ML19338C046

Intervenors',Other than Dow Chemical Co,Interrogatories to Util Re Const of Facility & Sale & Purchase of Steam & Electricity from Facility

ML19338C046
Person / Time
Site:	Midland
Issue date:	12/27/1976
From:	Cherry M CHERRY, M.M./CHERRY, FLYNN & KANTER
To:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.), Atomic Safety and Licensing Board Panel
References
NUDOCS 8007310633
Download: ML19338C046 (17)

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4h a' UNITED STATES OF AMERICA

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NUCLEAR REGULATORY' COMMISSION g N-1,>.>^/

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CONSUMERS POWER-COMPANY ) DOCKET NOS. 0-32

) - 30 (Midland Plant, Units 1 and 2) ) ,

/ 2. 2 7 ' Id INTERROGATORIES OF ALL INTERVENORS EXCEPT DOW CHEMICAL COMPANY

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TO CONSUbERS POWER C0pANY Pursuant to 10 C.F.R. 92.740b,. the.following inter-rogatories are requested to be answered separately and fully in writing, under oath or affirmation, by an officer of Consumers Power Company having personal knowledge of the answers. These answers shall be served no later than 14 days after service of these interrogatories.

l These interrogatories are intended by Intervenors j to be continuing in nature. Consumers Power Company (Consumers) l is required to update its answers from time to time in the event it obtains knowledge which renders a prior answer to these interrogatories incomplete or inaccurate.

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pEFINITIONS

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1. The term " Consumers" shall include Consumers

Power Company, its officers, agents, employees, and represen- I tatives, and shall also include any other companies, associa-tions or. partnerships in which Consumers Power Company owns or controls at least a 107. beneficial interest.

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.2. _The word." person" shall mean any1 natural perso~n,  ;

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' trust, partnership, or corporation. '

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3.. . The words'"you" Land "yours" shall mean and refer

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4 to Consumers and shall include its-predecessors'(i.e., companies

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it has' acquired in any. manner or with which it has merged),

its-subsidiaries (and their predecessors and successors), its i

. divisions-(and their predecessors and successors), its affiliates (and their predecessors and-successors), and any and all of their

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. respective present and former officers,. directors,' agents, employees and any and all'other persons acting on their behalf. ,

4. " Communications" shall mean and include all docu-

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h .ments.as hereinafter defined and all written, oral, telephonic r .or.other inquiries, discussions,-conversations, negotiations,

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agreements, understandings, meetings, . letters,-notes, telegrams,

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advertisements and~ interviews.

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5 .' " Documents" shall mean and include al1~ written,

, graphic,'or recorded materials of any nature whatsoever-(includ-ing drafts or final copies and whether formal or informal),

including but.not limited to, lettebs, correspondence', memoranda,

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notes,ctelegrams, diaries, desk calendars, circulars, charts,

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. papers, tape or-other sound recordings ~ ledgers, sehedules,

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-work' sheets, contracts, . films,_ transcripts, agreements, licenses,

, memoranda'of. telephone or personal conversations, microfilm,

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< books y news ' releases ,; newspapers , : magazines , adv,ertis ements , .

periodicals , -bulletins, ;-pamphlets , ' statements ,. notices , reports ,-

records'Earticl~estbf-incorporation,~articlesof~ association,

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by-laws,. rules, regulations ~~ directives, teletype messages,

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minutes of maetings, interoffice comunications, . accounting .

work sheets, financial statements, stock transfer books, -jour-nals, books ~of account, bills, vouchers, bank checks, hotel charges, proposals, prospectuses, offers, orders, receipts,-

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working papers,' appointment books, ' time sheets, logs,--photo-graphs, f obj ects, drawings, studies, forecasts, proj ects ,

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stenographers notebooks, punch cards, and computer. printout-sheets. -

6. The term " relate to" shall mean consist of, refer l

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to, reflect-or be in any way logically or factually. connected l

l with the matter' discussed.

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II IDENTIFICATIONS

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1 ~... " Identify"-

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,(a)i when used with respect to a' natural person, re-

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c - quires a statement of such person's name, present _ address,

'emplo'yer, his division,' department, district and regional ~,

'territoria'l or other_ organization unit, the capacity in which he is employed,;and.his business =and home telephone numbers.

4-(b) when used with respect to a committee of the 3, board of' directors, division, department, district, office, bureau, regional,. territorial or a description of its functions, l a description of the geographic area of-the United States or

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! :any state or subdivision _thereof'with respect to which its

~ functions are performed, from the period January 1, 1968 to

, the-date of your answers to these interrogatories during which

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it'has existed, theiname and title of each' person in charge of' the operation of suchTentity and the name and title of all

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[ persons reporting to such person in charge and of the name and l' ~

' title of all persons t:o whom he reported.

(c)L when used with respect'to a partnership, state the

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11ocat',onfof each place

of the partnership's businesses, state

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each~ general landclimited partner,gthe-present. address.~of each

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. partner,SandLthe businessfand home celephone number.

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(d)1 lwhen:used with raspect to a corporation, stateithe

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place?andidate'offincorporation, the-location'of.the corpora -

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Ltion's-principal office,

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1 eachiline or type ofibusiness1 engaged

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l .in'by.such corporation, ano,, if the shares of such corporation r are publicly.. traded, identify.each person beneficially or legally

. owning. 57. or.more of each class of such shares.

(e) when used-with~ respect to a document, shall-mean .

identify <the person or persone-by whom the document was written, i the-p'erson by whom the document was typed or otherwise created, e the person or persons to.whom the document or'any copy thereof l'

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.was sentLand the person or persons now having custody of the L original of such document, or, if.such original does'not exist,

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of'eachfexisting copy of such document; state the'date upon .

which such document was first written, and describe.the contents and substance of.such document.

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(f)':when used with respec't to a communication, identify theJperson by~whom made and the person or persons by whom ~

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received; state the time.and plac'e at which it was made and, if made by telephone,.the telephone number at which it was received '

and the exact location of such telephones; describe the contents.

and substance of such communication; identify all documents p which set forth or contain, or relate to, the. contents or sub-L

. stance, or any portion-thereof, ofEsuch communication.

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. TIME- PERIOD.'

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.'Except where otherwise stated, each interrogatory re-

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quests

informationLfor! the' period beginning: December 1, 1967 to

- the date.oftyour answers

toithes~e interrogatories. ~

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COMPLETENESS REQUIREMENT i

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In addition to-answering each interrogatory as set

.forth below, . please~also identify-(in connection with each

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interrogatory answer),..each fact,' document:or communication '

1which you?have' relied'upon or which.you:believe supports your

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answer to each interrogatory. Also, in connection with your answer to each interrogatory, identify each person who has any a i

knowledge of any. fact which relates to or which you have relied 1 l upon in connection with each said answer. Whenever an inter-

. rogatory is framed.in the conjunctive, it sh all also be: taken  !

in the disjunctive and vice versa.

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INTERROGATORIES

'l. Testimony in this proceeding thus far has indicated

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a dispute between Consumers and Dow Chemical Company (Dow) re-

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latin ~g to the' construction of the Midland. Nuclear Facility and

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sale and purchase cf steam and electricity from said facility.

-AllLor a portion of the Dow-Consumers contracts have been

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identified'or' attached.in written testimony of your witnesses- 1

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in this proceeding, Messrs.'Keeley and Howell. - With respect to a

, anyLdispute concerning such cantracts between Consumer.s and Dow

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please state theLfollowing:

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(a)~ Describe in' detail the nature. of the dispute and c '

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the : status: of any: negotiations to: resolve said dispute.

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- If it!is'your-positionfthatino dispute exists, please state-

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-the basis therefor 11n light of.the cross-examination testi-mony of-Dow witness-Temple, including.but not. limited to the disclosures made by:Mr. Temple of meetings between Consumers and1Dow and-their representatives in September 1976 whereinLauggestions of lawsuits were made, as well as correspondence between Youngdall and Temple during 1975

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and 1976 which has already been produced by Consumers. i (b) i Describe in detail your factual and legal position .)

concerning said dispute including wh' ether you believe Dow has_an' obligation to purchase steam or' electricity at any time regardless of the date when the Midland Nuclear

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Facility.first becomes operational.

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(c)- Set forth the legal theory or. theories in connec-

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tion'with said dispute upon which Consumers would base any' lawsuit' against Dow in the event Dow announced a posi-tion that it would no longer consider itself obligated-by any contracts for.the purchase or sale of electricity ,

from the Midland Nuclear Facility.

'(d) To the best of your ability and whether based

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1 upon personal knowledge' or not state'*rhat' you believe to ' l

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'be the; position of Dow in' connected with the dispute.

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Used within.these interrogatories the-wor'd'" dispute" shall have the~ broadest possible. meaning 1and shall include differing posi-tionsa disagreements; different viewpoints, different objec-

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Ltives and different perspectives concerning'all or any part of.

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the subject 3 matter.

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2. ' State'the date of commercial operation for the -

Midland Nuclear Facility which you- currently proj ect. If a I

'different date is. applicable to each unit then so state. 1 Explain._in- detail the basis .for your proj ection and set forth

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L i in detail-whether you have taken-into. account in your . proj ec-

• l tion a contested hearing at the operating stage level, economic r

L conditions which could restrict your-ability to raise funds for construction completion and regulatory changes requiring modi-i fications in the design of the Midland Nuclear Facility. Where .

applicable give dates for each of the events or factors upon which you base your overall proj ection.

3. State in detail how you intend to finance comple- .

I tion.of construction for the Midland Nuclear Facility. Your

-answer is not complete by only making reference to general fund raising but also requires cash-flow proj ections and sources and -

application of funds analysis throughcut the period of your currently projected date for commercial operation ,of the Midland

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Nuclear Facility.

~4. - With-respectto your existing contract with Dow concerning the purchase and sale of steam and electricity, state-the -date by. which you are . obligated to 5tave - the Midland Nuclear

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. Facility:in' commercial operation-capable'of making available to

! -Dowlthose'amountsLof steam and electricity contemplated'by your

, ~ existing" contract with Dow. If it is your' position that your existing. contract calls for no-particular date, please exp1'ain

-yourianswerLin detail including;your legal theories on interpre-

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ation of theLeontract' making specific reference to applicable contractual. provisions.

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Do you'have a. contingency plan setting.forth,.

• whether formal or informal-and whether oral or written, any

alternatives to.the Midland Nuclear Facility in the event I that.

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, -(a) - the construction . permit is suspended; l (b) the ' construction permit is permanently lifted and vacated;

(c) Dow determines not to purchase steam or electricity from the Midland Nuclear Facility; and/or -

(d) it is _ impossible or improbable for you to have a i

! Midland Nuclear Facility in commercial operation by your

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currently proj ected commercial operation date.

l If it is your. position that you.do not have a contingency plan

-in the' event of one or more of the above occurrences please state l why not.

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6. Have any of your representatives (including legal representatives) rendered any advice (whether formal or informal and. whether written' or oral) concerning a lawsuit against Dow in .

the event it determines'not to purchase steam or electricity from

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-the Midland Nuclear Facility. . Explain your answer in'd'etail-and .

if:such,advicefhas'been rendered set'forth the advice with parti-

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'cularity. including applicable;1egal theories.

7< Have you begun"or.do you'at sone-point-presently Leontemplate :beginning: negotiations 1with:any person, other than

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i Dow,1regarding the sale or purchase of an ownership _-interest- '

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in any fom, ' of' all or part of the' Midland. Nuclear. Facility.

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.If y~ur o answer:is "yes," state.whether such-investment would -

n; L be . permitted under your current agreements with Dow (giving

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l  : reasons therefor)-and how such potential' investment is related, b .

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Tif'at all, to your ability, from the financial standpoint, to

. complete cdnstruction of the Midland' Nuclear Facility.

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8 '. 'In the original proceedings-concerning the con-L struction license the total cost of the Midland Nuclear Facility l

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was approxir.2tely $600 million. Both Consumers and the Regula- >

tory Sta_#r-took'the position that the chief benefit (under a f

, cost-benefit analysis pursuant to.the National Environmental r ,

l . Policy Act) wasethe' production.of electricity to various users

as well as the saleJof steam and electricity to Dow. The' o

, proj ected cost for the nuclear ' facility is. now at least $1.67 L

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billion and mayybe higher. Pleas ~e state in light of'the addi-

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tional cost, each benefit which exists.today, if any exists,ynot applicable'and/or analyzed in connection with-the earlier cost-

. benefit' analysis in'this' proceeding and.co:the extent any such ,

? additional. benefits exist, please quantify them and give your l

judgment in' detail, asHto whether such'edditional

benefits justify

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'the increased'capitalfcost. '

-9.- DowLis currently-under a consent order with the

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_ Michigan ~ Air Pollution Control Authorities which prevents -Dow from.  ;

ioperating'its existing 1generatingifacilities past 1980. In addi-

. tion the United States l Environmental Protection Agencyg has-

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recently-taken the. position that it may not permit Dow to wait ~

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,as long asl1980 to remedy. air pollutionproblems in and arc,und  ;

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Michigan. In the event that the State and. Federal Air Pollution

regulatory authorities do not permic Dow to operate its present

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. generating facilities after 1980 would you agree that it is no ,

longer necessary'from a cost-benefit standpoint, to bu'ild the- ~

' Midland Nuclear Facility ai currently. designed and at its current location. Whether you agree or disag'ree, please explaingyour

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10. Is it.possible for you to construct at the site

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j. of ,the proposed Midland Nuclear Facility a fossil fuel generating facility. If not, state why not. If your answer is "yes," then 9

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a descriptien of the type of fossil fuel generating

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.(a) facility which can be constructed, 4

(b)- 'a statement of the total capital ecat'of such '

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'(c) an estimate of the time which it would take J' .. .

j to construct or make commercially o'perable such a fossil fuel

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I generating facility,_and ,

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~(d) whether, if you' began'to use good faith efforts now, you could construct such a fossil fuel generating facil-

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icy which~would-be commercially operable on or before the end fof 1980.-

,As used;within-these interrogatories, the term " fossil fuel facil-

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i ty'.' ' -means;a. facility which could take the place-of the Midland

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l Nuclear Facility to' generate electricity and/or steam in accor-dance with you'r perception of your current needs. ,

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. Include within.your answer-to this interrogatory ,

whether.you agree that_the. total cost of such a fossil fuel

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- generating facility, plus assuming a complete loss of your .

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current invescment in the Midland. Nuclear Facility, would be.

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less than $1.67 billion. - If you disagree please explain your .

answer in detail and whether you. agree or not set forth the figures upon which you have relied in your answer..

11. Set forth your understanding and , definition  ;

of the term " energy conservation." After you have set forth your understanding and definition of the term " energy conservation,"

provide the following information: .

-(a') What steps .cn actions you have planned or are ,

contemplating planning'to initiate voluntary energy conser-vation throughout the period 1976-1986.

(b) Janat steps or actions you have planned or are I' contemplating. planning to initiate mandatory. energy conser-

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vation throughout the period 1975-1986.

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(c). Set forth what steps you are planning or contem--

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, .. plating. planning concerning.the adoption of" inverted, rate structures which would contemplate consumers of electricity _

g .who use more' electricity to pay more therefor.rather-than less. >(

l (d) . L With respect .to each of the alternatives- described

.in (a), '(b), & ;(c) 'above and in consideration of. your plans

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tor (contemplated plans if any,oset-forth.what.you believe 121-

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- Jwould~ be~ the: savings?in . energy sales f(in Omns 'of megawatts

el'ctrical)4that'.would' e result lover the period of'1976-1986.

L12. With respect to the~most'recent communication, of

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~ which'you are~ aware;' issued by:the Advisory, Committee on Reactor Safeguards (and' identifying.such communication).regarding a list-

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fing-of unsolved s'afety.:or other problems. generic to the nuclear itidustry, state:

(a)' whether each unresolved problem or-item is deemed by you or the.ACRS to be' applicable.to the Midl'and Nuclear Fach.lity,answeringspecificallyforeachproblemoritem; ^

[ (b) the manner and metho'd of resolution of each such t

[ item identified in (a) above,

[ (c) the cost of' resolution of each such item identi-c '

fied in (a)'above, and

[ (d) the completion date by which each such item iden-tified nin. (a) . above will- be resolved including whether such p _ ...

item will be resolved -by the currently projected completion j -date for;theLMidland Nuclear Facility.

13. Please set-forth each cost and benefit which you g currently believe .to be -applicable in connection with the Midland l Nuclear Facility. The - term cost-benefit analysis" in this inter-

'rogatorylshall mean thateprocess, as'you understand it, required.

,. . -toLbeEdone'.pursuantito-the? National Environmental-Policy Act.

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y din? connection with your' answer quantifyLseparately each cost and

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reach-benefit andEstate whether you are including within your-

$ lanswerMthe'costjof fuel reprocessing,'. fuel storage, fuel availa-

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bility,and-decommission'of the Midland Huciear Facility. If you I

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do'not include any.of said items in1the cost-benefit analysis, l 1

Also include within your answer the p9r-

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.please state why not.

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centage of the design' electrical rating of the Midland' Nuclear Facility > l (e.g., 907,of megawatt: electric rating)_which you believe'should l i

be used in connection with the cost-benefit analysis, explaining your reasons therefor.  !

14 . - Do.you' agree that there exists in relationship with Dow any change of- circumstances" from those which existed in 19737- If you do not agree, please explai,n your answer"in detail. If you do agree, list each changed circumstance in

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sufficient detail sofas to be understood with.out reference to any document'other than your answer.

15. If your existing steam-electric contract ~with Dow were terminated, . would you still move -forward ~ to construct the

. Midland . Nuclear Facility as currently designed? If "yes,"

please explain your answer in -detail. If not, please set forth each change.in theidesign or-location of the Midland. Nuclear

. Facility (including whether a non-nu~ clear facility would be such .a change) which you would . contemplate, stating, to the extent applicable,. capital costs, schedules and completion dates asso-ciated with each such change. 'As used-within this interrogatory Lthe word " terminated" means'"at an end".without regard'to reasons 1 therefor, disputes, lawsuits-or any other legal actions and f requires you to make the assumption in connection with this

. answer,z that'you'are-no-longer required to. supply from the Midland

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' Nuclear Facility or-any.other facility lany steam or electricity

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to.Dow-referred to r contemplated in - t-he steam-electric . contract, as amended, between you and Dow.

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Attorney for.all Intervenors except Dow Chemical Company

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Myron M Cherry -

Suite 4501'

' One IBM ~-Plaza-Chica 60611-l (312)go , ; Illinois

-565-1177

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PROOF OF SERVICE BY. MAIL

'I, Elizabeth Shannon,.being,first duly sworn on oath ~

~ state that I caused' copies.of the.above and foregoing Interroga-tories ~to be served on the persons below at the addressed listed below by first class mail, postage prepaid, by depositing.the same in the U. S. Mail chute at One IBM Plaza, Chicago, Illinois 60611 this 27th day'of December, 1976. .

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n Subscribed and sworn to before me -

,4 e.,e h o cp 7 , 1976

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' Notary Public Frederic J. Coufal,.Esq., Chairman Lawrence Brenner, Esq.

Atomic Safety and Licensing Board U. S. Nuclear Regulatory Panel Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington,-D. C. 20555

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Lee F. Nute, Esq.

Dr. J. Venn Leeds General Counsel's Office

- ' Atomic Safety and Licensing Board Dow Chemical Company Panel. Midland, Michigan 48640 10807 Atwell- .,

' Houston, Texas _ 77096 Dr. Emmeth-A. Luebke # 4D Atomic Safety'and' Licensing Board ,, , g Panel S. Nuclear Regulatory Commission gjs

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gg1, ::Lp Washington, D. C. 20555 9-

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Mr.~C. R. Stephens, Chief

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Docketing & Service Section 1 l

Office of the Secretary.of the  %

Commission w \,p

.U. S. Nuclear Regulatory Commission .

Washington,'D. C. 20555=

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. .e-Elizabeth Shannon, being first duly sworn on. oath states 'that she caused copies of the above a ' foregoing Interrogatories to be served upon David J. Rosso, Esq. and R. Rex Renfrow, III, Esq., Isham, Lincoln & Beale, Suite 4200, One First National" Plaza, Chicago,' Illinois 60670, by messenger, this 27th day of December, 1976.

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l Subscribed and sworn to before me , &

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w/e</g7 7 , 1976 D c1 7

1. Notary W27sC6> J&' 0 3y$ f kIl Public g c.pf ,,, 4,'

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