ML12340A598
| ML12340A598 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/29/2012 |
| From: | Schlissel D Schlissel Technical Consulting, State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12181A466 | List: |
| References | |
| RAS 22868, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12340A598 (28) | |
Text
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 1
UNITED STATES 1
NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
x 4
In re:
Docket Nos. 50-247-LR; 50-286-LR 5
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6
Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7
Entergy Nuclear Indian Point 3, LLC, and 8
Entergy Nuclear Operations, Inc.
June 29, 2012 9
x 10 PRE-FILED WRITTEN REBUTTAL TESTIMONY OF 11 DAVID A. SCHLISSEL 12 REGARDING CONTENTION NYS-37 13 On behalf of the State of New York (NYS or the State),
14 the Office of the Attorney General hereby submits the following 15 testimony by David A. Schlissel regarding Contention NYS-37.
16 Q.
What is the purpose of your testimony?
17 A.
The purpose of this testimony is to respond to the 18 testimony of Entergy Witnesses Donald P. Cleary, David Harrison, 19 Jr., and Eugene T. Meehan Regarding Contention NYS-37 (Energy 20 Alternatives).
21 Q.
What documents did you review in preparation for your 22 rebuttal testimony?
23 United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of:
Entergy Nuclear Operations, Inc.
(Indian Point Nuclear Generating Units 2 and 3)
ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #:
Identified:
Admitted:
Withdrawn:
Rejected:
Stricken:
Other:
NYS000437-00-BD01 10/15/2012 10/15/2012 NYS000437 Submitted: June 29, 2012
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 2
A.
I read Entergy's Statement of Position concerning 1
Contention NYS-37; the testimony of Entergy witnesses Donald P.
2 Cleary, David Harrison, Jr., and Eugene T. Meehan concerning 3
NYS-37 and exhibits thereto ("Entergy Testimony") and the report 4
prepared for Entergy by NERA Economic Consultants.
I have also 5
read NRC Staff's Statement of Position concerning Contention 6
NYS-37 and the testimony of NRC witness Andrew L. Stuyvenberg 7
and exhibits thereto("Staff Testimony").
8 Q.
What are your conclusions?
9 A.
My conclusions are as follows:
10 1.
Entergys witnesses on Contention NYS-37 (Energy 11 Alternatives) inappropriately used the widely 12 respected National Energy Modeling System 13
("NEMS") to model the No Action Alternative. NEMS 14 is traditionally used to model the effect of 15 proposed policy changes or alternatives. I have 16 never seen it used, as Entergys witnesses use it 17 here, to model the retirement of one or two 18 specific generating units.
19 2.
There are other production simulation models that 20 are traditionally used in the industry to 21 evaluate the economic and environmental impacts 22 of power plant retirements and the addition of 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 3
new generating capacity, energy efficiency and 1
renewable resources. For example, Entergys 2003 2
assessment of the potential economic and 3
environmental impacts of an Indian Point Energy 4
Center (IPEC) retirement used the GE MAPS 5
model.
6 3.
Entergy has not modeled a credible No Action 7
Alternative.
It assumes that there would be no 8
market or state response to replace the lost 9
generation from IPEC until 2026 other than 10 through the continued operation of old, dirty and 11 inefficient coal and oil/gas steam units that 12 would otherwise be retired by 2015.
13 4.
The results of Entergys NEMS modeling of the No 14 Action Alternative do not provide credible 15 evidence that there would only be a small role 16 for additional energy efficiency and conservation 17 under the No Action Alternative.
18 A.
Neither the NEMS Baseline analysis nor 19 Entergys No Action Alternative modeled New 20 York States current 15 x 15 energy 21 efficiency plan.
22 B.
NEMS does not model energy efficiency as an 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 4
additional resource. Instead, the only way 1
in NEMS to model additional energy 2
efficiency is to reduce the energy forecast 3
- something that Entergys witnesses did not 4
do either in the Baseline Analysis or the 5
No-Action Alternative.
For this reason, it 6
is not possible for NEMS to directly compare 7
the cost of continuing to operate Indian 8
Point against the cost of achieving more 9
energy efficiency. In fact, the NEMS model 10 could not add additional energy efficiency 11 even if it is the lower cost resource.
12 5.
The results of Entergys NEMS modeling also do 13 not provide credible evidence that additional 14 renewable resources would not play a significant 15 role as replacement energy in a No Action 16 Alternative.
In particular, Entergy did not 17 consider the potential for a proposed 18 transmission line to bring additional low cost 19 renewable resources into downstate New York from 20 Canada or that the cost of renewable resources 21 might decrease as a result of economies of scale.
22 6.
Entergy unreasonably assumes in its No Action 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 5
Alternative that the following substantial 1
amounts of older, dirtier and less efficient coal 2
and oil and gas steam capacity would continue to 3
operate long past 2015:
4
323 MW of coal capacity in Upstate New York 5
that would otherwise be retired in 2015 or 6
2017 7
8
822 MW of oil and gas steam capacity in 9
Upstate New York that would otherwise be 10 retired in 2018 11 12
25 MW of combustion turbine capacity on Long 13 Island that would otherwise be retired in 14 2015 15 16
85 MW of coal capacity in New England that 17 would otherwise be retired in 2016 18 19
960 MW of oil and natural gas steam capacity 20 in New England that would otherwise be 21 retired in 2015 or 2016 22 23 7.
Entergys witnesses misleadingly understate the 24 marginal cost of generating electricity at 25 existing coal and oil and natural gas steam 26 generating units.
27 8.
In Entergys modeling of the No Action 28 Alternative:
29 A.
No clean and efficient replacement capacity 30 is added in New York State (let alone 31
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 6
downstate New York City/Westchester County) 1 until 2026 and then only a relatively small 2
amount (300 MW in total) is added in the 3
years 2026 through 2040.
4 B.
In Entergy's modeling of the No Action 5
Alternative most of the replacement power 6
for Indian Point is built in New England and 7
not New York State. However, no clean and 8
efficient replacement capacity would be 9
added in New England before 2025 and then 10 only a relatively small amount (110 MW) 11 would be added until 2030.
12 9.
It is more reasonable to expect that the likely 13 market response would be to add some replacement 14 generating capacity before 2026 if IPEC is not 15 relicensed.
16 10.
New York State is currently taking a number of 17 actions to ensure that there would be new 18 generating capacity in downstate New York if IPEC 19 is not relicensed or that there would be 20 additional transmission capability to import new 21 generating capacity (both clean and efficient gas 22 and renewable) into the downstate region. These 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 7
actions include the development of a New York 1
Energy Highway.
2 11.
Well over 2,000 MW of clean and efficient new 3
natural gas-fired combined cycle capacity is 4
being proposed for construction in or near New 5
York City and Westchester County.
6 12.
The NEMS modeling of the Baseline Analysis and 7
the No Action Alternative does not reflect either 8
the New York Energy Highway or the over 2,000 MW 9
of clean and efficient generating capacity being 10 proposed for construction in or near New York 11 City and Westchester County.
12 13.
Entergys witnesses misleadingly overstate the 13 environmental impacts of the No Action 14 Alternative by understating the potential for (a) 15 substantial energy efficiency, (b) renewable 16 energy and (c) clean and efficient generating 17 capacity as alternatives if IPEC is not 18 relicensed.
19 Q.
Entergys witnesses have testified that they have 20 developed two related empirical evaluations to identify the 21 environmental impacts of the generation that would likely 22 replace Indian Point Energy Center (IPEC) under the No Action 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 8
Alternative.1 Do you agree that they have presented the results 1
of two empirical evaluations?
2 A.
No.
They present only a single empirical evaluation -
3 based on their NEMS modeling - (and that is seriously flawed as 4
I will explain). The remainder of the Entergy witnesses 5
testimony on Contention NYS-37 consists of hypothesis and 6
conjecture.
7 Q.
Entergy's witnesses testify that the results of their 8
NEMS modeling show that under the No Action Alternative (1) 9 existing IPEC generation would be replaced primarily by fossil-10 fueled generation from existing natural gas and coal facilities 11 and (2) conservation and renewables would be unlikely to play 12 significant roles in replacing lost generation from IPEC.
Do 13 the results of the NEMS modeling support these claims?
14 A.
No. The NEMS results presented by Entergys witnesses 15 are misleading and flawed for several reasons. First, NEMS is 16 not the appropriate model to use to determine the economic and 17 environmental impacts of the No Action Alternative.
- Second, 18 NEMS does not accurately or fully model New Yorks 15 x 15 19 energy efficiency plan or the potential for additional energy 20 1
Testimony of Entergy Witnesses Donald P. Cleary, David Harrison, Jr., and Eugene T. Meehan Regarding Contention NYS-37 (Energy Alternatives), ENT000479 ("Entergy Testimony") at Answer A49 on page 34.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 9
efficiency above that included in the 15 x 15 plan.
- Third, 1
the assumption that if Indian Point Units 2 and 3 were retired 2
in 2013 and 2015, respectively, replacement capacity would not 3
be added in downstate New York until sometime in 2026 is 4
completely unrealistic in that it ignores (a) the current plans 5
being developed by New York State to add clean and efficient new 6
natural gas-fired generating capacity in the New York 7
City/Westchester region of the state and (b) the economic 8
incentives that the retirement of IPEC would create for 9
developers of new generating projects in the New York 10 City/Westchester region.
11 Q.
Have you ever seen NEMS used to measure the economic 12 and environmental impacts of retiring one or two generating 13 units, as Entergy's witnesses use it here?
14 A.
No.
I have seen NEMS used (a) to evaluate the impact 15 of new or revised national or regional policies or (b) to 16 provide inputs (such as projected future natural gas and coal 17 prices) that have been used in plant retirement studies.
18 However, I have not seen NEMS used to evaluate the potential 19 economic and environmental impacts of retiring one or two 20 specific generating units such as Indian Point Units 2 and 3.
21 Q.
In your experience is the NEMS model the appropriate 22 model to use to evaluate the economic and environmental impacts 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 10 of retiring Indian Point Units 2 and 3?
1 A.
No. As Entergys witnesses have explained, NEMS is 2
used by the Energy Information Administration to perform policy 3
analyses in response to requests from Congress, the White House, 4
the Department of Energy, and other federal agencies.2 The firm, 5
NERA Economic Consulting, for which Entergy witnesses David 6
Harrison and Eugene Meehan work, and other analysts, also have 7
used NEMS to model potential policy changes in other contexts.3 8
Q.
Why is NEMS an inappropriate model to use to evaluate 9
the economic and environmental impacts of retiring IPEC?
10 A.
Although NEMS is a widely used model for policy 11 analysis because it seeks to replicate the entire U.S. and even 12 portions of Canada, it offers only very simplified descriptions 13 of the electric grid and the electric dispatch process in any 14 one state (New York State included). For example, generating 15 units are dispatched in NEMS for only 9 demand points or 16 segments in the year instead of all 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br />. Thus, the model 17 does not provide a detailed or accurate picture of the dispatch 18 of generating units in the state. The same is true for the rest 19 of the United States. For this reason, the results of the NEMS 20 analyses presented by Entergys witnesses may be gross 21 2
Entergy Testimony, Answer A88 at page 72.
3 Id.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 11 distortions of what would actually happen if IPEC is not 1
relicensed.
2 In addition, NEMS divides the New York State electric grid 3
into only 3 zones with just a single transmission link modeled 4
between each zone. By way of contrast, NYISO divides New York 5
into 11 zones (A through K) with different transmission 6
interchange limits between the zones.
7 Q.
Are there other electric system models that Entergy 8
could and should have used to better evaluate the economic and 9
environmental impacts of the No Action Alternative?
10 A.
Yes.
There are a number of electric system models 11 that are routinely used for capacity expansion planning analyses 12 or for examining the economic and environmental impacts of 13 retiring existing generating facilities. These models include 14 GE-MAPS, Strategist, Market Analytics, and PROMOD.
These models 15 provide more detailed replications of the existing electric 16 grids and the economic dispatch of existing generating 17 facilities than does NEMS.
18 Q.
Has Entergy previously used any of these models to 19 evaluate the economic and environmental impacts of retiring 20 Indian Point Units 2 and 3?
21 A.
Yes.
As noted by Entergy witnesses Harrison and 22 Meehan, Entergy used the GE MAPs model in a 2002-2003 assessment 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 12 of the potential economic and environmental impacts of an IPEC 1
shutdown.4 2
Q.
What is your opinion of the No Action Alternative that 3
Entergy has modeled with NEMS?
4 A.
The No Action Alternative that Entergy has modeled is 5
not credible in any way. It assumes that there would be no 6
market or state response to replace any of the lost generation 7
from IPEC until 2026 other than through the continued operation 8
of old, dirty and inefficient coal and oil/gas steam units that 9
would otherwise have been retired by 2015.
10 For this reason, Entergy does not model a reasonable No 11 Action Alternative.
Instead, it models what clearly is a worst 12 case alternative in which (a) there is very little or no new 13 energy efficiency, (b) little new renewable energy and (3) no 14 efficient and clean new capacity is added until 2026 or later.
15 Instead, Entergy models a No Action future in which old, dirty 16 and inefficient coal and oil/gas units that would be retired in 17 or around 2015 are operated as baseload facilities for an 18 additional 20 years.
This is simply not a credible future.
19 Q.
What have you reviewed to reach your conclusions about 20 the reasonableness of the results of Entergy's NEMS modeling of 21 the Baseline analysis and the No Action Alternative?
22 4
Entergy Testimony, Answer A12 at page 9.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 13 A.
I reviewed an Excel file provided by Entergy entitled 1
"NERA_Full NEMS Output Including Unused Tables." Entergy 2
represents that this Excel file contains the full NEMS output, 3
including all the output tables that NERA used in its analysis 4
and the output tables that NERA deemed irrelevant and did not 5
use in its analysis.5 6
Q.
What is your opinion of the results of Entergys NEMS 7
modeling that purport to show there would only be a small role 8
for additional energy efficiency and conservation under the No 9
Action Alternative?6 10 A.
These results are not credible. First, contrary to 11 what Entergys witnesses imply, NEMS does not model (nor does it 12 have an easy way to model) New York States current 15 x 15 13 energy efficiency goal. Consequently, Entergys witnesses have 14 not shown that all of the low cost energy efficiency that will 15 be achieved under the 15 x 15 plan already is included in 16 their Baseline analysis and, in fact, there may be a 17 significant amount of additional low cost energy efficiency 18 available to replace IPEC beyond that reflected in that Baseline 19 analysis.
20 At the same time, the NEMS model does not treat energy 21 5
Exh. NYS000438 6
Entergy Testimony, Answer A85 at page 71.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 14 efficiency as an additional resource - that is, the only way to 1
model additional energy efficiency in NEMS is as a reduction to 2
the energy forecast. For this reason, it is not possible in 3
NEMS to directly compare the cost of continuing to operate 4
Indian Point against the cost of adding more energy efficiency.
5 As a result, as Entergy has run it, (that is, without reducing 6
the energy forecast for New York State to reflect either the 15 7
x 15 goal or the availability of other low cost energy 8
efficiency) the NEMS model could not add additional energy 9
efficiency even if it is the lower cost resource. Instead, the 10 model is limited to reflecting only a very limited amount of 11 price induced conservation.
12 Q.
After reviewing the testimony and report filed by 13 Entergys witnesses on Contention NYS-37, is it still your 14 opinion that energy efficiency could play a significant role as 15 replacement energy in a No Action Alternative?
16 A.
Yes.
It is not a surprise that Entergys modeling 17 results do not show a major role for additional energy 18 efficiency in the No Action Alternative because (1) NEMS does 19 not model the New York State 15 x 15 energy efficiency goal 20 and (2) it is not possible to add any other low cost energy 21 efficiency in NEMS except by reducing the energy forecast which 22 Entergys witnesses have not done. For these reasons, I 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 15 continue to believe that energy efficiency could play a 1
significant role as replacement energy in a No Action 2
Alternative.
3 Q.
What is your opinion of the results of Entergys NEMS 4
modeling that purport to show that additional renewable 5
resources would not play a significant role as replacement 6
energy in a No Action Alternative?
7 A.
These results are not credible.
Entergys 8
hypothetical analysis that purports to show that any additional 9
renewable resources beyond those considered in the States 30 x 10 15 plan would be more expensive is incomplete and misleading.7 11 First, the NEMS output information provided by Entergys 12 witnesses does not show conclusively that the amount of 13 renewable energy in either the Baseline Analysis or the No 14 Action Alternative actually meets the New York State 30 x 15 15 goal.
16 At the same time, Entergys modeling of the No Action 17 Alternative ignores the possibility that there will be 18 additional low cost renewable energy above that included in the 19 30 x 15 goal. For example, Entergys NEMS modeling ignores 20 the very possibility that its own witnesses cite, that is, that 21 7
For example, see the discussion in Entergy's Testimony, answer A68 on pages 53 and 54.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 16 the completion of transmission system upgrades could unlock the 1
capability of bringing large amounts of low cost hydro generated 2
power from Canada into downstate New York.8 Entergy also ignores 3
the very real possibility that the cost of renewable resources 4
will decrease over time, in part as the result of economies of 5
scale.
Instead, all Entergys witnesses provide are some 6
theoretical graphs that are not empirically tied to actual costs 7
and circumstances in New York State.
8 Q.
Will the new hydro generation capacity and energy from 9
Quebec that Entergys witnesses discuss be available whether or 10 not IPEC is relicensed?
11 A.
Not necessarily. Entergy provides absolutely no 12 evidence that this additional hydro generation from Canada is 13 included as a resource either in the states 30 x 15 renewable 14 portfolio plan or in Entergys NEMS Baseline analysis. Nor do 15 they present any evidence that the delivered price of the 16 additional hydro generated power from Quebec would be more 17 expensive than any of the renewable energy that is included in 18 30 x 15 plan or the NEMS modeling. Instead, Entergy presents 19 only analytic conjecture and theoretical graphs with no 20 empirical links to New York State.
21 Q.
What units does Entergy assume would not be retired if 22 8
See Entergy Testimony, Answer A124 on page 98.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 17 IPEC were not relicensed?
1 A.
Entergy assumes that the following older, dirtier, and 2
less efficient coal and oil/gas steam capacity that would be 3
retired in the Baseline analysis would not be retired in the No 4
Action Alternative:
5
323 MW of coal capacity in Upstate New York that would 6
otherwise be retired in 2015 or 2017 7
8
822 MW of oil and gas steam capacity in Upstate New 9
York that would otherwise be retired in 2018 10 11
85 MW of coal capacity in New England that would 12 otherwise be retired in 2016 13 14
960 MW of oil and natural gas steam capacity in New 15 England that would otherwise be retired in 2015 or 16 20169 17 Q.
Is there any evidence that the merchant companies that 18 own this capacity will want to keep their plants operating in 19 future years whether or not IPEC is relicensed?
20 A.
No.
In fact, coal units in both New York State and 21 New England have reduced their generation or have been shut down 22 as a result of competition from extremely low natural gas 23 prices.
24 Q.
Based on their NEMS modeling, Entergys witnesses 25 claim that the marginal costs of generation at existing coal and 26 oil and natural gas steam generating units are lower than the 27 9
Exh.NYS000438
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 18 costs of either (1) generating power at new natural gas fired 1
combined cycle units, (2) additional conservation beyond that 2
included in the states 15 x 15 energy efficiency plan or (3) 3 additional renewable energy beyond that included in the states 4
30 x 15 plan.
From this, they argue that new, clean gas-fired 5
generation, additional conservation or additional renewable 6
energy will be more expensive and therefore less competitive in 7
New York's deregulated electricity market. Do you agree?
8 A.
No. Entergys witnesses present a very misleading 9
comparison in Table 1 on page 58 of their testimony that 10 purports to show the marginal costs of generation technologies 11 that are generally capable of increasing utilization," which 12 are all fossil fuel power plants and do not include wind, solar, 13 or hydro facilities. The listed marginal costs are too low 14 because Entergy uses the heat rates of efficient new coal and 15 gas fired combined cycle and combustion turbine units to 16 calculate the marginal costs of the existing coal and natural 17 gas steam units that NERA assumes will run more if IPEC is not 18 relicensed. However, these existing units generally are less 19 efficient than new natural gas combined cycle units and the heat 20 rates of these older, less efficient units are more probably 21 above (perhaps significantly above) 10,000 btu/kwh than in the 22 7-8,000 btu/kwh range assumed by Entergy in the derivation of 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 19 the marginal costs in Table 1.
Therefore, the marginal costs of 1
existing fossil fuel units are higher per megawatt hour than the 2
figures shown in the table and they would be less competitive 3
than Entergy asserts.
4 Q.
When would new generation capacity be added under Entergys 5
No Action Alternative?
6 A.
Figures 1 and 2, below (taken from the outputs for 7
Entergys NEMS modeling) show the cumulative megawatts of 8
capacity added in New York State and New England under Entergys 9
Baseline analysis (Figure 1) and the No Action Alternative 10 (Figure 2).
Figure 3 then shows how much capacity is added 11 under the No Action Alternative above that which would be added 12 in the Baseline analysis.
This represents the capacity added as 13 a result of the retirement of Indian Point Units 2 and 3.
14
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 20 Figure 1: Cumulative Capacity Additions After 2012 in New York 1
State and New England in Entergys Baseline Analysis 2
0 500 1000 1500 2000 2500 3000 3500 4000 4500 5000 Megawatts NYC/Westchester Long Island Upstate New York New England 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 21 Figure 2: Cumulative Capacity Additions After 2012 in Entergys 1
No Action Alternative 2
0 500 1000 1500 2000 2500 3000 3500 4000 4500 5000 Megawatts NYC/Westchester Long Island Upstate New York New England 3
4 5
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 22 Figure 3: Cumulative Megawatts of Replacement Capacity Added in 1
NEMS No Action Alternative above That Added in Baseline Analysis 2
-200 300 800 1300 1800 Megawatts New York State New England 3
Q.
What do Figures 1, 2 and 3 reveal about the results of 4
Entergys NEMS modeling of the No Action Alternative?
5 A.
In Entergys NEMS modeling of the No Action 6
Alternative:
7
No clean and efficient replacement capacity is added 8
in New York State (let alone New York City and/or 9
Westchester) until 2026 and only a relatively small 10 amount (300 MW in total) is added in the years 2026 11 through 2040.
12
No clean and efficient replacement generating capacity 13 would be added in New England until 2025 and then only 14
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 23 a relative small amount (110 MW) of new capacity would 1
be added between 2025 and 2030.10 2
Although this result is not reflected in Figure 4, remarkably, 3
the results of Entergys NEMS modeling projects that more new 4
generating capacity would be built in Upstate New York in the 5
Baseline analysis than under the No Action Alternative.
6 Q.
Is it reasonable to expect that any significant 7
portion of the replacement capacity that would be added if IPEC 8
is retired would be built in New England?
9 A.
No.
It is more reasonable to expect that replacement 10 generating capacity would either be built (1) in the downstate 11 New York region or (2) in Upstate New York rather than in 12 unspecified locations in New England.
13 Q.
What do you believe would be the likely market 14 response to the retirement of Indian Point Units 2 and 3?
15 A.
It is reasonable to expect that current or new market 16 participants would seek to add new capacity in New York City or 17 Westchester County close to the downstate loads. Given the 18 current and projected low costs of natural gas, and the 19 financial risks faced by new coal plants, I believe that the new 20 generating capacity that would be added would be clean and 21 efficient natural gas combined cycle units. Indeed, new 22 10 Exh.NYS000438
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 24 efficient natural gas combined cycle units have been added in 1
New York City within the past decade and other proposed combined 2
cycle units were licensed by the state to be built in downstate 3
New York but were unable to obtain needed financing. It is 4
reasonable to expect that IPECs retirement would facilitate the 5
licensing of new replacement generation projects.
6 Q.
What actions is the State of New York currently taking 7
to ensure that there would be new clean and efficient natural 8
gas-fired or renewable generating capacity added in downstate 9
New York or that there would be additional transmission 10 capability to import new generating capacity into the downstate 11 region?
12 A.
The State has taken a number of actions that can be 13 expected to lead to efficient and clean new generation being 14 built in or imported into downstate New York. First, the Power 15 New York Act of 2011 established a process for the siting of 16 electric generating facilities and repowering projects. Second, 17 the State has started the process for developing an Energy 18 Highway plan that will include (1) building new transmission 19 lines or rebuilding and upgrading existing ones; (2) repowering 20 aging power plants to increase their efficiency and making them 21 more environmentally friendly and (3) building new plants 22 including those powered by natural gas and by wind and other 23
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 25 renewable fuels.11 The State has explained that:
1 While taking action to reduce demand through the 2
States on-going energy efficiency initiatives 3
remains critical to the current and future 4
sustainable energy system, this initiative 5
focuses on supply-side and infrastructure 6
projects that generate and transmit energy.12 7
8 The specific objectives of the Energy Highway are to:
9
Reduce constraints on the flow of electricity into, 10 and within, the downstate area; and expand the 11 diversity of power generation sources supplying 12 downstate 13
Assure that long-term reliability of the electric 14 system is maintained in the face of major system 15 uncertainties 16
Encourage development of utility-scale renewable 17 generation resources throughout the state 18
Increase the efficiency of power generation, 19 particularly in densely populated urban areas.13 20 The current schedule calls for the States Energy Highway Task 21 Force to develop an action plan sometime in the summer of 2012.
22 Q.
Are clean and efficient new generation facilities 23 being proposed for in or near downstate New York?
24 A.
Yes. A number of new projects representing well over 25 2,000 MW of clean and efficient generating capacity have been 26 proposed for completion in and near New York City in the years 27 11 New York Energy Highway Request for Information, at page 4, www.nyenergyhighway.com/Content/pdf/EH_RFI/Brochure_2012.pd f
12 Id.
13 Id. at page 11.
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 26 2014-2017:
1
NRCs Berrians GT I, II and III project involving the 2
addition of 580 MW of natural gas-fired capacity in 3
New York City 4
The CPV Valley Energy Center in Orange County 5
involving 650 MW of natural gas -fired combined cycle 6
capacity 7
US Power Gens Luyster Creek Energy Project in New 8
York City involving 400 MW of natural gas-fired 9
combined cycle capacity 10
The Cricket Valley Energy Center located east of 11 Poughkeepsie, New York which would add 1000 MW of new 12 natural gas-fired combined cycle capacity.
13 Q.
Does Entergys NEMS Baseline or No Action Alternatives 14 include the New York Energy Highway or any of these proposed 15 facilities?
16 A.
No.
17 Q.
You testified earlier that in Entergys No Action 18 Alternative, clean new replacement generating capacity would not 19 be added in the New York City/Westchester region until 2026 and 20 in New England until 2025. Does the discussion of the 21 environmental impacts of the No Action Alternative by Entergys 22 witnesses address the impact of adding this clean new 23 replacement capacity?
24 A.
Not surprisingly, Entergys witnesses discuss only the 25 environmental impacts of not relicensing IPEC in the years 2016-26
Pre-filed Rebuttal Testimony of David Schlissel Contention NYS-37 27 2025.14 This is significant because under Entergys No Action 1
Alternative only a very small amount of clean and efficient 2
replacement capacity would be added in New York State during 3
this period and a mere 46 MW of clean and efficient replacement 4
capacity would be added in New England. Entergy also adds only 5
a little bit more energy conservation and barely any additional 6
renewable energy. Instead, Entergy assumes that the great bulk 7
of the replacement energy would come from the continued 8
operation of existing inefficient and dirty coal and oil/gas 9
steam units.15 Consequently, it is no wonder that Entergy 10 concludes that there would be significant environmental impacts 11 as it has excluded all clean sources of replacement energy.
12 Q.
Does this complete your testimony?
13 A.
Yes.
14 I have reviewed all the exhibits referenced herein. True 15 and accurate copies are attached.
16 17 14 For example, see Entergy Testimony, Table 8 on page 80.
15 As shown in Entergy Testimony, Table 7 on page 78, 43.1% of the replacement energy would come from coal and 55.9% from existing gas and oil units.
28 1
UNITED STATES 2
NUCLEAR REGULATORY COMMISSION 3
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4
----x 5
Docket Nos. 50 -24 7-LRi 50 -2 86-LR In r e:
License Renewal Application Submitted by 6
AS LBP No. 07 - 858 LR-BDOl Entergy Nuclear Indi an Poi nt 2, LLC,
8 Ente r gy Nuclea r Indian Point 3, LLC, and Ente r gy Nuclea r Ope r ations, Inc.
10
x 11 DECLARATION OF David A. Schlissel 12 I, David Schlissel, do hereby declare under penalty of 1 3 perjury that my statements in the foregoing testimony and my 14 statement of professional qualifications are true and correct to 15 the best of my knowledge and belief.
1 6 17 18 1 9 20 21 22 23 2 4 Executed in Accord with 10 C.F.R. § 2.304(d)
~~]tJ. f~
7 David A. Schlissel 45 Horace Road Belmont, MA 02478 Davi d@Schl issel-Techni cal. com 617 - 489-4 840 June 29, 2012 Pre - fil ed Reb uttal Testimony of Davi d Schli s sel Contention NYS-37