9.115 lb 1 294 ~ 4~ 30.i* 1 DUl@TAl, - CICo ov erheeJe 59,4 % 2,221 2,301 2,389__ 66,365 2,h83 2,907 3,011 3,119 3,224 D1,109 3,330 3,507 3,685 3,802 M ,1, U Hite. Other Work orders; sg.are Isrte (70:'2) -- --- --- -- --- --. --- --- -.- --- --- ... ... __ _ _,

IEnJ (70L'll 3,660 25 25 25 3,735 26 20 20 21 21 3,843 21 21 21 21 3,927 Isulloch-huw I.ine (7025) 162 5 5 5 in 3 --- -- --- -- 100 --- .- --- --. ino I.tcrnsing (7el) 3,628 291 291 292 4,502 292 55 55 55 55 5.01b $5 535 55 55 5,7 '4 tlictric u & D (% 72) 171 --- --- ---

I'(1 --- --- --- --.

17: -.- -.. ... ... g SumrAL - Hisc, Work orders ~T,T.F 321 321 322 T,5fri 91--- 75 75 76 76 900 76 576 76 76 Di2

~

i.efstrea try at. 972 (302) (346) (151) 173 (173) --

IvrAr. amitrt $369,623 $12,269 $15,721$14,750 $412,363 417,660 $17.453 416,968 $18,3 7 $i6,%9 1499,740 (18,519 $ 37,k 39 $ig,m s;w,cf $vA,93

Exhibit 6A Mil 4.AND ACRS ITDt! Pace 1 AFFECT ON RESOI1rflON BY CONTINUED CONSTld)CTION (3)

CURid14T

_ ACic3 REpONT Compliance Fore- Compliance Not CENERfC R6EOIJfrIOff NIDI.AND STATtti Full Compliance closed if Construc- Foreclosed if Con-ACK3 ITEM Date Reference Acic3 I.tr II comply I2I Open Already tion continues to struction cont.inues RG Etc Foreclosed MI/77 to 9/1/77

1. On-Site Meteorological 6-16-70 1.23 X Program (Hidland Docket)

2. "

Control of Radioactivity X in Export Steam

3. Prohibit Salt Mining "

X Within one-half Mile

4. Chlorine Accidedit - "

X Design of Control Room Vent System 5 Reactor vessel Cavity "

X Design

6. ECC3 Design "

k-16-76 X Rulemaking Acceptance Cri-teria for ECC3

7. Reactor Trip on liigh "

X Containment Pressure

6. Design of Emergency and "

1.75 I lower Systems - Physical I and Electrical Indepen-dence 9 Fuc1 Design - Damage Due "

X to Flow Starvation. Etc

10. Detection of Gross Fuel "

X Failure I

___ __ m _ _

Exhibt & 6 A (Cont'd) l' age 2 HIDIAND ACHS ITDel AFFECT ON RESOIAFfTON BY COIFFINUED Colt 7rHICTION CURRElff Compliance Fcre- Compliance Not ACRS REPOffP GENERTC RESO!JFff0N MIDIAND STA'IUS Full Comp). lance closed if Construc- Foreclosed if Con-Already tion continues to struction Continuca ACRS ITkN Date Reference ACHS Ltr RG, Etc Comply Open Foreclosed 9/1/77 to 9/1/TT

11. Control of H;. in Contain. 6 8-70 1-16-76 6 1.7, SHP X sent following Accident

12. A'!VJ " "

Mash - 1270 X X

13. Dersonstration of Aneiytica19-23-70 X D3ulpment and Pro edures for Determining levels in Export Steam from Process Steam 1,vaporators (1) Comply means that Midland complies with:

(al Documented ACHS Generic Resolution, or (t i HitC Staff Implementation of the ACHS Resolution (c!) Open means disc asalon concerning implementation of the ACRS Resolution is continuing between Consumera Power and Staff.

(3) This menna that a slantricant plant modification any be required to meet the ACHS Resolution or the NHC Staff implementation of ttWst resolution.

Exhibt i 6B l' age 1 CENERIC ACRS ITD4S ADECT ON RESOIAFFION BY ColtrIMIED CONUl%UCTION QJRRElrF Compliance Fore-ACRS REPOfff Compliance Not GENERIC RESOIJFPION MINMD STAitJS Full Compliance closed if Construc- Foreclosed if Con-ACRL TTEM Date Already tion Continues to struction continues Reference - ACHS !.tr RG, Etc ( } Con g ( Open Foreclosed 9/]/77 to')/1/77

1. Post-!4CA environment: 1-17 69 1MI-2 (4)l.$4, X effect on materials in 1.82 containment, pli, corro-ston and abrialve alurries

2. Evaluation of the Conse- 1-27-70 Palisados 1.5% X quences of water con-taminution by structural coatings Post-I4CA 3 teak tightness of Mata 2-17 67 n. B. 1,48 X Stears and other Con. Robinson Appendir J tainment isolation Valves 4 Experimental vertfication 3-14-67 Browns X

of linear heat geners- Ferry s tion rate used as fuel element danage limit 5 Flooding Protection for 9-10.69 Dresden 1.59,1.102 X emergency cooling Unit 2 pumps

6. Effect of Blowdown Forces 7 11-67 Oconee X on Core and Primary Cystem

7. Abi1ity of Fuel to wIth- 7-11 67 Oconee X stand tranatents in its old age s

Exhibit 68 (Cont'd)

Page 2 GENERIC ACH3 ITDt3 AFFECT ON RESollff!ON BY COffflMIED CON 3TtJICTION QJRRDff ACRS REPolff Compliance Fore- Compliance Not GENERIC RESOfifflON MIDIAND STATtIS Fall Compliance closed if Construc- Foreclosed f.f Con.

ACR3 ITD4 Da te ( Already Lion Continuca to Reference ACRS I.tr RG, Etc Comply Open Foreclosed struction Continueu 9/1/77 to 9/1/T7 8 Tenon oscillationa 7-11-67 Oconee X

9. Inaper clon of Welde in 7-11 67 Oconee 1.19 I Contatsument Liner Plate

10. Teating of Eng Garety 8-17-72 Zion 1.22,1.52, Fea tures I 1 79,1.68, X Sect II (1) Comply means that Midland complies with:

a Documented ACR3 Generic acaolution, or b NHC Staff Implementation of the ACH3 Resolution (2)

Open means discusaton concoming implementation of the ACH3 Resolution la continuing between Consumera Power and Staff .

(3)

This means that a algnificant plant modification may be required to meet the ACit3 Resolution or the NRC Staff implementation of that n.resolutio (h) Deerlatory Galde relates in part to this item.

6

Ext:1 bit 6C

_GENERTC ACR3 ITEft1

, AFFECT ON RES0!IFFION BY C00fflMJED CONSTHUCTION CURRENT Compliance Fore- Compliance Not ACHS REPORT GENERIC hEG0LIMION MIILAND STATtU Full Compliance closed if Construc- Foreclosed if Cbn-II comply Already Lion Continues to struction N ntinues ACHS ITEM Date Re ference ACRS Ltr HG. Etc (2)0 pen Foreclosed '9/1/77 to 9/1/77

1. Net Positive Suction Head 12-18-72 I-1 k-16-76 1.1 X for ECC3 Pumps (Generic Letter)

2. Emergency Pcver " "

I-2 1.6,19, X 1.32 IEEE-308

3. " "

H2 control after LOCA I-3 1.7, ShP X 4 Inst Lines Penetrating "

Ib "

1.11 X 5 Strong Wtor Seismic " "

I-5 1.12 X Inst

6. Fuel Pool Design Basis "

I-6 "

1.13 X

7. Pmtection Against Pump I-7 1.1% X Flyulaeel Missiles

8. Pmttction Against I-8 "

1.17 X Sabotage 9 Vibration Wnitoring of I-9 1.20 X Reactor Internals &

Primary System

10. " "

Inservice Instmetion I-10 Sec XI,1.65 X

11. Quality Assurance I-11 Appendix B, X X Sec III. ANSI-N45.2 1.28, 1 33.

1.64, 1 70.6 ANS-3.2

Eahibit 6C (Cont'd)

Page 2 ggg;RIC ACR3 ITEMI AFFECT ON RESollffION BY COIrf1NUED CONSTRUCTION CURRENT Compliance Fore- Compliance ilot ACHS RE folff GENERIC HESOLiff!O'J MIDI.AND STATtG Full Compliance closed if Construc- Foreclosed if Con-Already tion Continues to. struction Continues ACH3 ITEM Date lie fe rence AC R4 f.tr HG Ete comply Open Fbreclosed 9/1/77 to 9/1/77

13. (Applies only to BWR) 12-16-72 1-12 b-16 ~45 (Generic Letter)

13. Independent Check of Prl * " "

I-13 Sec III X X mary tfystem Stress

14. ( Applies only to BWR) "

I-lb '

15 RV Surviellance "

I-15 =

100 FR 50 x Appendix A & !!, ASIN-E-185

16. RV haterials "

I-16 "

10C FR 50 X Appendix A&G, Sec III, ACRS PV Report 17 Operation with less than I-17 ACRS/ Staff Not applicable All I. oops in Operation Position

18. Prcoperational Testing I-18 "

1.68 X

19. Diesel Fuel Capacity I-19 ACIG/ Staff X Position .

20. " "

Capability of Diological I-20 ACR3/ Staff X X Shield withstanding Position IDCA at safe ends

~

21. " "

Constructing one Plant I-21 ACRS/ Staff X X while other la in Position vill operation Be Prepared

Exhibit 6C (Cont'd)

GENERIC ACRS IWMi AWEC'f ON IESOlifff0N BY CONTINUED CQiSTHUCTION CURRENT Compliance Fore- Compliance Not ACHS REPOttT CENEHIC RESOIJPflOld MIDLAND STATiti full Compliance closed if Construc- Foreclosed if Con-Already tion Continues to struction Continues ACHS ITEM III Comply (2)Open Date Re ference ACHS I,tr RC. Etc Foreclosed 9/1/77 to 9/1/77

23. Seismic Design of Steam 12-18-72 I-22 4-16-16 1.3 X Lines

23. Quality Group Classi. I-23 1.26 X fication Sk. Ultimate liest Sink "

I-2b "

1.27 X X 2$. Inst to Detect Stress I-25 1.18 X in Containment Wall

26. Adequacy of Primary Sys- "

II-l 1.45 X tem leak detection &

Incation 2(. Positive Moderator coef 11-2 ACRS X Position 28 Use of Sensitized SS II-3 1.b4 X

29. Protection Against Pipe II-k 1.46 X Whip

30. Turbine Missiles II-4 (Pending) X X

31. Fixed In-core Detectors II 6 h-16-76 Not Safety Related on I!!gh Power IVR's per ACRS Cenerul Statement

32. Perfonnance of Critical II-7 1.40, 1.63 X X Comionents in Post- 1.73, 1.89, LOCA Environment IEEE Stds

9 Ext.lbst 6C (Cont'd) esce 4 GENERIC ACRS ITDtl AFFECT ON RESollffION BY COWrilAJED CONSTHUCION (3 CuRnErr Compliance Fore- Compliance Not ACRS REPOKr GENERIC RESOI1rftOff MIDTAND STA1US Full compliance closed if construc- Foreclosed if Con-ACHS ITDI Already tion Continues to struction Continuca Date Re ference ACitS Ltr RG, Etc } Comply Open Foreclosed 9/1/77 to 9/1/TI

33. Effective Operetton of Cont Spraya in IDCA 12-18-72 II 8 (Pending) 34 (Appites only to BWR) "

II-9

35. ATWS II-10 4-16-76 Wash-1270 I X (See Exhibit TA, item 12) 36 Rudweste k nagement "

II-11 4 16-76 Appendix I I I

37. Possible Failure of RV Post-IDCA by Theriaal Shock "

II-12 (Pending) 38 Inst to Detect Fuel "

thilures II-13 (Pending) (See Exhibit TA, iten 10)

39. Monitoring for Exceesive Vibrutton or Loose Parta Inside the TW II-14 (Pending) feO. Common Mode Failurea II-15 (Pending) (See Exhibit 7A, item 12) fel . ECCS Cupability "

II-16 4 16-76 Rule making- x Acceptance Centeria for ECCS 8e2. Bahavior of Ibel Under Abnomul Conditions II-17 (Pending)

43. Daergency Power for Two or more Heactore "

II-18 4-16 76 1.81 I

44. ( Applies Only to BWR) "

II-19

4 Exhibit (C (Cont'd)

Page 5 GENERIC ACRS ITEMS AFFECT ON RESO!1FFI(W BY COIrrlNIJED CONSTHEICTION (

QJRRElff Compilance Fore- Compliance Not ACRS REIOfff CENERIC ISSOllFFTON MIDIAND STABJS Full Compliance closed if construc- Ioreclosed if Con-Already tion Continues to struction Continues ACR0 ITEM Ih te Reference ACR3 Ltr RG, Etc {y) Comply ( )Open Foreclosed 9/1/(7 to9/1/77

45. Inst to Follow Course of an Accident 12-18-72 II-20 (Pending) la6 (Applies only to BWR) "

II-21 47 Advlaablity of Seismic Scrum "

II-22 (Pending) e a

(1) Comply means that Midland complies with:

(a Documented ACR3 Ceneric Resolution, or (b NHC Staff Implementation of the ACR0 Resolution (2) Open means discueston concerning implementation of the AORS Resolution is continutns between Consumers Power and Staff.

(3) his means that a significant plant modification may be required tra meet the ACR3 Resolution or the NRC Staff implementation of tha'. resolution.

Exhibit (.D GENERIC ACRS ITDt.1 AFFECT ON RF00!JrflON BY CONTINtJED CONSTRICTION Compliance Fore- Compliance Not ACRS REPORT CENERIC RESOIJrff0N MIDIAND fifAWS Full compliance closed if Construc. Foreclosed if Con-Already tion Continues to struction Continues ACRS ITEM fa te Reference ACRS Ltr RG, Etc (1) Comply (2)Open Foreclosed 9/1/77 to 9/1/77

1. Pressure in Containment Following liCA 2-13-74 IIA-1 (Pending)

2. ( Applies Only to BWR)

• IIA-2 3 Fuel Densification IIA-3 4-16-76 Appendtx x x 4 (Applies only to Westing-house) IIA-4

$. Rapture of litsh Pressure Lines Outside Containment IIA-5 (Pending)

6. I'wr limp Overspeed Im aring TICA IIA-6 (Pending) 7 Rod Sequence Contrcl System "

IIA-7 Not Applicable 8 Isolation of low Pressure System from !Ilgh Pres-sure Systems "

IIA-8 (Pending)

9. Steam Genenstor Tube leakage IIA-9 4-16-76 x X Purtially Re-solved by 1.83 10 ACRS/NRC Periodic 10 Year Review "

IIA-10 (Pending)

(1) Comply means that Midl.and complies withs (a) Documented ACR3 Generic Resolution, or (b) NRC Staff Implementation of the ACR3 Resolution (2) Open means discussion concernind implementation of the ACH3 Resolution is continuing between Consumers Power and Staff.

(3) 1his means that a algnificant plant modification may be required to meet the ACitS Resolutioa or Lhe NRC Staff implementation of that resolution.

4

Exhibit 6E GENERTC ACRS ITEMS AFFECT ON RESO!Jff!ON BY CONTINilED CONSTidjCTION CuRaErr Compliance Fore- Compliance Not ACRS REPolff CENERIC RE3011TfTON MIDIAND STA1US Full Compliance closed if Construc- Foreclosed if Con-Already Lion Continues to struction Continues

( Comply (2)Open ACHS ITD4 Date Reference ACic! Ltr RG, Etc Foreclosed 9/1/77 to9/1/T7

1. Hybrid Reactor Protection System 3-12-75 IIn-1 (Pending)

2. Qualification of Ilew Fuel "

Geometry IIB-2 (Pending)

3. (Applies Ordy to DWR) .IID-3 Is . Seismic Category I Require-ments for Aux Systema IIB Is 3-16-76 1.26,1..?)

6 X 5 (Applies Only to BWit) "

IIB-5 (1) Comply means that Midland complies with:

a).DocumentedACRSGenericHenolution,or b) NHC Staff Implementation of the ACRS Resolution (2) Open means discussion concerning implementation of the ACHS Resolution is continuing between Consumers Ibwer aat Staff.

(3) shis means that a atenificant plant modification may be required to smeet the ACRS Resolution or the NRC Staff implemer.tation of that resolution.

Exhibit 6F CENERIC ACRS frDt3 coRuewr AFFECT ON RESOI11 TION BY CONTINIED CONS 1RIMTION(3}

Compliance Fore- Caspilonce Not ACR3 REPORT MIDIAND STAltl3

_ GENERIC RESO!1FrION Full Compliance closed if Construc- Foreclosed if Con-Al ready tion continues to struction Continues ACRS ITEM Date He fe rence ACRS Ltr HG, Etc Comply .

Open Foreclosed 9/1/T7 to 1/1/T7 1 Locking Out of trc8 Power Operated Valves le 36-76 IIC-1 (Pending)

2. Fire Protection

• IIC-2 (Pending) 3 Dealgn Features to control Ikibotage "

IIC-3 (Pending) le . Decont & Decome of Reactors IIC 16 (Pending) 5 Vessel Support structures "

IIC-5 (Pending) 6 Water llammer "

IIC-6 (Pcnding)

7. 11ulatenance & Inspection of Plants "

IIC-7 (Pending) 8 (Applies Only to BWR)

• IIC-8 (1) Comply means that Midlaski complies withs (a) Documented ACRS Generic Resolution, or (b) NRC Staff Implementation of the ACH3 Resolution (2) Open means discussion concernind implementation of the ACRS Resolution is continuing between Consumers Ibwer and Staff.

(3) ihis means that a significant plant modification may be rerluired to meeL the ACR3 Resolution or the NRC Staff implementation of that resolution.

Exhibit 16 - ,

MIDLAND PLAllT, UNITS 1 AND 2 i Delay Costs Associated With Suspending Construction 5 Months and 9 Mcaths (x $1,000)

Current Suspension 12/1/76 - 5/1/77 Suspension 12/1/76 - 9/1/77 Item Budget Increased Cost - Actual Delay Cost Increased Cost - Actual Delay Cost B & W Nuclear Steam Supply System $ 108,1:00 $ 109,750 $ 1,350 $ 110,650 $ 2,250 B & W Process Steam Evaporators 15,500 16,000 500 16,000 500 G neral Electric Turbine Generator 52,1 00 4 52,MO 1:50 53,150 750 Bechtel (Balance of Plant):

Manual Labor (Field) 238,870 216,270 4 7,100 4 21 8,170 9,300 Nonmanual (Fle]d) 51,900 57,100 5,200 60,000 8,100 Distributables 50,360 53,560 3,200 55,860 5,500 Subcontracts and Materials 282,900 286,900 1,000 4 288,100 5,500 Engineering and llome Office Support 90,600 97,900 7,300 102,100 11,500 Contingency 76,000 81,600 5,600 84,200 8,200 Escalation -

35,300 35,300 16,900 6 46,900 Miscellaneous (Allowances, Fees and Productivity Declines) 151,200 151,200 -

151,200 -

Consumers Power Company -

Directs (Project Management and Direct Engineering and Operator Training 65,995 70,526 1,531 8 75,200 9,205 Administrative and General 22,818 28,541 4 1,723 25,145 2,327 other Overheads (Taxes and Insurance) 141,620 19,360 4 7,7ho 58,350 16,730 AFUDC 102,837 4 h61,143 58,306 522,550 119,713 Miscellaneous Work Orders (Land, Licensing, Spare Parts, Electric Heucarch and Development) 18,600 21,000 2,100 4 22,125 3,525 Total Plant Cost $1,670,000 $1,815,000 $1h5,000 $1,920,000 $250,000 Nuclear Fuel Cost 121 ,600 4 132,009 7,h09 136,965 12,365 Replacement Power and/or Differential Power Cost -

- 210,900 - 381,h00 TOTAL DELAY COSTS $1,79 14,600 $1,917,009 4 $363,309 $2,056,965 $643,765 Base

HIDIAND PIAlff ~

Eattested Abanlonnent Coat Data - $1.000's .

Abandon Plant Abandon Plant AbenJon Plant Abandon Plant Abandon on5/1/77 on5/1/77 on9/1/77 Plant on9/1/TT Construction Continued Construction Suspended Construction Continued Construction Suspended Description on12/1/T6 To 5/1/77 From 12/T6 to 5/77 To 9/1/77 From 12/76 t.o 9/1/TT

1. Plant Empenditures to Date $ 412,000 $ 500,000 $ 478,000 $ 595,000 $ 535,000 A. Salvage Value of Material (%$,000) (52,000) (52,000) (58,000) (58,000)

2. Plant Material and Subcontracts Ccanitted But Wt Paid 136,000 169,000 154,000 134,000 115,000 A. Cancellation Coat of hterial and Subcontracts 56,000 59,000 58,000 41,000 40,000 B. Salvage value of heterial (7,000) (7,000) (7,000) (6,000) (6,00c,)

3. Eclear Fuel Cost Expenditures to Date 6,000 6,086 6,086 6,174 6,174 A. Fuel Cost Comreitted Eut ht Paid 118,600 118,514 125,923 118,426 130,791 B. Cancellation Coat of Fuel 86 88 88 TO To

c. Suivage value of Fuel (16,735) (16,735) (16,735) (16,735) (16,735)

%. Site Restoration Cost 59,000 76,000 59,000 101,000 59,000 5 Dow Dual Purpose Cost Retabursement (52,000) (70,000) (65,000) (84,000) (77,000)

6. Coat of Alternate (1600 MW) Fossil Plant

• A. Im Sulfur Coal 1,061,600 1,063,700 1,120,400 1,063,500 1,158,400 B. High Sulfur Cwl 1,265,500 1,268,500 1,336,200 1,271,700 1,385,000

7. Purchase Power and/or Differential Itwer Coat From Midland Inservice Dutes to Alternate Plant Inservice Intess 661,000 755,000 596,000 829,000 502,000 8 Midland To-Co Capital Coat 1,258,000 1,170,000 1,337,000 1,075,000 1,385,000

9. Midland Operation cost

• A. Fuel 840,000 840,000 889,000 840,000 922,000 B. Operation and W intenance, Eclear Insurunce and Teres 1,323,000 1,323,000 1,420.000 1,323,000 1,488,000

10. Alternate Plant Operation Coat (!m Sulfur)#

A. Wel 6,230,000 6,272,000 6,923,000 6,173,000 7,264,000 B. Operetton and Maintenance, Insurance and Taxes 767,000 766,000 820,000 760,000 8;0,000

11. Alternate Plant Operation Cost (High Sulfur)#

A. Fuel 3,372,000 3,407,000 3,760,000 3,353,000 3,9%,000 B. Operutton and Muintenance, Insurance and Taxes 1,108,000 1,050,000 1,193,000 1,101,000 1,242,000

• Sen single asterisk footnote on Exhibit 20

- h Exhibit 18a 7/M', 7. -

uAa 16 rso ':

ccIA:a ecus:c?

zc::Ixo scAan C? A??zAls l RM2 TO ---- ;

FDDINGS A'O 033ER Pursuant to notice published in the Midland Laily News on August 1 and August 6,1969, a copy of which netice was -m e d to all owners of property adjoining the property in questien, & public hearing was held in the Midland Township e at 7:00 ?M on Ouesday, k.: gust 12, 1969, on the Ju h 18, 1969 petition of Censu=ers ?ower Conpany (hercin-after called the "Cc=pany") to locate a nuclear power plant, ccoling .

pond, and appurtenant equip =ent, structurcs and facill:1es on the foi-lowing described property in Midisnd Tcwnship, Midland County, Michig:.n A parcel of land in Sections 26, 27, 33, 34 and 35 T143, 323, MidMa Cownship, Mid'a-4 County, Michigen, being nore specifically described as fo11cus:

Beginning at the Xofh 1/4 post of said Section 33; thence N. F9 20' 40" E along the Kcrth line of said Section 33' a distance of 2644.c6 feet to the Northeast corner of said Section 33; thence N. 89 30' 00" 2.

along the North line of said Section 34 a distance of 907.C0 feet to the centerline extensics of Eu.uoch C::cek (so called); thence North along said creek centerline a distance of 2195 feet = ore or less to the thread of the l

Tittabavassce River (so called); thence Southeasterly along the thread of ,

said river apprcxi=stely two =11es to the South line of said Section 35 n a point S. 89* 52' co" 2. a distance of 1196.00 feet frem the scuth 1/4 t post of said Section 35; thence N. 89 52' co" w. along the souch lice of j 1

l said section 35 a distance of SS22.42 feet to the Soutacast corner et s.ac Section 34; thence N. 89' 52' 09" W. along the South line of said Section l l

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34 a distance of 87 79 feet; thence ecutinuing along said scetion lino S.

'89 48' 50" W. a distance of 2613.12 feettotheSouth1/4postofsaidSee-tion 34; Mce S. 89 49' ol' W. along the South line of sa'd Section 34 a distance of 84.54 foot; thenco ccati=uing along asid scetics line S. 89 42' 37" W. a distanco of 2574.67 fact to the Southeast corner or said See-tion 33; the.ce S. 89 42' 40" W. alcr4 the Scuth line of said Section 33 a distance of 8130 feet; thence cc:tinuing alcng said section line S. 89 31'lo"W.adictanceof2558.2ofeettotheSouth1/kpostofse.idSection33; thence N. 00 13'23"E.alongtheNorthandSouth1/4lineofsaidSection 33 a distance of 2637 76 feet to the East and West 1/k line of said Section 33; thence continu1=g alo:s r. aid scrth c.=d south 1/4 line N. 00 15' 42" 9 ,

a distance of 2635.c9 feet to the 312:e of beg 4- 'ms.

Cu the hasis of the petitic=, the state =ent,s =ade at de hearing, and other infor. stic: available to the Scard, the 3 card finds as follows:

1. The Cc pany is a corpers-ics organized under the it.vs of the State of Michigan, with its princi;al office a.t 212 W., Michigan Avenue, Jackson, MiA*c$m, .is duly authorized to carry on the business of generating and supplying electric energy as a public utility in the State of Michigan, and is carrf.=g on such business is a substantial area of Michigan's Lc.rer peninsula.

2. The Cc=pa.:y's proposed nuclear power plant, ecoling pond, and appurtenant equi;=est, structures and facilities are public utility build-

.ings, structures and uses.

3 The const: c.etion and operation of the cc=:any's proposed two-unit nuclear power plant, is Xidland Township, together with a cooling pond and appurtenant egai;:ent, stre. tures and facilities, as described is the

V 3

petition cnd at the hearing, is reasonably necessary to neet foreseeable de= ands upon the Cc=pany for elact% c energy in the State of Michigan.

4. Autc=obile access to the proposed plant will be fros the vest via Miller Road, which will be st'rengthened. A railroad spur v' 7 '

serve the site fic: the northwest and vill be constructed across the Tittabavassee River on a new railroad bridge. Sasse Road and River Road vill be discontinued to the extent they fall within the boundaries of the Co=pany's site. Stewart Road will be ter=inated by a turnaround at the vestern boundary of the plant site. Se Cc=pany intends to' provide ade-quate off-street parhing on its site for its e=ployees and visitors to the plant. The Bullock Creek and the Waite & Debolt drains win be re-routed as approved by the County Drain Cc=nissioner. A bridge vm be constructed over the rerouted drains where they cross Miner Road.

5. ne plant.will not produce noise, dust, fc=cs or odors in objectionable quantity, and pla:ned releases of radioactivity frc: the plant will be controlled so as to be within the l' 'ts estchlished by the United States Atc=ic Energy C 'ssion. Che Cc=pany has advised the Board that its studies indicate that the incidence of local fogging v not increase by =cre than three or fcur days a year as a result of the pro-posed plant and pond operatien. The Cc=pany has presented infor=ation including =eterorological studies, indicating that physical ds= ge to ex-isting dwellings from fogging, water or ice due to the Cc=pa=y's project

. Will not occur.  ;

6. The Company's proposed plant, pond, and appurtensnt equip- l mant, structures and facilities vill be attractively desig.ed and lani-scaped.

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7 The Cc=pc=y esti=stes that de ecustructed cost of the plant, pond and appurtens=t ecci, ent, structures and facilities vill be about $350 "' en. Up to apprcxt.stely 700 perscas v be e= ployed at the site duri=g ccustruction. The 2*t's per=asent staff v nunber about seventy-five.

8. All of the petitioner's proposed i= prove =ents, with the exception of the cooling pc d, will be located in Section 27 of Midis =d Township, which is ened " Industrial." The pond and its structures will be located in a.n area zoned " Residential A."

9 The Cc=pany's proposed nuclear power plant, cooling pond, and appurtenant etai,..e=t, structures and ft.cilities, as described in the peti-tion and t.t the hearing, are reaso. ably necessary for the public convenience and service, and vill be designed, erect.ed and landscaped to cc for= ha:=cni-ously with the general architecture and plan of the use districts in which they are proposed to be lect.ted.

10. The Cc=pa=y ow.s, has contrceted to purchase, or has opticus to purchase all of the land ec=prising the property described abo,,3, except for a parcel of land ow.ed by T'1hm J. Mergard and Es e13. Mergard, 3697 E. Gordonville Road, being the South 1/2 of the Southwest 1/4 of Sec-tion 34andtheSouthwest1/4oftheSoutheast1/4ofSectics34,014:i, R2E, Midland Cou=T,y, Michigan. The Cc=pany has no present legal interest in the Mergard parcel and the ov:.ers have not given the Cc=pany pc. .issic:

to use the sa=e for the purpose set forth in the Cc=pany's petition.

h.t:v3E, the 3 card hereby grants permission to the Cc=pany to locate, construct and operate its said proposed nuclear pcrer plant, cool-

"a "aa ing pond, a d appurtenant equ:. ..ent, facilities and st: setures in l

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i districts and on the property hereinabove first described, pursucnt to Section 13.2 of the zoning Ordinsnee of Midland Ocw. ship, xidland County, Michigan, except for the parcel ncv owned by Will'a= J. and Hazel 3. Xersard e

and described in paragraph 10 above, and the Building inspector is hereby authorized and directed to issue a building pe=it therefor upon appli-cation by the Cc=pany. As to the Mergard parcel on?/, the 3oard hereby denies the Cc=pany's petitien, without prejudice to the Cc=pany's right to petition the 3 card for its inclusion in the Cc=pany's project when and if the Cc=pa=y obtains a fee, leasehold, purchase-option, condenner's title (whether or not subject to fi=al court confi = ation), or si=ilar interest in said parcel, or has contracted to purchase the ss=e, or has secured its evners' pe=ission to so petition the Board. This Order is conditioned upon the following:

1. The Cc=pa=y sha]2. turre'.:nd the cooiing pond with a security fence which s' all, at the northwest comer of the pond in the vicinity of Oisland Subdivision, angle northeasterly to follow the line of the pond dihe instead of continuing northward along che Co=pany's property line;

2. The Co=pa=y shall provide and =aintain gccd evergreen trees and a continuous hedge alcng and en -le outside of the security fence on the'vestern side of the pend frc= Gordenville Road north, to ter"nte at existing vegetatien near the edge of Bullock Creek, and shall provide and =aintai= good evergreen trees rrMy spaced on the outside of the securi,y fence alcng the Cc=pany's scush property 1' e : m=ing east to the floed plain of t.he River defined by the 100-year floed. The Cc=pany

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' shall repisce vege ,stics and screening in aress of exis:1:3 vegetatic: =c = the edge of Sullock Creek and in any oder areas of 2 1=. ting should the existing vege atics be removed or die off or the pir ting of new screening ft.11 to prcvide proper screening is ce fat =e;

3. Except on tM river side, the Cc=p;:y shall iccate the dike of the pcud so that cc center of the dike shall be no closcr tha: one hundred sixty (160) feet fr= the property line c.t Q point, and the security fccce s'"' act be placed less tht.: sc:

(10) feet, inside -he Cc=pany's property linc at t.ny point.

k. Cc=pany sv' set erect a:y buildi gs c: cr alcag the dike so:

shown c dravi=gs here ofere subsi, cd to the 3 card, and chs11 not use his property for any other use then is provided for in this Order er as per=itted by c e fc mship Zening Ordin= cc for the use district in vr.ich de projec , is iccated; ?rovidci, however, tha , c= 1:fc::::ics center ccccersing the nucler.:

Power plan =ay be ec st: acted c this property in a locatic:

other thc: -lat sicc c= such drev1=gs, subjec , to the approval by te 3 card of cc si.a stereof.

5 If the Cc=;a:y she-A-- -2e use of ce proper.y as approved by this Order, the: ,ha di2a a:d pc:d rea s r31 te leveled and left vi h a cover of scil in such a =c=ner as to he ha c-nious with ce t% -existest dre.iza ,e c and suit,abic for uses per-mitted by the Ocvt. ship Zccing Crdine ce for the use distric; is which the dike s=d pc d area is iccated.

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The Cc=pany has furnished the Board a set of plans of the entire pond area, showing setbacks, acreeni=gs, asi sAcificatices of all lines ccr. plying vith Conditio=s 1, 2 and 3 above; asi said pls:s, r.arked as "SX-C-235, Rev. A" and "SK-A-52, Rev. D," are Sereby incorporated into and r.ade a part of this Order. The Secretary of the Board shall forthwith deliver a copy of these 7' "-~p and Order to the Office of the 3uilding Inspec or.

ZCNEIG 30ARD OF A??IALS MIDLAND TC'ASE2, ICDIAND CC*w?;TY, XIC*CCAN 1 z. .' s : e { f > s.. >'

Chair s=

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Date: //[ '//[,1970 e

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h $ 'c c Exhibit 18b MIDIAND fCVNSHIP - -'

ZONING BCARD OF APPEALS .

FINDitlGS AITD ORDER

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Pursuant to notice published in the Midland Daily News en May 21,197h, a ecpy of which notice was mailed to all owners of prop-erty adjoining the property in question, a public hearing was held in the Midland Township Hall at.7:OO FM cn Wednesday,, May 29,197h, en the May 6,197h petition of Consumers Pcwer Company (hereinafter called the " Company") to locate a cooling pond and appurtenant equipment, structures and facilities on the following described property in Midland Township, Midland County, Michigan:

The S 1/2 of of Section 34,the SW B2E.

T1hN, 1/h and the SW 1/h of the SE 1/4 f

A previous public hearing was held before the Board en August 12, 1969, upon the application of the Cc=pany to locate a nuclear power plant, ccoling pend, and appurtenant equip =ent, structures and facilities upon described preperty in Sections 26, 27, 33, 3h and 35 of Midland Township. A T.ranscript of said public hearing is in the pos-session of the Board. On March 18, 1970, the Beard issued its findings and an order authorizing the Ccepany to locate, construct and operate said facilitics upon all of the petitioned property except the parcel of land which is the subject of the Ccmpany's May 6, 1974 petition, subject to various conditions set forth in the order.

On the basis of the petitien, the statements made at the hearings, and other infornation available to the Beard, the Board finds as follows:

1. The Company is a corporation organized under the laws of the State of Michigan, with its principal office at 232 W. Michigan

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/ Avenue, Jackson, Michigan, is duly authorized to carry on the business of generating and supplying electric energy as a public utility in the State of Michigan, and is carrying on such business in a substantial area of Michigan's Lower Peninsula.

2. The Companys proposed cooling pond and appurtenant equip-ment, structures and facilities are public utility buildings, structures and uses. *

3. The construction and operation of the Company's proposed cooling pend and appurtenant equipment, structures and facilities, as described in the petition and at the hearings is necessary in order for tire Company to operate the Company's nuclear power plant presently under construction.

4 The Company has advised the Board that its studies ind'cate that the incidence of local fogging vill not increase by more than three or four days a year as a result of the proposed plant and pond operation.

The Company has presented infomation including meteorological studies, indicating that physi..al damage to existing dwellings frem fogging, water or ice due to the Co=pany's project vill not occur.

5 ,

The Company's proposed cooling pond and appurtenant equip-ment, structures and facilities vill be attractively designed and land-

. scaped.

6. The Company's proposed cooling pond and appurtenant equip-ment, structures and facilities, as described in the petition and at the hearings,' are reasonably necessary for the public convenience and service, and vill be designed, erected and landscaped to conform har-moniously with the general architecture and plan of the " Residential A" use dirtrict in v1.ich they are proposed to be located.

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. C. ) O 3 7 The Ceepany has received a warranty deed to the property described herein frcm Willia = G. and Hacel B. Mergard dated Febntar/ 12, 197h.

WlEEF0E, the Board hereby grants pensissica to the Ccepany to locate, construct and operace its said preposed eccling pond and appurtenant equip =ent, facilities and structures in the use districts and on the property hereinabove first described, pursuant to Section 13.2 of the Zoning Ordinance of Midland Township, Midland County, Michigan, subject to the same tems and conditions as the Beard's prior order of March 18, 1970. The Secretary of the Board shall forthwith deliver a copy of these Findings and Order to the Office of the Building Inspector.

ZO1GliG BCARD OF AFFF.ALS .

MIDLAliD TO'4IISIEF, MIDIjJiD COULTY, MICHIGAIT-

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f2 s'. u <* Y D & Chair =an 1)]_ - tt1 $ k he  % f.s -

Secretarf G -</ < t .

/ / / g Mec'cer Date: )/cq 30 , 1974

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Exhibit 19 Analysis I Cocroarison of Midland Abandonment Costs - 81,000's Abandon at 5/1/77 Abandon at 5/1/77 Abandon at Assuming Continuation Assuming Suspensio:

12/1/76 Of Construction of Construction

1. Plant Expenditures to Date $412,000 $500,000 $478,000 A. Salvage Velue of Material (45,000) (52,000) (52,000)

2. Plant Material and Subcontracts Committed But Not Paid --- --- ---

A. Cancellation Cost of Material and Subcontracts 56,000 59,000 58,000 B. Salvage Value of Material (7,000) (7,000) (7,000)

3. Nuclear Fuel Expenditures to Date 6,000 6,000 A. Fuel Costs Committed But Not 6,000 Paid --- --- ---

B. Cancellation Cost of Fuel 86 174 174 C. Salvage Value of Fuel (16,735) (16,735) (16,735) 4 Site Restoration Oost 59,000 76,000 59,000

5. Dov Dual Purpose Reimbursement (52,000) (70,000) (65,000)

'IOTAL $412,351 $495,439 $460,439 Abandonat9/1/77 Abandon at 9/1/77 Assuming Continuation Assuming Suspension Of Construction Of Construction

1. Plant Expenditures to Date $595,000 A. Salvage Value of Material

$535,000 (58,000) (58,000)

2. Plant Material and Subcontracts Committed But Not Paid _-- ___

A. Cancellation Cost of Material and Subcontracts 41,000 40,000 B. Salvage Value of Material (6,000) (6,000)

3. Nuclear Fuel Expenditures to Date 6,000 6,000 A. Fuel Costs Com=itted But Not Paid ---

B. Cancellation Cost of Fuel 2W 2W C. Salvage Value of Fuel (16,735) (16,735)

4. Site Restoration Cost 101,000 59,000

5. Dow Dual P upose Reimburse =ent (84,000) (77,000)

TOTAL

$578,509 $482,509

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Analysis II Exhibit 20-Cost to Complete and operate Midland Vs Cost of Abandoning Hidland and Installing and operating Alternative Capacity (Iow Sulphur Coal)

(Hillions)*

To 02mplete at 12/1/76 To Complete at 5/1/77 To Complete at 9/1/77 Assuming Suspension Assuming Suspension Assuming Continuation of Construction Assuming Cont.nuation of Construction of Construction at 12/1/76 of construction at 12/1/76 HIDIAND PIANT*

Hidland to-go Capital Cost 1,258 1,170 1,337 Taxes 1,075 1,385 768 768 835 Fuel 840 768 883 840 689 Bho operation & Haintenance 502 922 502 530 502 Nuclear Insurance 53 549 J3 55 53 56 Total Generation Cost 3,421 3,333 3,646 3,238 3,795 Abandon at 12/-1/76 Abandon at 5/1/77 Abandon at 9/1/77 Assuming Guspension Assuming Suspension Assuming Continuation of Construction. Assuming Continuation of Construction of Construction at 12/1/76 of Construction at 12/1/76 AI.TEhWATIVEs Capital Cost 1,061.6 1,063 7 0xtrageable Haterial 1,120.k 1,063.6 1,158.4 (61.3) (68.9) (72.3) (75.3)

Dow Lual Purpose Cost (70.8) (92.8) (81.k) ltelmbursement (90.k) (109.0) (108.1)

Cancellation Cost of Haterial 66 7 68.9 70.9 an! Subcontracts Hinus Sal- h5.k 47.7 vege Value (Net of Number 2A-28)as Site Itestoration Q)st 80.3 100.8 82.0 Purchasing Power and/or 661.0 1 31 . 0 82.8 775 0 596.0 829.0 Litterential Power Cost 582.0 Tues & Insurance 495.0 L96.0 Funt 522.0 496.0 540.0 6.230.0 6,272.0 6,923.0 6,173.0 operation & Maintenance 272.0 7,284.0 270.0 298.0 26k.o Nuclear Fuel Cost 14.k (13.5) 310.0 (1%.2) (13.6) (14.7)

(Net or number 3 + 3B -3C)**

Total Generation Cost 8,T20.1 8,851.2 9,k35.h 8,804.1 9,800 7 (Costs are stated in ihture value dollars as of the date of cosssercial operation of Hidland !! nit 2 r.nd column 5 e 6/1/82. , ie, columns 1, 2 and 4 e 3/1/81, Column 3 e 12/1/81 seFrom Exhibit 17. .

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Analysis II Exhibit 21 Cost to Complete and Operate Midland Vs Coat of Abandoning Midland and Installing and Operating Alternative capacity (Ifish Sulphur Coal)

(Millions)

Tocompleteat12/1/76 To Complete at S/1/77 Assuming Continuation Tocompleteat9/1/77 h auming Suspension Assuming Continuation Assuming Suspension of Construction of Construction at of Cocatruction of Conatruction at 12/1/76 12/1/76 MIDIAND PIAlrP Midland to-go Capital Cost 1,258 1,170 Taxea 1,33T 1,075 1,385 768 768 835 Fuel 840 768 833 840 88) 840 Operation & Maintenanca 502 922 502 530 502 Nuclear Insurance 53 53 549 55 53 56 Total Generation Cost 3,421 3,333 3,646 3,238 3,735 Abandonat12/1/r6 Abandon at 5/1/T7 Abandon at 9/1[g s Assuming Continuation Assuming Suspension Assuming Continuation Assur '*2g Suspenaton of Construction of Construction at of Construction of Co,atruction at 12/1/% 12/./77 ALTERNATIVE Capital Cost 1,265.5 1,268.5 1,336.2 1,271.7 Suivageable Material 1 385.0 Dow Dual Purpose cost (613) (68.9 (72.3) (75.3) ($1.4)

Heimbursement (70.8) (92.8)) (90.h) (309.0) (108.1)

Cancellation Coat of Material 66.7 68.9 and Subcontracts Hinus Sal- 70.9 h5.4 47.7 vnge Value (Net of Nweber CA-2D)se Site Restorstion Coat 80.3 100.8 82 131.0 82.8 Purchased Power and/or Differ 2ntial Power Cost 661 755 Tsues & Insurance 596 829 582 590 534 623 Fue1 3,372 593 68.6 3,407 3,760 3,353 Operation & Maintenance $18 3,956 51 6 570 Zuclear Fuel Cost 508 596 (Net of number 3 + 3B - 3C)e* (14.4) (13.5) (14.2) (13.6) (14.7)

Total Genedation Cost 6,407 6,475 6,861.2 6,533.2 7,091.3 (Costs are stated in future value dollara as of the date of comnercial operation of Midland Unit 2, i.e., columna 1, 2 and 4 e 3/1/81, column 3 e 12/1/01 c.nd column 586/1/82.

seFrom Exhibit 17.

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s Exhibik22 Analysis III Abandonment Patio of Generation Cost of Midland with Gen-eration cost of an alternative Generating Facility (Low Sulphur Coal) 12/1/76 5/1/77 9/1/77 Assuming Continuatican Assuming Ccntinuation Alternative 8,720.1 8,851.2 8.80h.1 Midland 3,421 3,333 3,238 Ratio = 2.55 Ratio = 2.66 Ratio = 2.72 Assuming Suspension Assu=ing Suspension 9,h35.h 9,800.7 3,646 3,795 Ratio = 2 55 Ratio - 2.59 Ratio - 2.58 e

Exhibit 23 Analysis III Abandonment Ratio of Generation Cost of Midland With Generation Cost of an Alternative Generating Facility (High Sulphur Coal) 12/1/76 5/1/77 9/1/77 Assuming Continuation Assuming Continuation Alternative 4,407 6,L75 6,533.2 Midland '3,421 3,333 3,238 Ratio = 1.87 Ratio = 1 94 Rat,10 = 2.02 Assuming Suspension Assuming ?qq+ G*:n

- 6,861.2 7,c91.3 3,646 3,795 Ratio - 1.87 Ratio - 1.88 Ratio - 1.87

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