Case No. RF340-00060

March 3, 1998

DECISION AND ORDER

OF THE DEPARTMENT OF ENERGY

Application for Refund

Name of Petitioner: Enron Corporation/

Ferrellgas, Inc.

Date of Filing: January 30, 1992

Case Number: RF340-60

On September 14, 1988, the Economic Regulatory Administration of the Department of Energy (DOE) filed a Petition with the Office of Hearings and Appeals (OHA) requesting that the OHA formulate and implement procedures for distributing funds obtained through a consent order with Enron Corp. (Enron). See 10 C.F.R. Part 205, Subpart V. The consent order resolved DOE allegations that Enron and all of its subsidiaries, affiliates, prior subsidiaries, predecessors and successors in interest violated the mandatory petroleum regulations in their sales of crude oil and refined petroleum products from January 1, 1973 through January 27, 1981 (the consent order period). On July 10, 1991, the OHA issued a Decision and Order setting forth final procedures for disbursing the portion of the Enron settlement fund attributable to various Enron entities' sales of NGLs and NGLPs. Enron Corp., 21 DOE ¶ 85,323 (1991) (Enron). These covered Enron entities are UPG, Inc. (UPG), Northern Propane Gas Company (Northern), and Florida Hydrocarbons Company. In accordance with the goals of 10 C.F.R. Part 205, Subpart V, Enron implements a process for refunding the consent order funds to purchasers of Enron NGLs and NGLPs who are able to demonstrate that they were injured as a result of the covered entities' alleged overcharges. This Decision and Order renders a determination upon the merits of an Application for Refund submitted by Ferrellgas, Inc. (Ferrellgas). Ferrellgas purchased Enron propane and butane for resale to its customers. Accordingly, Ferrellgas was a reseller of Enron products.

I. Background.

In Enron we adopted a presumption that the alleged overcharges attributable to NGLs and NGLPs had been dispersed equally in all sales of refined product made by the covered entities during the

consent order period. Enron, 21 DOE at 88,959. We stated that, in the absence of a demonstration of a disproportionate overcharge, a claimant would be allocated a share of the consent order funds on a volumetric basis. We provided that eligible claimants would receive $.00601 per gallon of covered Enron product purchased.(1)Id. We refer to the dollar amount derived by multiplying an applicant's purchase volume by the per gallon refund amount as the applicant's allocable share.

Enron generally requires a claimant to demonstrate that it was injured by Enron's alleged overcharges in order to receive a refund equal to its full allocable share. However, in Enron, we adopted several presumptions of injury that would allow certain types of claimants to receive a refund without a detailed demonstration of injury. We established that resellers, retailers and refiners seeking volumetric refunds of $10,000 or less were injured by Enron's pricing practices. Id. at 88,960. Such applicants would, therefore, only have to document their purchases of covered Enron products in order to receive a refund of their full volumetric share. Id. at 88,960.

We further established that a reseller, retailer or refiner whose volumetric share of the Enron consent order funds exceeds $10,000 may elect to receive as its refund the larger of $10,000 or 60 percent of its volumetric share up to $50,000. Id. Accordingly, a claimant in that group need only establish the volume of Enron covered products that it purchased during the refund period to receive a refund of 60 percent of its allocable share up to $50,000.

Ferrellgas has chosen not to rely upon these presumptions of injury. Instead, the firm has submitted information aimed at showing that it was injured with respect to the product that it purchased from Enron and resold to third parties or used in its refining operations. Accordingly, we will consider granting Ferrellgas a refund for its volumes of Enron purchases based on our analysis of this information concerning injury.

II. The Bases for Showing Injury in this Proceeding.

A refiner whose allocable share exceeds $10,000 must demonstrate that it was injured by Enron's alleged overcharges in order to receive a refund equal to its full volumetric allocation of the consent order fund. The procedures in Enron outline a two-step requirement for applicants attempting to make an injury showing. First, a claimant must show that it accumulated banks of unrecovered increased product costs large enough to justify the amount of the refund claimed during the period from either November 1973, the first month of the banking period, or the first month in which it purchased from Enron, whichever was later, through the end of the banking period. Second, it must show that market conditions forced it to absorb the alleged overcharges. Id. at 88,960.

In order to determine the degree to which market conditions forced an applicant to absorb the alleged overcharges, we generally apply a three part competitive disadvantage analysis that has been upheld by the courts. See. Behm Family Corp. v. DOE, 903 F.2d 830 (Temp. Emer. Ct. App. 1990); Atlantic Richfield Co. v. DOE, 618 F. Supp. 1199 (D. Del. 1985). Under this methodology, we infer that purchases made at above average market prices indicate that the firm was unable to pass through the alleged overcharges. Conversely, we infer that purchases made at prices below the market average placed a firm at a competitive advantage and did not injure the firm. The analysis produces three measures which the OHA uses as guidelines in determining the claimant's level of injury. The first measure, "gross excess cost," is the sum of the amounts by which an applicant's monthly purchase costs exceeded the market average. The second measure, "net excess cost," equals an applicant's gross excess cost minus the sum of the amounts by which its purchase costs were below the market average in other months. This measure provides an indication of the cumulative impact of the alleged overcharges, balancing the adverse effect of the comparatively expensive purchases against the positive effect of comparatively inexpensive purchases. The third measure, the "above-market volumetric share," is the number of gallons purchased at prices which exceed market prices multiplied by the volumetric factor. This measure is indifferent to the magnitude of the excess costs incurred, accounting only for the number of gallons of uncompetitively priced product purchased by the applicant. We consider all of these indicators of competitive disadvantage in determining whether, and to what extent, an applicant was injured by its purchases, and thereby to calculate an appropriate refund amount. See Texas Oil and Gas Corp./Gulf Oil Corp., 13 DOE ¶ 85,135 (1985); see also Texaco Inc./Oakwood Oil Co., 22 DOE ¶ 85,262 (1993) (Oakwood).

III. The Business Operations of Ferrellgas.

Ferrellgas maintains that it purchased large quantities of propane and butane from UPG beginning in March 1978. In its application, Ferrellgas describes its business operations as follows:

... Ferrellgas is a large retailer with some wholesaler customers. Ferrellgas presently markets in 45 States through 740 outlets, its present sales are 684,000,000 gallons of retail NGL's with 800,000 customers, [and] 96,000,000 gallons of wholesale NGL's. Ferrellgas had a continuing supply relationship with UPG/Enron that continues to the present time. Ferrellgas in turn made regular purchases from UPG/Enron to maintain supplies to its base period customers for all of its plant locations. Also Ferrellgas supplied dealers and wholesale customers.

... we believe that Ferrellgas' purchases were not immediately used in the same month. If you compare their purchases to sales it shows that the NGL's were stored and used when needed to supplement and maintain supplies to base period customers.

... Ferrellgas utilized purchases for its retail operations and, when it had product available, for the wholesale operations. To support this you will see listed the retail locations of Ferrellgas on the retail bank calculations. Sales were conducted at a local environment as we stated above, usually with homes, farms and commercial places.

July 23, 1996 Ferrellgas submission at 1-2.

We believe that the firm's explanation and supporting data are sufficient to establish the likelihood that Ferrellgas was injured by its purchases from UPG. Ferrellgas depended on UPG as a supplier of propane and butane in order to meet its allocation requirements to its regular customers, regardless of the prices being charged by UPG for those products. Since the prices that Ferrellgas paid UPG for product were not fixed, and in fact varied considerably from month to month, it is clear that Ferrellgas' purchase agreements with UPG did not insulate the firm from the impact of price increases by UPG. Because Ferrellgas’ purchased product was stored and used as needed to supply base period customers, Ferrellgas appears not to have engaged routinely in the type of back to back purchase and sale transactions that would tend to insure some level of profit on its resales of UPG product.

The contemporaneous monthly bank records compiled by Ferrellgas indicate that the firm maintained several classes of purchasers and that many of these purchasers were steady customers of Ferrellgas. Many of Ferrellgas' customers were homes, farms and businesses that apparently relied on Ferrellgas as a steady source of supply. Ferrellgas therefore facilitated the movement of butane and propane from Enron's gas plants to the end-users of those products.

Through its transportation, storage and resale activities, Ferrellgas performed significant economic functions associated with the operations of the NGL market. In its purchases and sales of UPG propane and butane, Ferrellgas was not assured of achieving a complete pass through of the price it paid UPG. Accordingly, we will proceed to evaluate Ferrellgas' banks of unrecouped increased product costs and its information concerning competitive disadvantage to determine whether Ferrellgas has demonstrated that the prices that it paid to UPG for butane and propane resulted in an economic injury to Ferrellgas.

Ferrellgas has submitted monthly purchase summaries that indicate that it purchased 41,855,982 gallons of UPG propane from March 1978 through January 1981. It also claims to have purchased 14,280,000 gallons of UPG butane in 1978 and 1979, for a total gallonage claim of 56,135,982 gallons of UPG product. This volume claim is confirmed by information submitted by Enron to the DOE concerning sales of product by UPG. Based upon this claim, Ferrellgas could receive a maximum volumetric refund of $337,377, plus a proportionate share of the interest that has accrued on the Enron escrow account.

IV. Analysis of Ferrellgas' Injury Showing.

As noted above, Ferrellgas purchased large quantities of propane and butane from UPG for sale at its retail outlets and for resale to other classes of customers. Ferrellgas has submitted data which purports to document its banks of unrecovered increased product costs for the propane and butane purchased from UPG. Under the price regulations, the calculation of cost banks is based on a firm's May 15, 1973 selling prices for its products. During the regulatory period, Ferrellgas maintained a single product cost and a single bank calculation.

A 1983 fire has prevented Ferrellgas from presenting a complete picture of its contemporaneously calculated bank of unrecovered increased costs. However, Ferrellgas has provided two reconstructions of its cost bank. The first is based upon May 1973 profit margins outlined in a Ferrellgas memo dated March 1978. These calculations show Ferrellgas' bank of unrecovered product costs stood at $1,141,531 as of January 31, 1976, and gradually rose to $2,832,816 as of January 31, 1981. The second bank calculation was constructed using May 1973 profit margins established in the DOE audits by Messrs. Messenger and Sellers. These calculations show banks standing at $1,292,993 as of January 31, 1976 gradually rising to $3,188,017 by January 31, 1981. In addition, Ferrellgas has submitted information showing that it received four prior refunds from the DOE totaling $72,375.

Ferrellgas' bank calculations are based on the best available contemporaneous data and appear to be reasonably calculated. Both of the firm's estimates indicate banks for butane and propane that are substantially in excess of the firm's full allocable share of the Enron consent order fund for those two products, even when Ferrellgas' banks have been reduced to reflect prior refunds received from the DOE. Accordingly, Ferrellgas has satisfied the first part of the two-part injury requirement by demonstrating that it incurred increased costs that it was unable to pass through to its customers. See Atlantic Richfield Company/Gast Fuel and Service, Inc., 20 DOE ¶ 85,127 (1990).

In its Application for Refund, Ferrellgas also has performed the three step competitive disadvantage analysis outlined above. As its source of data, the firm initially used the Energy Information Administration's (EIA) Monthly Petroleum Product Price Report (MPPPR). In its October 27, 1997 submission, Ferrellgas submitted an alternative analysis with respect to its purchases of propane using regional prices published in Platt's Oil Price Handbook and Oilmanac (Platt's). Ferrellgas continues to rely on MPPPR data for the analysis of its butane purchases, because Platt's did not publish regional butane prices.

When determining competitive injury, the OHA generally relies on Platt's as the best source of regional average market price data for the purpose of determining the months in which an applicant purchased refined products at prices higher than the regional average. See Atlantic Richfield Company/Phillips Petroleum Company, 22 DOE ¶ 85,217 (1992)(ARCO/Phillips), and cases cited therein at 88,575. We believe that price information assembled on a nationwide basis (like the EIA prices) does not adequately reflect competitive conditions characterizing the regional product markets. See Atlantic Richfield Company/BTU Energy Corp., 22 DOE ¶ 85,074 at 88,231 (1992)(ARCO/BTU). Accordingly, we will rely on Ferrellgas' analysis of its propane purchases from UPG that utilizes Platt's postings for comparative purposes.

In its October 1997 submission, Ferrellgas submitted two competitive disadvantage analyses for its propane purchases, one using Platt's prices for its "Group 120" and the other using Platt's prices for Wood River, Illinois. It states that these two postings best reflect the region where Ferrellgas operated. These sets of prices are very similar, and when applied to Ferrellgas' propane purchases, yield the exact same figure for the amount of UPG propane purchased by Ferrellgas at above market prices. Ferrellgas' net excess cost and gross excess cost do vary slightly according to which set of prices is used. Accordingly, we will take the average of these figures for purposes of conducting our competitive disadvantage analysis.(2)

With respect to Ferrellgas' butane purchases from UPG, we cannot accept its use of EIA data in its competitive disadvantage analysis. Because Platt's price postings are not available for butane, we have developed a methodology for extrapolating regional butane prices from the Platt's postings for propane, based on a finding that butane follows a regional pricing pattern similar to propane, the most widely used NGL product. Eason Oil Company/Presidio Exploration, Inc., 26 DOE ¶ 85,046 at 88,119 (1997)(Eason/Presidio); Enron Corporation/Unocal Corporation, 26 DOE ¶ 85,041 (1997) (Enron/Unocal); ARCO/BTU, 22 DOE at 88,231 and cases cited therein.

Accordingly, we have revised Ferrellgas's analysis of its butane purchases. Our revised analysis extrapolates comparative regional prices for butane using an average of the Platt's wholesale propane price postings for "Gp 120" and Wood River, Illinois, the Platt's listings selected by Ferrellgas, and available EIA nationwide data. In Eason Oil Company/Koch Hydrocarbon Company, 26 DOE ¶ 85,065 (November 7, 1997), we used EIA prices for propane and butane to arrive at a monthly price ratio between those two products. We will use that method here. We will use this monthly ratio as a conversion factor to extrapolate a monthly regional price for butane in this case.(3) Accordingly, in our analysis of Ferrellgas' butane purchases, we have multiplied the monthly propane price (derived from averaging the two Platt's propane price listings) by the ratio of EIA butane to propane prices for that month to arrive at an extrapolated monthly regional butane price.

Our competitive disadvantage analysis, as detailed in the Appendix to this Decision and Order and summarized in Table I below, shows that Ferrellgas was charged uncompetitively high prices for butane by UPG in six of the seven months in which Ferrellgas purchased butane from that firm.

TABLE I

Butane

14,280,000 Gallons

Allocable Share for those Gallons: $85,823

Total Gross Excess Cost $767,041

Total Net Excess Cost $639,361

Above-Market Volumetric Share $60,581

Volumetric Share [71%]

While none of these figures is intended to represent an absolute measure of the injury suffered by the firm, taken together they reveal whether an applicant was placed at a competitive disadvantage by its refined petroleum product costs during the period in which it was allegedly being overcharged. Ferrellgas' gross excess costs and net excess costs substantially exceed the firm's full allocable share of the Enron consent order funds. Moreover, 71% of Ferrellgas' purchases from UPG were made at above-market prices. Collectively, the measures used in the competitive disadvantage analysis strongly suggest that Ferrellgas experienced a substantial and consistent competitive disadvantage

as a result of its purchases of butane from UPG. See, e.g., Enron Corp./Odessa L.P.G. Transport, Inc., 24 DOE ¶ 85,038 at 88,106 (1994); Texaco Inc./Oakwood Oil Co., 22 DOE ¶ 85,262 (1993); Marathon Petroleum Co./Acme Oil Co., 17 DOE ¶ 85,634 (1988); Conoco Inc./Power Pak Co., 17 DOE ¶ 85,016 (1988).

With respect to propane, there is also a strong indication that Ferrellgas experienced some level of injury. However, as shown in Table II below, the level of injury demonstrated by the competitive disadvantage analysis is insufficient to qualify Ferrellgas for a full volumetric refund based on its propane purchases from UPG.

TABLE II

Propane

41,855,982 Gallons

Allocable Share for those Gallons: $251,554

Total Gross Excess Cost $628,744

Total Net Excess Cost ($1,211)

Above-Market Volumetric Share $115,608

Volumetric Share [46%]

While none of these figures is intended to represent an absolute measure of the injury suffered by the firm, taken together they reveal whether an applicant was placed at a competitive disadvantage by its refined petroleum product costs during the period in which it was allegedly being overcharged. For the period as a whole, Ferrellgas' net excess cost for propane is a slightly negative figure and Ferrellgas' gross excess cost is 2.5 times the value of the firm's full allocable refund share of the Enron refund. In previous cases, the gross and/or net excess costs of refund applicants has frequently been more than ten times the applicants' full allocable share of the refund. In such instances, it is clear that an applicant experienced a substantial and consistent competitive disadvantage as a result of its purchases. See Enron Corp./Unocal Corp., 26 DOE ¶ 85,041 at 88,104 (1997); Atlantic Richfield Co./Coast Gas, Inc., 24 DOE ¶ 85,136 (1995) (analysis of propane and butane purchases); Total Petroleum/Mid States Petroleum, Inc., 19 DOE ¶ 85,665 (1989) (analysis of motor gasoline purchases); Conoco, Inc./Power Pak Co., Inc., 17 DOE ¶ 85,016 (1988); Marathon Petroleum Co./Acme Oil Co., 17 DOE ¶ 85,634 (1988); Mobil Oil Corp./Hughes Oil Co., 17 DOE ¶ 85,510 (1988).

This Office has granted only partial refunds to firms whose competitive disadvantage analyses fail to indicate a substantial and consistent competitive disadvantage. For example, in several previous instances where an applicant's net excess cost for covered product is less than 100 percent of its full volumetric refund for that product, we have granted a refund only for the gallons of covered product that the competitive disadvantage analysis indicates were purchased by the applicant at above-market prices. See Atlantic Richfield Company/Coast Gas, Inc., 24 DOE ¶ 85,136 (1995) (analysis of natural gasoline purchases); Total Petroleum/Mid States Petroleum, Inc., 19 DOE ¶ 85,665 (1989) (analysis of No. 2 Oil purchases); Marathon Petroleum Co./Acme Oil Co., 17 DOE ¶ 85,634 (1988); Mobil Oil Corp./Perry Oil Co., 17 DOE ¶ 85,074 (1988). Also, in several instances where even the applicant's gross excess cost of covered product was less than 100 percent of the volumetric refund for its above market purchases, we have limited the applicant's refund to its gross excess cost. See Eason Oil Company/Presidio Exploration, Inc., 26 DOE ¶ 85,046 (1997) (analysis of propane purchases); Aminoil U.S.A., Inc./Mornes, Walter J., 18 DOE ¶ 85,564 at 88,924 (1989); see also Kansas-Nebraska Natural Gas Co., Inc./Cities Service Oil and Gas Corp., 14 DOE ¶ 85,231 at 88,434-35 (1986) (in a case involving a large, negative, net excess cost and a gross excess cost much smaller than the firm's allocable share, the applicant's refund was limited to 50 percent of the gallons that it purchased at above market prices multiplied by the per gallon refund rate).

As noted above, Ferrellgas' competitive disadvantage analysis for propane indicates that its net excess cost is slightly negative and its gross excess cost is 2.5 times its full allocable share of the Enron Consent Order funds. These figures, although indicative of some level of injury, do not clearly establish that Ferrellgas experienced the level of substantial and consistent competitive disadvantage from its purchases of UPG propane that would justify a refund based on its full volume of UPG purchases. Under these circumstances, we believe it is appropriate to grant Ferrellgas a refund based on the volumetric refund for its above-market purchases of propane from UPG.

Based upon the foregoing competitive disadvantage analyses, and in view of our finding that the firm possessed substantial banks of unrecovered increased product costs for propane and butane during the relevant time period, we have concluded that Ferrellgas should receive a refund equal to its maximum potential refund for its purchases of 14,280,000 gallons of butane from UPG, or $85,823. We also have determined that Ferrellgas should receive a refund of $115,608 for its purchases of 19,236,000 gallons of propane from UPG at an above market cost. Accordingly, Ferrellgas' principal refund in the Enron proceeding totals $201,431. In addition, Ferrellgas will receive a proportionate share of the interest accrued on the consent order fund, or $146,118.(4)Ferrellgas will therefore receive a total refund of $347,549 ($201,431 principal and $146,118 interest) for the volumes of butane and propane that it purchased from UPG/Enron.

Accordingly, the total volume approved in this Decision and Order is 33,516,000 gallons of Enron product and the total refund, including interest, is $347,549.

Although we have examined Ferrellgas' claim and supporting data, the determination reached in this Decision is based on the representations made in the application. If the factual basis underlying our determination in the Decision is later shown to be inaccurate, this Office has the authority to order appropriate remedial action, including rescission or reduction of the refund.

It Is Therefore Ordered That:

(1) The Application for Refund submitted by Ferrellgas, Inc. (Case No. RF340-60) is hereby granted as specified below.

(2) The Director of Special Accounts and Payroll, Office of the Controller, of the Department of Energy shall take appropriate action to disburse a total of $347,549 ($201,431 principal and $146,118 interest) from the DOE deposit fund escrow account maintained at the Department of the Treasury and funded by Enron Corporation, Consent Order No. 730V00221Z, to:

Ferrellgas, Inc.

c/o Energy Refunds, Inc.

Highway 80 East

31 Small Lane

Hardin, Kentucky 42048

(3) The determinations made in this Decision and Order are based on the presumed validity of the statements and documentary material submitted by the applicant. Any of those determinations may be revoked or modified at any time upon a determination that the factual bases underlying the Application for Refund are incorrect.

(4) This is a final Order of the Department of Energy.

George B. Breznay

Director

Office of Hearings and Appeals

Date: March 3, 1998

(1)1/ This amount was derived by dividing the fund received from Enron allocable to refined products ($43,200,000) by the estimated volume of refined products sold by Enron from June 13, 1973 through the date of decontrol of the relevant product (7,186,265,624). Id. at n. 8.

(2)We note that Ferrellgas has combined its propane and butane purchases into a single competitive disadvantage analysis. We believe it is appropriate to conduct separate analyses for these two products. See Eason Oil Company/Presidio Exploration, Inc., 26 DOE ¶ 85,046 at 88,120 (1997).

(3)Several earlier OHA decisions calculated a price conversion factor by directly comparing the Platt's regional propane prices with national EIA prices for butane. See ARCO/Phillips, ARCO/BTU, and cases cited therein. We believe that the relationship between propane and butane prices in this case can be understood more accurately by assessing comparable national EIA price data for propane and butane. The conversion factors from propane to butane derived from this relationship may then be applied to the Platt's regional propane prices to calculate regional prices for butane.

(4)Interest has accrued on the Enron consent order funds since July 27, 1988, the date that Enron remitted the consent order funds to the DOE. Almost all of this money earns interest at rates established in auctions of six month treasury bills. The current ratio of interest to principal in the Enron account is roughly seven to ten.

A
$639,361 $767,041 10,080,000
     
Appendix              
Case No. RF340-60              
Competitive Disadvantage Analysis              
Propane              
               
Date Gallons UPG/Enron Average of Above/ Net Gross Above
    Price/ Platt's Prices/ (Below) Excess Excess Market
    Gallon Gallon Market Cost Cost Volume
               
1978              
March 4,830,000 $0.2200 $0.246290 ($0.0263) ($127,029) $0
April 2,249,982 $0.2175 $0.240309 ($0.0228) ($51,300) $0
November 7,770,000 $0.2231 $0.212085 $0.0110 $85,470 $85,470 7,770,000
             
1979            
February 4,200,000 $0.1850 $0.204450 ($0.0195) ($81,900) $0  
March 5,250,000 $0.1950 $0.202587 ($0.0076) ($39,900) $0
September 2,100,000 $0.4000 $0.316769 $0.0832 $174,720 $174,720 2,100,000
November 3,570,000 $0.4171 $0.351850 $0.0653 $233,121 $233,121 3,570,000
December 1,050,000 $0.4500 $0.364415 $0.0856 $89,880 $89,880 1,050,000
               
1980              
February 1,680,000 $0.3740 $0.406107 ($0.0321) ($53,928) $0  
March 3,150,000 $0.3500 $0.418556 ($0.0686) ($216,090) $0  
May 420,000 $0.3800 $0.420555 ($0.0406) ($17,052) $0  
June 840,000 $0.3731 $0.424000 ($0.0509) ($42,756) $0  
October 2,520,000 $0.4317 $0.422223 $0.0095 $23,940 $23,940 2,520,000
December 1,050,000 $0.4650 $0.445242 $0.0198 $20,790 $20,790 1,050,000
               
1981              
January 1,176,000 $0.4538 $0.453087 $0.0007 $823 $823 1,176,000
               
               
Totals: 41,855,982       ($1,211) $628,744 19,236,000
               
               
Competetive Disadvantage Analysis              
Butane              
               
Date Gallons UPG/Enron Extrapolated Above/ Net Gross Above
    Price/ Regional (Below) Excess Excess Market
    Gallon Price/ Butane Market Cost Cost Volumes
               
1978              
October 3,360,000 $0.2150 $0.207937 $0.0071 $23,856 $23,856 3,360,000
November 4,200,000 $0.2013 $0.231679 ($0.0304) ($127,680) $0  
December 1,050,000 $0.2500 $0.218415 $0.0316 $33,180 $33,180 1,050,000
               
1979              
May 2,100,000 $0.4063 $0.339742 $0.0666 $139,860 $139,860 2,100,000
June 1,050,000 $0.4075 $0.389846 $0.0177 $18,585 $18,585 1,050,000
September 1,646,400 $0.6050 $0.420111 $0.1849 $304,419 $304,419 1,646,400
November 873,600 $0.6435 $0.360598 $0.2829 $247,141 $247,141 873,600
               
Totals 14,280,000       $639,361 $767,041 10,080,000
               


Last Updated on 6/9/98
By Marcia Carlson