ML11348A134
| ML11348A134 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/27/2009 |
| From: | Schlissel D Schlissel Technical Consulting |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML11348A126 | List:
|
| References | |
| RAS 21536, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML11348A134 (3) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD x
In re:
Docket Nos. 50-247-LR, 50-286-LR License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BDD1 Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and DPR-26, DPR-64 Entergy Nuclear Operations, Inc.
DECLARATION OF DAVID A. SCHLISSEL David Schlissel, hereby declares under penalty of perjury that the following is true and correct:
- 1.
I am a senior consultant at Synapse Energy Econiomics, Inc.,(Synapse),
an energy and economic consulting firm located in Cambridge, Massachusetts.
- 2.
Synapse has been retained by the New York State Office of the Attorney General to provide expert services to the State of New York concerning the proposed relicensing of the two operating reactors located at the Indian Point Nuclear Power Station in the Village of Buchanan in Westchester County (Indian Point Unit 2and Indian Poiht' Unit 3). I have previously provided.a copy of my CV to the Board as part of my November 2007 submission.
- 3.
As noted in the State of New York's supplemental contention concerning energy alternatives, the State has taken aggressive actions to Declaration of David A. Schlissel NYS000053 Submitted: December 14, 2011
implement its "15x15" plan to reduce electricity usage by 15 percent by 2015. For example, the New York State Public Service Commission issued an "Order.
Establishing Energy Efficiency Portfolio Standard and Appraising Programs" on June 23, 2008 and an "Order Approving "Fast Track" Utility-Administered Electric Energy Efficiency Programs with Modifications" on January 16, 2009.
- 4.
In addition, as noted in the State's supplemental contention, the federal government recently has taken significant steps to foster greater energy efficiency, energy, conservation, and renewable energy.
- 5.
This Board' may take judicial notice of the fact that the United States, including New York State, is experiencing a recession. This recession can be expected to lead to lower electricity sales and peak loads for at least this year and, perhaps, even longer. Therefore, the~time frame within which the alternatives (e.g.,
conservation, efficiency, renewables, transmission / interconnection enhancements, re-powering) would need to be implemented under the "no-action" alternative would be extended. These reduced energy sales and peak loads will delay and defer the need for the energy and capacity ýom-I-ndia-n-Point Units 2 and 3 if the operating licenses were not renewed.
- 6.
Con Edison's sales of electricity were essentially flat between 2007 and 2008, growing at only 0.1 percent for the entire year. Con Edison's sales of electricity during the Fourth Quarter of 2008 were 2.6 percent below its sales during the same three month period in 2007.
Declaration of David A. Schlissel K
- 7.
The sales of the Long Island Power Authority during 2009 are expected to be the same as its projected 2008 sales and as its actual 2007 sales.
- 8.
I have reviewed the December 22, 2008 Draft Supplemental Environmental Impact Statement prepared by the NRC in this proceeding. The DSEIS ignores much of the information and analysis contained in my November 2007 Report. In addition, the alternatives analysis contained in Chapter 8 of the DSEIS significantly underestimates the impact of energy efficiency, energy conservation, renewable energy, facility re-powering, and transmission /
interconnection enhancements in New York State and in Zones H, I, J, and K. In addition, the DSEIS's analysis of the combination of alternatives, see DSEIS at 8-65 to 8-66, fails to take into account other combinations of energy alternatives that are conservative and readily achievable under existing and identified New York State programs. I have identified two additional sets of combinations of energy alternatives andthese additional combinations are set forth in the State's supplemental contention (at ¶ 21).
- 9.
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.
Dated:
February 27, 2009 Cambridge, Massachusetts David Schlissel Declaration ofDavidA. Schlissel