ML20213G363
| ML20213G363 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/11/1987 |
| From: | Madsen A LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20213G347 | List: |
| References | |
| OL, NUDOCS 8705180250 | |
| Download: ML20213G363 (38) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TdE COMMISSION
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL
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(Shoreham Nuclear Power Station,
)
Unit 1)
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AFFIDAVIT OF ADAM M.
MADSEN IN SUPPORT OF REQUEST FOR AUTHORIZATION TO INCREASE POWER TO 25%
STATE OF NEN YORK
)
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To-wit:
CITY / COUNTY OF NASSAU
)
Adam M.
Madsen, being duly sworn, deposes and says:
(1)
My name is Adam M.
Madsen.
My business address is Long Island Lighting Company, 175 E.
Old Country Road, Hicksville, New York 11801.
(2)
I am currently Vice President, Corporate Plan-ning, for the Long Island Lighting Company.
I have been em-ployed by the Long Island Lighting Company for 26 years and l
l have served in a number of positions, including Manager of j
Engineering and Manager of the Planning Department.
Since 8705180250 870512 PDR ADOCK 05000322 O
PDR 1978, I have been LILCO's representative on the New York Power Pool Planning Committee.
Since 1984, I have been LILCO's representative on the Northeast Power Coordinating Council's Joint Coordination Committee.
(3)
I hold a Bachelor of Electrica] Engineering de-gree from Manhattan College and a Master of Science degree in Nuclear Engineering Science from Long Island University, and I am a registered Professional Engineer in tne State of New York.
(4)
As Vice President for Corporate Planning, I have the overall responsibility for supervising and directing the development of the Company's gas and electric load forecasts and the planning of the gas and electric supply, generation and transmission facilities needed to meet projected loads.
In exercising this responsibility, I and persons under my direction and control have developed extensive knowledge of the electric demand and supply situation not only for Long Island but also for New lork State and the Northeast region.
I have been intimately involved in the Company's efforts to deal with the electric energy crisis that has developed on Long Island.
(5)
I previously submitted an affidavit supporting LILCO's Request for Authorization to Increase Power to 25%
i (LILCO Requestj.
My affidavit attested to tne accuracy of the description of the need for Shoreham's power in LILCO's submittal.
Tne purpose of this affidavit is to respvt.d to the Affidavit of William E.
Davis of the New York State En-ergy Office.
(6)
Mr. Davis' conclusion that Shoreham is not needed is totally inconsistent with the realities of the energy supply situation on Long Island and is unsupported by his own affidavit.
The affidavit is flawed because:
(a) it relies on SEO forecasts that have changed noticeably to reflect the State's opposition to Shoreham; (b) the forecasts in question are totally at odds with the assessments of responsible expert agencies that have consistently confirmed the marginal and declining reliability of the efec-tric supply system on Long Island over the past several years; (c) the options suggested by Mr. Davis are al-ready incorporated into LILCO's analysis sub-mitted to the NRC and that analysis shows that Shoreham is needed; and l
1
_4_
(d)
Mr. Davis relies upon erroneous statistics to underestimate the severity of the electric reliability situation on Long Island last summer.
Significantly, Mr. Davis' affidavit is inconsistent with a statement attributed to his superior shortly after the affi-davit was signed.
According to an April 30, 1987 Newsday article:
" State Energy Commissioner William Cotter told a legislative hearing yesterday that Long Island immediately needs more electricity capacity."1/
The SEO's Forecasts Have Reflected New York State's Opposition to Shoreham (7)
The State Energy Office's present position that Shoreham is not essential in either the near or longer term is a dramatic departure from the longstanding energy policy of New York State.
The latest approved version of the New York State Energy Master Plan, issued in 1982, recognizes the importance of Shoreham as a remedy for Long Island's chronic and dangerous dependence on foreign oil.
A draft of a new New York State Energy Master Plan, dated August 1983 i
also supported the completion of Shoreham.
1/
Newsday, April 30, 1987, at p. 7.
Mr. Cotter suggested this need could be met by small power producers.
In para-i graph 22 below, I discuss why this proposed solution is un-i realistic.
l t
(8)
Since New York State adopted a policy of opposing the operation of Shoreham in 1984, however, the State Energy Office has served as one of the principal arms of New York State government in subsequent attacks on the need for Shoreham's capacity.
Since 1984, the New York State Energy Office has consistently underforecast the demand for elec-tricity on Long Island.
See Figure 1.
In December 1984, despite four years of strong growth in normalized electric demand on Long Island, the SEO submitted an affidavit to an NRC Licensing Board / which included a load forecast showing a projected decrease of 147 MW over a five year period.
(Figure 1).
In the two years since that forecast, the actu-al weather normalized peax load on Long Island increased nearly 200 MW, a development consistent with previous trends.
(9)
The Davis Affidavit relies heavily on a December 1985 report 2/ which has been found to be seriously flawed in its forecast for the reliability of electric supply on Long 2/
Affidavit of Eugene Gleason, Director, NYS Energy Of-Tice, Bureau of Planning, NRC Docket No. 50-322-OL-4, attached to "New York State and Suffolk County Supplementary Affidavit in Support of Comments filed November 29 and Re-quest for Oral Argument filed November 29," submitted December 5, 1984.
3/
" Meeting the Challenge An Analysis of Electricity Supply Options for New York State," NYS Energy Office, December 1985.
l
- i Island.
This forecast prompted the member electric corpora-tions of the New York Power Pool (NYPP) to perform their own study of Long IslandA! which was made public at a press briefing given by the Energy Association of New York StateI!
3 on February 18, 1986.
In a press release of the same date,b/ Howard Shapiro, Director and General Counsel of the i
Energy Association, citing the NYPP report, criticized the I
portions of the Energy Office study which focus on Long Is-land, noting in particular inconsistencies in the projected j
electric demand growth rate between the SEO report and actu-al experience.
He called specific attention to the 1
seven-tenths of one percent (.7%) per year growth rate projected by the SEO for 1986-1995 and compared this figure
[
]
to the 2.5% average annual increase in electric demand actu-l i
j ally experienced over the previous five years (1980-1985).
[
l Mr. Shapiro stated that the SE0's low projection " strains l
one's credibility," especially since it is about half the j
growth rate projected by the Sdo during the same time periou I
f/
"An Assessment of Future Reliability of Electric Supply i
)
on Long Island," February 18, 1986.
i j
5/
The Energy Association represents the seven investor i
owned combination electric and gas utilities in New York State.
l f/
"Long Island's Energy Supply in Jeopardy," Energy Asso-clation of New York State, February 18, 1986 (referred to as l
l Press Release).
1 i
l for the State as a whole.
The SEO had manipulated its fore-cast to conclude that average growth over a 15 year period would be 1.79% per year, not significantly different from other projections.
But the SEO reached this result by pre-dicting a.7% growth for 10 years and then a precipitous in-crease in the growth rate for the next 5 years.
- Moreover, even 1.79% average growth per year over tne period 1984-2001 was contrived.
It was based upon a 1984 actual, experienced peak demand (3096 MW) which had not been corrected for weather.
In fact, the 1985 actual peak demand (3 380 MW) was known by the SEO long before the issuance of the SCO report.
By using the lower base number, however, the percentage in-creases gave the appearance of a higher, more reasonable, growth rate even though the absolute annual peak values were significantly lower than in other projections.2/
The result of the S80's manipulation was a projected peak demand for LILCO whicn increased by only 114 MW over five years - com-pared with an actual weather normalized peak growth of 385 MW over the preceding five years and an increase of 100 MW between 1985 and 1986.
This low forecast for the late 1980's allowed the SE0 to conclude that Shorenam is not needed.
7/
The SEO forecast growth rate for LILCO in December 1985 should have been expressed as 1.3% per year (as the SEO now Concedes).
(10) In commenting upon the 1985 SEO Report Mr.
Shapiro of the Energy Association said it was totally incon-sistent with Long Island's booming economy:
How can the SEO justify a depressed electric demand growth projection in an area where unemployment is extremely low, new jobs are being created at a prodigious rate, the economy is booming and the portion of disposable income spent on utility bills is lower tnan anywhere else in New York?
It is clear that the SEO's Long Island strat-egy lacks the balance required for a serious planning study.d/
(11) In another criticism of the SE0's 1985 report, Mr. David Laniak (past Chairman of the New York Power Pool Planning Committee) relied on the NYPP report to conclude that electric reliablity on Long Island was below minimum statewide standards and could be expected to get gradually worse over the next few years.
With the assistance of State and local
. we are gradually governments, creating for the Island an electric supply situation which threatens to stymie its economic growen.
The reasons for this situation are simple not enough generation on the Is-land and the exceptionally limited ca-pacity to transmit electric power to the Island from the rest of New York State and Connecticut.9/
8/
Press Release at p.
2.
9/
Press Release at p.
3.
Mr. Laniak concluded that the easiest way to correct this situation is to begin commercial operation of the Shoreham plant.1S/
(12) Mr. Davis' heavy reliance on the 1985 SEO fore-cast that has been totally discredited and immediately repu-diated by the New York Power Pool makes his entire af fidavit unreliable.
(13) The Davis Affidavit reveals that the S80 is now predicting a peak load forecast for LILCO of 1.9% growth per year through the year 2000 (versus 1.3% in its 1985 report).
The report, however, has not been maae public and Mr. Davis provided no details.
Thus, this statement must be viewed with extreme caution, particularly in light of the 1985 forecast manipulation.
(14) Significantly, LILCO's currently expected net peak demand of 3500 MW (3570 MW 1ess 70 MW of conservation and peak load control) for the summer of 1987 exceeds the December 1985 SEO forecast peak for LILCO for 1990.
And now the Davis Affidavit indicates that forecast growth rate for LILCO through 2000 has been increased to 1.9% per year.
It is impossible to reconcile those facts with his conclusion that there is still no need for shoreham's capacity.
10/
Press Release at p.
3.
Experts Have Consistently Confirmed the Electric Supply Crisis on Long Island (15) The Davis Affidavit is totally at odds with studies conducted by several expert organizations which have verified the marginal electric reliablity situation on Long Island.
In particular, three studies produced in 1986 and referenced in LILCO's Request (pages 111-15) suggest tnat Mr. Davis is out of touch with reality.
Those reports are:
" Assessment of future Reliability of Electric Supply on Long Island," New York Power Pool, February 1986.
"New York Power Pool 1986 Summer Operating Re-serve Projection and Analysis," New York Public Service Commission, May 1986.
"1986 Summer Assessment of Overall Reliability of Bulk Power Supply," North American Electric Reliability Council, 1986.
In these reports, the PSC, the NYPP and NERC agree that Long Island is presently experiencing severe capacity and system reliability problems which will get progressively worse over time.if no rew capacity is installed on Long Island.
(16) Since the submittal to the NRC of LILCO's origi-nal Request on April 14, the eight member systems of the New York Power Pool have published their 1987 Integrated Plan-ning Strategy which again confirms the margin 11 reliability situation on Long Island.
The report status:
"The reliability of NYPP is high except on Long Island...."
Integrated Planning Strategy at 12.
The report cites Long Islanc's limited transmission capabilities and notes that both new generation and transmission reinforcements are re-quired to improve electric reliability on Long Islana.
In-tegrated Planning Strategy at 19, 27.
The report also states that if Shoreham is not permitted to operate, more than just Long Island will be affected; capacity deficiencies for the NYPP as a whole will appear much earli-er than anticipated.
Indeed, statewide deficiencies coula appear as early as 1992 if Shoreham and an upstate pumped storage project that has licensing problems do not operate.
Integrated Planning Strategy at 29.
(17) Thus, the conclusion in the Davis A;.Adavit tha t Shoreham is not needed is totally at odds with the conclu-sion of several expert agencies whose only interest in the Shoreham situation is assessing power reliability.
Mr. Davis' Recommendations Have Already Been Incorporated into LILCO's Assessment (18) The Davis Af fidavit (paragrapn 10), suggests a number of steps which can be taken in the near term to in-crease available resources and " maintain supply relianility on Long Island in the absence of Shoreham."
Each of these suggestions, however, has either already been included in LILCO's projections or cannot be achieved in the time frame suggested.
The analysis provided in LILCO's Request in-cludes all feasible resources available in the 1987-1989 time frame.
The following review demonstrates that the steps suggested by the SEO do not eliminate the need for Shoreham.
(19) Increase Transmission Capacity of 345kv Cable -
The increase in capacity of the Y-50 cable suggested oy the SEO is already underway and has been included in LILCO's analysis submitted to the NRC.
This presumes that LtLCO's internal system will be able to accommodate the increased impacts.
A study is now underway to determine if reinforce-ments are needed.
(20) Increase Imports From Connecticut - LILCO's interconnection to Connecticut Joins the LILCO system at the Northport Power Station.
The transmission exits from the Northport Power Station into the LILCO transmission system have the capability of delivering approximately 1520 Md.
The Northport Power Station has a total capacity of 1518 Md.
Therefore, there is no capacity available for power imports from Connecticut whenever the Northport generating units are operating at full capacity.
It would take about three years to license, uosign and construct a new circuit out of Northport to permit increased imports.
But capacity limitations out of Northport are only part of the problem.
During peak load conditions or when certain transmission i
lines or generating units are not available in Connecticut, Northeast Utilities cannot deliver any power to LILCO.
LILCO Request at 113-14.
Limitations in Connecticut are ex-I pected to continue to exist until several transmission rein-forcements are fully completed in the Norwalk area in tne 1990-1991 time frame.
Finally, while Northeast Utilities currently has generation available for export since Mill-stone 3 went on line, the New England Power Pool has been 4
experiencing operating shortages and reliability problems for the past several summers.
With the uncertainty sur-rouncing Seabrook and no other major generation currently planned anywhere in New England, it is not clear that generating capacity would be available in tne 1990's even if the required transmission reinforcements are in place.
(21) Utilize Shoreham Diesels -
The SEO suggests an absurd trade:
809 MW of non-oil fired base-load capacity for 28 MW of oil fired peaking capacity.
As the NRC well knows, LILCO cannot rely on its emergency diesels at Shoreham to supply system loads as long as LILCO continues to seek an operating license for Shoreham.
(22) Promoting Small Power Producers - LILCO's analy-sis of capacity needs for the future already includes over
. - - - ~. -
300 MW of small power production facilities over the next ten years.
The SEO's suggestion that 300 MW of such facili-ties could be in service by 1991 and 480 MW by the year 2000 is unrealistic and would essentially require contracts for that capacity to be in place now.
In fact, LILCO now has contracts signed for only about 99 MW of such generation.
Mr. William D. Cotter, Commissioner of the New York State Energy Office, in a presentation before a joint legislative hearing on small power producers on March 25, 1987, noted that the SEO has cut its projection of statewide small power producers through 2002 nearly in half from its December 1985 report.11/
The new projection is 800 MW versus 1500 MW in 1995.
He also noted that small hydro could comprise 240 MW of this total - leaving 560 MW of non-hydro additions.
There are no small ' hydro sites on Long Island.
Mr. Davis' claim that "over 480 MW" of small power producers could be in service on Long Island by the year 2000 is over 85% of the total non-hydro sources which the SEO has predicted for the entire State.
Something is clearly wrong with such an estimate.
The nature of the industrial load on Long Island 11/
Remarks of William D. Cotter, Commissioner, New York l
State Energy Office, Before the Joint Public Hearing of the New York State Assembly Standing Committee on Energy, New York State Assembly Standing Committee on Environmental Con-servation and New York State Senate Committee on Energy, March 25, 1987.
t is not particularly suitaole for large cogeneration instal-lations.
Needless to say, if the forecasted small power producers do not materialize, reliability will be further eroded.
(23) Enhancing Conservation and Load Management - The Davis Af fidavit states that 210 MW of conservation and load management could be in place by 1991 and a total of 540 MW of such load reducing measures by the year 2000.
LILCO has recently embarked upon the most aggressive and ambitious load management program of any of the New York State utilities.
This program anticipates the expenditure of ap-proximately $10 million per year, a level 2 1/ 2 times the spending guidelines established by the PSC for other utilities.
The LILCO forecast upon which the LILCO analysis is based already includes 315 MW of conservation / load man-agement load reduction by 1991 and 705 MW by the year 2000 -
levels substantially greater than that suggested as feasible by the SEO.
To the extent that such measures do not come to pass, or fail to have lasting peak load reduction, the ca-pacity deficiencies presented in LILCO's anlaysis will be even greater.
(24) New Gas Turbines on Long Island - Because of New York State's and Suffolk County's continuing efforts to delay Shoreham, LILCO began work on a nominal 200 MW combustion turbine installation on Long Islano in late April, 1986.
After a comprehensive siting study which eval-uated ten candidate sites, LILCO selected the preferred lo-cation in November, 1986.
LILCO proceedea immediately with bid preparation and solicitation and with preparation of all required major permit applications.
Bid packages were sont out in late December,1986, and final proposals were re-ceived in March, 1987.
Commercial and technical bid evalua-tions are currently being performed.
Major environmental permit applications have been drafted.
While it may be pos-slole to acnieve commercial operation of this installation by the summer of 1989, given the uncertainties inherent in both the licensing and design and construction process, a 1990 in-service date appears more likely at this time.
The Davis Affidavit Fails to Recognize the Severity of the Electric Reliability Situation on Long Island in 1986 (25) Mr. Davis attempts to support his position on Shoreham by suggesting that the power supply situation last summer really was not all that bad.
He bases his attack on a " supply ratio" computed using weather normalized peak load.
He also attacks key assumptions in LILCO's analysis.
On each score, Mr. Davis is in error.
l 1 (26) The SE0's " supply ratio" uses weather normalized data.
While weather normalized cata should be used to fore-cast future loads, it does not give a true picture of the actual supply situation on any given day in the past.
The actual experienced peaks give the proper indication of sys-tem reliability.
Thus, LILCO has computed the SE0's " supply ratio" for the past several years using actual experienced peak load on Long Island.
These historical supply ratios, shown in Table 1, give a clear indication of tne declining reliability on Long Island over the past 5 years, and con-firm, as LILCO has stated, that 1986 was the worst year yet.
(27) Mr. Davis attempts to bolster his reliability conclusions by asserting that there were no voltage reduc-tions in 1986.
While no voltage reductions occurred last summer, the reliability of the system was still inadequate.
Voltage reductions were avoided only because of abnormally cool weather and unusually high generation availability dur-ing the peak.
Weather conditions conducive to producing a summer peak occurred fewer times in 1986 than any summer over the last 10 years.
(Table 2).
This results in a num-bor of peak load days well below average and a significant reduction in the probabili ty of system problems occurring.
Even with the cool weather, the peak load forecast was ex-coeded by 60 Md.
Another reason the 1986 experience was not worso was the very high generation availability on pean load days.
On days where peak load exceeded 3000 MW, the average amount of generation that was unavailable was 533 MW.
Even moro unusual, during the top throo load days, the average amount of gonoration that was unavailable was an ex-traordinarily low 315 MW.
This compares to an average unavailability during the four summor months of over 700 MW for the past throo years.
Soo Table 3.
Even if one woro to look only at the " typical" peak load months of July and August (though high loads havo occurred in Juno and Septembor), the corresponding unavailability has boon nearly 600 MW (Tablo 4).
(28) The SEO suggests that LILCO's low unavailability rato in 1986 was not unusual.
But the unavailability sta-tistic pr.sonted in paragraphs 19-20 of the Davis Affidavit is moroly an averago of just four individual days over four years.
This statistic is moaningless.
As shown abovo, over the past throo summers, LILCO's averagu unavailability value was over 700 MW compared to Mr. Davis' 468 MW.
Daily unavailability could be much higher than the averago.
The wook prior to the 1986 Summor Poak, the actual unavailability value for the LILCO system was 1100 MW.
Fur-thermoro, when considoring the actual gonoration availaulo to moot load, an additional 200 to 300 MW of oporating i
I
-t9-reservo is needed to survivo the f ailure of the largest sup-ply source on-lino.
LILCO must be prepared to cope with the worst conditions but without Shoreham it is becoming in-creasingly difficult to conclude that LILCO is capable of doing so.
(29) Even with unusually cool wouthor and unusually high gonoration availability, a number of system difficul-ties woro experienced during the 1986 summer period:
tio. of occasions Gonoral Public Appeals 1
LILCO Roduced Its own Load 6
Commercial Customors Auxod to Voluntarily Curtail 3
Roscrietod Domand Customors Called Upon 6
Municipals Askud to Run All Gonoration 7
As alroady stated in LILCO's potition on pago 104, "nad LILCO experiencud ovon the normal averago unavailability on July 7, l'386, brownouts and ovon solocted blackouts might well have occurrod."
This is clearly not tho indication of a rollablo or ovon desirablo oloctric nupply situation.
. Additional Reliability Analysis (30) As additional rebuttal to Mr. Davis' Affidavit, I would like to present LILCO's most recent analysis whicn confirms the declining reliability on Long Island in f uturo years without Shoreham.
Tno analysis submitted in LILCO's Roquest has boon extended through 1992 since it is possible that the only near-torm measure, other than Shoronam, to im-prove significantly the rollability of supply on Long Island
- the NYPA Sound Cablo Project - may not be availablo until after the summor of 1992.
(31) LILCO's system must be capable of mooting load domands without an unacceptablo lovel of brownouts or rotating blackouts.
Tho Now York Power Pool Agroomont, to whicn LILCO subscribos, conforms to the Northeast Power coordinating Council (NPCC) gonorating capacity design critoria which statost Each aroa's gonorating capacity will be planned in such a mannor, that after duo allowanco for scheduled mainto-nanco, forced and partial outages, interconnections with neighboring areas, and availabio oporating proco-duros, the probability of disconnocting non-intorruptiblo customors duo to gon-oration deficiency, on the avorago, will bo no more than onco (1) in ton years.
The NYPP has developed reserve margin and acceptable brown-out values based on this criterion.
The NYPP believes that the goal can be mot with a reserve of 18% for eacn member, assuming unlimited interconnection capacity.12/
This gener-ic reservo policy translates to a risk of no more tnan 4 voltage reductions per year for the whole power pool.
I n to-grated Planning Strategy at 27.
However, more stringent in-dividual resorvos are nocessary to maintain the target reliability level, if the assumption of unlimited interconnection is not valid.
For LILCO, of courso, it is not.
Thus, LILCO must perform a utility specific analysis to datormine the appropriate reservo margin.
LILCO's des ign objectivo is to acnieve a reliability lovel approaching no more than three voltage reductions per year.
Tnis repro-sonts 75% of the NYPP objective of no more than four voltage reductions statewide por year.
(32) Compliance with this criterion is measured by the loss of load probability (LOLP) index and by the considera-tion of omorgency oporating proceduros.
LOLP studies take into account the ratings of generators, planned maintenance, forced outage ratos and doratings.
Tho results of those probability calculations provido a measuromont of tno 12/
This genoric 184 reservo margin is a contractual mIntmum roquirumont for all NYPP members.
expected number of days per year on which available generating capacity cannot meet the forecasted load.
(33) Consistent with LILCO's original filing, the der-ivation of the required generation reserve margins and cor-responding deficiencies on Long Island considered total Long Island load and resources, not just LILCO's.
This is neces-sary because Long Island is an island with limited interconnections.
Table 5 shows the results of tne latest Loss of Load Probability (LOLP) analysis for Long Island.
It indicates that the probable number of brownouts tha t would occur far exceed the goal of 3 per year.
(34) Table 6 shows hypothetical generation additions required to meet the desired level of brownouts.
This most recent reliability analysis indicates that total resource margins required to provide reliable electric service to Long Island is in excess of 30%.
For the purpose of the original filing, LILCO conservatively used the approximate value of 30% (page 109) for the required reserve margin.
The higher reserve margins calculated in Table 6 are more precise numbers derived from a computer mocol designed for this type of study.
The required reserve varies from year to year depending upon the actual mix of load and resources available at the time.
(35) As stated in LILCO's Request, LILCO cannot meet the total 1987 deficiency with currently available or antic-ipated resources.
The hypothetical generation in Taole 6 needed to meet the reliability criterion represents the gen-eration deficiencies on Long Island.
This table includes the appropria te near term measures or actions mentioned in the Davis Affidavit.
In this most recent LILCO analysis, the 1987 summer demand exceeds available resources by 300 MW.11!
The deficiency is projected to double by 1992.1d/
This is hardly the improving situation claimed in paragraph 6 of the Davis Affidavit.
(36) The Davis Af fidavit suggests Consolidated Edison Company has barge mounted gas turbines that could be moved to Long Island.
As the State knows, LILCO and otners nave approached Con Edison about moving these gas turbines to Long Island.
Con Edison has stated that these units cannot be moved because Con Edison needs them for their own system.
But even if Con Edison did not need these gas turbines, they cannot be moved quickly.
A very preliminary analysis 13/
LILCO's Request predicts a 1987 deficiency of 216 MW.
THe prinicipal difference is that LILCO has used a more accurate computer simulation in the most recent Loss of Load Probability Study.
14/
Even if LILCO completes 200 MW of gas turbines and transmission reinforcements are made in Connecticut and Long Island, only about 300 MW additional would be available by 1990, still leaving large deficiencies.
_ _ _.. i indicates that, on an expedited basis, it would take 6 to 12 months to get the necessary permits and another 6 to 12 months to actually erect the necessary f acilities, move tne barges, and connect them to LILCO's transmission system.
(37) A May 10 New York Times article (a ttached) sug-gests that Con Edison would agree to let LILCO use the barges in an emergency; I have reconfirmea that Con Edison is unwilling to allow LILCO to use the 9arges.
The same ar-ticle also reports that Con Edison has available an addi-tional 200-300 MW of firm power they could sell to LILCO this summer.
The article misleadingly suggests this would improve reliability.
The confusion apparently stems from a lack of understanding regarding the type of power LILCO has availablc this summer.
LILCO has entered into firm two-party contracts to purchase power for this summer from Con Edison, Northeast Utilitics, NYPA, and the Villages of Freeport, Greenport and Rockville Centre.
The total amount of firm power LILCO has purchased is 541 MW, of which 505 MW is from of f Long Island.
The level of LILCO's firm power contracts takes into consideration (a)
LILCO's NYPP con-tract requires LILCO to maintain or puchase enough generating capacity to maintain at least an 18% reserve; (b) economic and operational flexibility considerations; and (c)
LILCO's normal transmission import capacity.
LILCO, through its NYPP contract and various interpool con-tracts, has the right to purchase additional power this sum-mer, including the purchase of emergency power if it is available.
As already stated in LILCO's Request on page 109, LILCO relica on importing up to the full effective emergency capacity (650 MW) of the transmission system in calculating its resource deficiency.
See Tables 5 ana 6.
Therefore, the "new" power referred to in the article has already been included in our projections; between firm and emergency contracts we will purchase up to the limit of 650 Md this summer.
In short, while LILCO could enter into firm contracts for thousands of megawatts, we cannot get it on to Long Island because of transmission limitations.
(38) As this analysis indicates, increased capacity is needed immediately to improve the marginal reliability situ-a tion on Long Island.
And Shoreham is the only new capacity that is immediately available.
4th M M Adam M.
Maasen
I J
l l I STATE OF NEW YORK
)
)
CITY / COUNTY OF NASSAU
)
Subscribed and sworn to before me this
//
day of May 1987.
THOMAS S. DAMICO NOTARY PU8UC, State of h Yd IM M h sum County My commission expires:
M Empires W dcc, g,, f7g7 kbo-l Dw.- -
Notary Public
COMPARISON OF FORECASTS ricuas 1 4500-
)
BEFORE CONSERVATION 8 PEAK DEMAND CONTROL 4000-S 2
+-- AFTER CONSERVATION 8 PEAK DEMAND CONTROL
( l.7 % / Yr. )
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fyc,o""',,,,o,o""
o 0d o ""l. io,,
3500-a o
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s 3000-1 I
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1980 1985 1990 1995 YEAR
- EXPERIENCED NORMALIZED PEAK ON L.I.
- - - -= FORECAST TESTIFIED TO BY SEO IN DEC.1984
............... S EO FORECAST OF DEC.1985 I\\\\ \\ \\ \\1 RANGE OF LILCO FORECAST
Supply Ratios TABLE 1 LOAD RESOURCES Actual LILCO Brk. &
L.I. Muni.
LILCO Emerg. Muni.
Supply Load Grumm.
(Estimated)
Total Generation
_ Tie Gen.
IPP Total Ratio 1981-3132 75 3207 3609 600 90 4299 34.1%
1982 3045 73 3118 36C9 600 90 4299 37.9%
1983 3108 20 75 3203 3609 600 90 2
4301 34.3%
1984 3094 23 75 3192 3609 600 90 1
4300 34.7%
1985 3317 33 80 3430 3717 600 90 3
4410 28.6%
1986 3441 31 83 3555 3747 600 90 3
4440 24.9%
TABLE 2 Number of Weekdays With a Year 24-Hour Average THI at 75 or Higher 1977 19 1978 8
1979 20 1980 20 1981 11 1982 9
1983 21 1984 11 1985 10 1986 6
10-Year Average 13.5
l TABLE 3 Average Generation Unavailable Year June - Septemoer (Md) 1984 709 MW 1985 655 MW 1986 818 MW 3 ' lear Average 727 MW
TABLE 4 Average Generation Unavailable Year July - August (MW) 1984 588 MW 1985 569 MW 1986 606 MW 3-Year Average 588 MW
Reliability of LILCO System Shoreham Out of Service 1
l l
{
i Long Island Load Available Resources LILCO L.I.
L.I.
Emergency Conse rva tion l
Base Muni. Grumm. &
Total LILCO Muni.
Independent L.I.
Total Brownouts Year Forecast Loads Brkhvn.
L.I. Load Cen.
Gen.
Power Prod Import Demand Control Resources Days / Year l 1987 3570 88 37 3695 3747 90 10 650 91 4588 14 l 1988 3725 90 37 3852 3747 90 40 650 193 4720 16 1989 3875 92 37 4004 3747 90 70 700 291 4898 15 1
1990 3995 94 37 4126 3747 90 100 700 356 4993 17 1991 4100 95 37 4232 3747 90 130 700 419 5086 19 1992 4200 97 37 4334 3747 90 160 700 480 5177 20 l
l I
l l
C E
m t.n
RELIABILITY OF LILCO SYSTEM With Hypothetical Generation Added to Maintain Criteria l
Shoreham Out of Service I
Required Resources Resulting Required Generation Total Available
- Hypothetical Cumulative Total
' Brownouts Reserve Margin Year L.I. Load Resources Required New Generation Generation (Days / Year)
(Total Cen./ Total Load) 1987 3695 4588 300 4888 3
32.3 1988 3852 4720 400 5120 3
32.9 1989 4004 4898 400 5298 3
32.3 i 1990 4126 4993 450 5443 3
31.9 1991 4232 5086 550 5636 3
33.1 1992 4334 5177 600 5777 3
33.3 0 Consisting of the same components presented in Table 5 Y
$o Os
1 NEWSPAPER ""71 M
. 77hk 3 DATE
,5~ /o T 7 PAGE 3pa w*n.2r ?r. /, /Q f
ConEdOffers LilcoXew PowerIf Xeeded ByJOHN RATHER In M to the a'*=*a. at-Mr. Davis and other officials, in-torneys for New York State and Suf-cluding Representative George J.
THE Long Island Lighting Company, which is folk County said questions raised by Hochbrueckner Democrat of Coram, seeking to use 170 megawatts of power frorn the Ulco Reposal, which the com-also assert that Lilco could borrow a the Shoreham nuclear plant to meet what it ex-pany spent 18 months preparing, generator mounted on a barge from pects to be record energy demands this sum.
should require a minimum of one Con Ed capable of producing 150 mer, can count on support from a neighboring utility.
year of hearings. The state and megawatts to increase supplies d' r-u Officials of the Consolidated Edison Company said county attorneys said they would also ing peak demand periods. Mr. Hoch-they were prepared to sell Lilco an additional 200 mega., need timeto review and assess Lilco brueckner said the gas-fired turbines watts to 200 megawatts of power beyond what it has al.
findings that operating the plant at on the berge could connect to the ready contracted for. But according to a Con Ed spokes-the higher power level would pose no Lilm electric grid at IAna Beach.
woman, Bea Meltser,"They have not asked us for it."
, risk to the lic, despite state and Ms. Meltser of Con Ed said the Under an agreement between the two utilities that ; local to participate in emer-company had no plans to allow Lilco took effect this month, Con Ed has already agreed to sell gencyp to use one ofits six barges,which Con Lilco 250 megawatts during the warm. weather months.
In an vit filed by t's attor. Ed deploys during storm watches and, With a comfortable margin of reserve power, the Con asys, a state energy official also said to back up its own supply system.
Ed officials seemed more than willing to sell Lilco more.
that Lilco would be unlikely to derive
'"You can't just plug them in and then Lilco officials have said that even the availability of dependable supplies from Shoreham unplug them,"she said.
additional power might not be enough to insure a pru.
even if the application were ap-But she also said that, at the re-dont margin of reserve power. State and local officials, preved.
however, say Lilco is overstating its needs to bring pres.
to William E. Davis, the ! quest of state officials, the company.
sure for the commercial operation of Shoreham.
E
! xecutive Commissioner of would lend a barge to Lilco in an The possible source of additional power was not the State Energy Office, six nuclear emergency.
i mentioned in April when Lilco officials announced a plants similar in design to Shoreham In its filing with the Nuclear Regu-plan of power imports, purchases and censervation to.'
.latory Commission, Lilco said it satisfy a Long Island demand that they predicted would ' prated power an average of only u percent of the time during their :would need 4,904 megawatts of power reach record levels this summer.
first three months of ccgnmercial this summer to meet projected de-But last week, Ulco offici4 said they were,in fact,, operation. "There is little assurance mand. The figure envisions a "rell-depending on additional power from Con Ed on an emer-ability reserve" of 1,100 megawatts, gency basis, and that is why Lilco did not specifically that the plant would be actually oper-equal to a 20 percent reserve margin ask Con Ed for a contract for power beyond the 250.ating when needed most," Mr. Davis to call upon in the event of a plant fail-megawatts.
said.
. ure or failure of any of the transmis-However, even with the increased imports, they The Nuclear Regulatory Commis-sion tie lir.ss that connect Lilco to said, the company wouM still need to operate Shoreham alon normally licenses nuclear plants othe.r utility power grids. Lilco can C1 O percent of full power to produce the 170 megawatts,
.to operate at 25 percent of full power generate 2,747 megawatts at its own and to assure its customers a reliable electricity supply. lto allow final testing and roonitoring power stations.
1he plant has been tested at up to 5 percent or full prior to full-power licensing. The The highest electricity demand power, but is not licensed to operate commercially.
regulatory scheme takes into acmunt, ulco faced occurred last July 7, when I
uloo is seeking a quick ruling from the Federal Nu-the need for early detection of plant ks customers used 2,441 megawatts
, deficiencies that may ha=== a prob-between 5 P.M. and 8 P.M.
clear Regulatory haa4==na=i on its lem when commercial operation be-State and suffolk officials said tion to bring the Bereham gins.
Uloo is vastly overstating its needs t to the 36 percent power level According te Lilco,the comentamaan when it says 4,884 megawatts will be week, the coensission staff -
should act before this summer to
=====ary this summer. They noted t===" Sad the propenal be consid-grant the company's application.
that the New Yorit State Power Pool, ered swtftly, while withheiding com-
"Shoreham's operation at 25 percent f an association of state utilities, re-most enits mertts-power is the only near term answer quires onlyan18 percent margin.
The ulco application also asks the to electric shortages on Long Island,"
Accareng to Ulco, without Shore.
.,comasteeton to waive a requirement me esapany arsued in ks applica-ham its maximum available supply t an approved emergency evacua-tion.
will reach 4,548 megawatts this sum-
,tien plan be in place cercre a nuclear.
However, according to Mr. Davis,' uner, or 216 megawatts short of what saay operate over the 5 percent ;
power from Shoreham "is not sesen-the company said it will need. The fig-Five percent power is anowed.
tial either in the near term or ha the ure bc)udes g50 megawatts of im-
,so t operators can test as.
longer term," and service reliability ported' power, the maximum amount precedures prior to
. le over the next two years will "not be the company sold its interconnections sommercieloperation.,,
significantly different" than in the with other ut111*Jes can accommodate.
last twa years.
James Isis, a Lilco spokesman, said the import figure also included a j
projected 200 megawatt increase m,
power from Con Ed above the 250 K ldg spegawstts now evallable.
1
NEWSPAPER
/ /e x).Y TNe <
DATE 5 /o5;7 PAGE
/
In addition to its connections with the Con Ed grid that links Jamaica with Valley Stream and Lake Suc-cess, the two utilities also jointly own a 345-kilovolt transmission line that runs from Shore Road in Sands Point beneath Long Island Sound to a Con Ed substation in Yonkers. The line can carry up to 800 megawatts of r supplied by the New York r Authority and other upstate utilities.
Under current agteements, more than half the power flows to Con Ed.
Smaller amounts also supply New York Power Authority customers,in-cluding Nassau and Soffolk municipal distribution agencies and three Long Island municipal power companies.
A separate,138-kilovolt line under IAng Is'and Sound connects North-port and Norwalk, bringing power from Connecticut and New England utilities.
But Lilco said that technical re-straints involving the operation of its.
Northport generating station, the world's largest oil-powered generst.
'ing facility, precluded full use of the GQf p h 7 connection. Representative Hoch-brueckner has called on the utility to make alterations that would increase
' imports on the line.
Lilco has warned that its depend-~
l ence on oil-poweM, aging genera-tors and its increasing need for im-
, ported power signal major difficul-ties ahead if Shoreham is not allowed to operata, a view that most New York and IAng Island officials refute.
They said that a proposed 3454110-
. volt line that would connect Long Is-land to upstate and Canadian power transported along the half-completed Ma South transmission corridor assure plentiful supplies on
'Long Island in three or four years, when both projects are expected to be completed The new line under IAng' Island Sound will bring 800 mega-Iwattsof extrapower to LongIsland.
I Until then, the official said, cur-rently available supp!!es are enough to assure there will be no serious dis-ruption in electrical service on 1Ang Island.
Suffolk officials said they would re-lease a report later this month by an, energy consultant detail alternate-ways to meet electricitydemand.
State and suffolk officials have also said they will go to Federal court to
' block operation of Shoreham at 25,
. percent levels if the Lilco application ils approved by the Nuclear Regula-
' tory Commission.
5
LILCO, May 12, 1987 DX P E !! '
- pq CERTIFICATE OF SERVICE
'87 MAY 12 P4 :06 In the Matter of
[0bb ' g+g "'"l LONG ISLAND LIGHTING COMPANY gO (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL I hereby certify that copies of LILCO's Reply to Intervenors' Opposition to Expe-dited Consideration of LILCO's 25% Power Request and attachments were served this date upon the following by hand as indicated by an asterisk (*), by Federal Express as indicated by two asterisks (**), or by first-class mail, postage prepaid.
Lando W. Zech, Jr., Chairman
- Alan S. Rosenthal, Chairman **
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board 1717 H Street, N.W.
Washington, DC 20555 U.S. Nuclear Regulatory Commission Fif th F'oor (North Tower)
Commissioner Thomas M. Roberts
- East-West Towers U.S. Nuclear Regulatory Commission 4350 East-West Highway 1717 H Street, N.W.
Bethesda, MD 20814 Washington, DC 20555 Gary J. Edles, Esq. **
Commissioner James K. Asselstine
- Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board 1717 H Street, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20555 Fif th Floor (North Tower)
East-West Towers Commissioner Frederick M. Bernthal
- 4350 East-West Highway U.S. Nuclear Regulatory Commission Bethesda, MD 20814 1717 H Street, N.W.
Washington, DC 20555 Dr. Howard A. Wilber **
Atomic Safety and Licensing Commissioner Kenneth M. Carr
- Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Fif th Floor (North Tower)
Washington, DC 20555 East-West Towers 4350 East-West Highway William C. Parler, Esq.
- Bethesda, MD 20814 General Counsel U.S. Nuclear Regulatory Commission John H. Frye, III, Chairman **
'1717 H Street, N.W.
Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission East-West Towers 4350 East-West Hwy.
Bethesda, MD 20814 Y
Dr. Oscar H. Paris **
Edwin J. Reis. Esq.
- Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board 7735 Old Georgetown Road U.S. Nuclear Regulatory Commission (to mailroom)
East-West Towers Bethesda, MD 20814 4350 East-West Hwy.
Bethesda, MD 20814 Lawrence Coe Lanpher, Esq.
- Karla J. Letsche, Esq.
Mr. Frederick J. Shon **
Kirkpatrick & Lockhart Atomic Safety and Licensing South Lobby - 9th Floor Board 1800 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20036-5891 East-West Towers, Rm. 430 4350 East-West Hwy.
Fabian G. Palomino, Esq. **
Bethesda, MD 20814 Richard J. Zahnleuter, Esq.
Special Counsel to the Governor Morton B. Margulies, Chairman **
Executive Chamber Atomic Safety and Licensing Room 229 Board State Capitol U.S. Nuclear Regulatory Commission Albany, New York 12224 East-West Towers, Rm. 407 4350 East-West Hwy.
Mary Gundrum, Esq.
Bethe.Aa, MD 20814 Assistant Attorney General 120 Broadway Dr. Jerry R. Kline **
Third Floor, Room 3-116 Atomic Safety and Licensing New York, New York 10271 Board U.S. Nuclear Regulatory Commission Spence W. Perry, Esq.
- East-West Towers, Rm. 427 William R. Cumming, Esq.
4350 East-West Hwy.
Federal Emergency Management Bethesda, MD 20814 Agency 500 C Street, S.W., Room 840 Secretary of the Commission
- Washington, DC 20472 Attention Docketing and Service Section Mr. Philip McIntire U.S. Nuclear Regulatory Commission Federal Emergency Management 1717 H Street, N.W.
Agency Washington, DC 20555 26 Federal Plaza New York, New York 10278 Atomic Safety and Licensing Appeal Board Panel Mr. Jay Dunkleberger U.S. Nuclear Regulatory Commission New York State Energy Office Washington, DC 20555 Agency Building 2 Empire State Plaza Atomic Safety and Licensing Albany, New York 12223 Board Panel U.S. Nuclear Regulatory Commission Stephen B. Latham, Esq. "
Washington, DC 20555 Twomey, Latham & Shea 33 West Second Street P.O. Box 298 Riverhead, New York 11901
_ _ Jonathan D. Feinberg, Esq.
Martin Bradley Ashare, Esq.
New York State Department of Eugene R. Kelly, Esq.
Public Service, Staff Counsel Suffolk County Attorney Three Rockefeller Plaza H. Lee Dennison Building Albany, New York 12223 Veterans Memorial Highway Hauppauge, New York 11787 Ms. Nora Bredes Executive Coordinator Dr. Monroe Schneider Shoreham Opponents' Coalition North Shore Committee 195 East Main Street P.O. Box 231 Smithtown, New York 11787 Wading River, NY 11792 Gerald C. Crotty, Esq.
Crunsel to the Governor Exe-utive Chamber State Capitol Albany, New York 12224 AC6s9t
~ Donald P. Irwin
/'
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: May 12,1987 G
e
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