ML19343A330
| ML19343A330 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 09/09/1980 |
| From: | Clay Johnson TEXAS PUBLIC INTEREST RESEARCH GROUP |
| To: | |
| Shared Package | |
| ML19343A331 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8009170225 | |
| Download: ML19343A330 (12) | |
Text
1 AFFADAVIT My name is Clarence Johnson.
I was formerly Executive Director of TexPIRG, and in that capacity I was the individual primarily responsible for the research on TexPIRG Amended Additional Contention #1 (re: natural gas generation).
I hold a B.S. and M.A.
from University of Houston.
I am presently employed by Texas Legal Services Center and the Texas Senate Natural Resources Committee in Austin, TX.
The following statement relates to the comparison of natural gas generation as an alternative to nuclear fission generation of electricity.
ENVIRONMENTAL ISSUES I. Water Use.
Fossil fuel plants such as a natural gas generation facility consume less water than a nuclear facility.
It is well recognized that nuclear plants lose something on the order of 60 % more thermal energy through discharge than do fossil fuel facilities (see " Thermal Pollution and Aquatic Life," Scientific American 1969, 220:3).
Moreover, use of cooling towers vould be very compatible with the degree of thermal discharge associated with a natural gas plant.
Based upon the water consumption per kilowatt associated with the Antelope Valley coal plant, I have estimated that a natural gas facility using cooling towers would save approximately 20,000 acre / feet of fresh water per year.
An examination of the the water consumption from Smithers Lake associated with HL&P's Parish coal and natural gas / oil units indicates a clear reduction of water consumption per kw. for natural gas using cooling lakes too.
Moreover, many of HL&P's existing natural gas facilities utilize canals connected to Galveston Bay together with cooling towers, and such an arrangement is likely to result in greater freshwater savings than either scenario described above.
So, if we're talking about extending the date of decommissioning sect present facilities that use natural gas, we're talking about very sizeable reductions in water consumption.
In my opinion, water usage may beccee a greater resource shortage problem for Texas than energy shortages in the near future.
Mr. Saxion's affadavit relating to site suitability of ACNGS clearly indicates the nature of the water consumption needs of the Texas coast.
II. Land Consumption.
Table 61 in " Impacts of Coal-Fired Plants on Fish, Wildlife, and Their 800917n f.J 6
2.
Habitats", published by the U.S. Fish & Wildlife Service, indicates a natural gas electric generating station will use approx 1=ately 220 acres for an equivalent sized plant at ACNGS. ACNGS, of course, will utilize 5,720 acres, according to the FES.
This means that a natural gas facility will save approximately 5,500 acres of land.
The FS-FES for ACNGS indicatus that savings to be prime farmland.
HL&P purchased the ACNGS land for approximately 17 million dollars, according to ts.eir Land Held for Future Use account filed at the Public Utility Commission in Docket 2676. Assuming an inflation rate of 8 %, that land is presently worth approximately $26 million.
That means that the land use savings is at least $24.9 million in market value terms.
Ill. Front End Fuel Cycle.
The extraction of the fuel to the =c=ent the fuel is burned may be thought of as the " front end" of the fuel cycle.
I believe natural gas involves subtantially less i= pact than uranium during this stage of the fuel cycle. The impacts of natural gas include:
the risk of fire and explosion during extraction; rare accidents involving the release c'f toxic gases such as hydrogen sulfide; the risk of offshore oil spill if the gas is being extracted in the same field with oil; and aesthetic impacts on land use.
The first two impacts are accidents and not routine operations.
They are both fairly rare and generally manageable. Because natural gas drilling does not normally occur in densely populated tracts, and because the accident impacts are very localized, those who are involved in the drilling operation itself are the only persons at risk.
The risk of oil spills polluting the ocean and seas pertains only to natural gas extraction which occurs offshore.
In actuality the risk occurs only to the extent that oil and gas are usually found together; and the shortages of oil probably means that those risks would exist without the existence of natural gas deposits, because the potential of oil discovery alone would justify drilling.
During the drilling phase of natural gas exploration, some persons may find the facility to be aesthetically displeasing.
But oil and gas drilling has been allowed in Aransas National Wildlife Refuge in Texas with little aesthetic i= pact, showingthatsuchi=pactscanbemitigategswherenecessary.
L.
4 2.
Drilling in sensitive wetland areas is allowed only after mitigation efforts satisfactory to the U.S. Fish and Wildlife Service and the appropriate state agencies.
I think it's fair to say that the environmental impacts of natural gas extraction are well-known with considerable certainty; and that such impacts are manageable.
The mining and milling of uranium can result in inhalation of radon gases and other radioactive materials by the workforce.
Excessive occupaticnal disease from the regular operation of uranium extraction 'has been documented (See " Respiratory Disease Mortality Among Uranium Miners," Archer, Z.E., Annals of the New York Academy of Sciences 271:280-93, 1976, and " Lung Cancer Among Uranium Miners in the U.S.," Health Physics, Archer, Z.E., 25 : 350-71, 1973).
It is well known in the past that uranium surface mining often resulted in destroying the practical useability of large tracts of land in such areas as South Texas, with many old sites left with deep pits filled w'ith toxic-con-taminated waters. The passage of federal surface mining reclamation laws, and in particular, a Texas Surface Mining Reclamation Act may subtantially improve the quality o,f land Icft from abandoned sites.
But this does not mean that the land has not been degraded.
In Texas, for example, where considerable uranium surface mining exists, the Texas Railroad Commission has very strictly defined " prime farniand" so as to require most abandoned site to be restored to a condition subtantially worse (in terms of vegetation capabilities) than it was prior to mining.
Uranium mill tailing produce radioactive health hazards to human and wildlife populations.
Both ground and surface water may become contaminated with excessive amounts of radioactive materials, placing populations at risk. Further-more, acids and other corrosives are common to solution-mining, and as such may result in further contamination of land and water. Such environmental impacts such as those described herein are documented in the following: " Ground and Surface Water in New Mexico: Are They Protected Against Uranium Mining and Milling," N&2 ural Resources Journal, Townsend, K. Oct. 19, 1978; " Unresolved:
Front End of Nuclear Waste Disposal," Bulletin of Atomic Scientists, Vol. 35, 15, May,1979; " Effects of Uranium Mining and Milling on Groundwater in Grants Mineral Belt, N.M.," Groundwater Journal, vol.14, Sept, to Oct. 1976.
I think its equally fair to say that the environmental impacts of uranium extraction are bounded by a greater degree of uncertainty than natural gas
3.
extraction.
In my opinion, the evidence and research seems to indicate that the front-end cycle of uranium fuel is marginally to subtantially worse in terms of environmental i= pacts than natural gas fuel, depending upon the effects of uranium extraction legislation on the future.
IV. Back-end of fuel cycle.
Once the fuel has been consuced by power generation, disposal of ashes may be referred to as the "back-end" of the fuel cycle.
There is presently no resolution of the spent fuel rod disposal issue.
Thus, the status of such imyacts is very uncertain. However, it's readily conceded that burial is probably the most likely longterm solution.
Such burial will entail containment for over a thousand years.
During that period, unknown numbers of populations will be at-risk from accidental "unburial" or through scepage from containment into groundwater.
Temporary storage of spent fuel on-site increases, perhaps marginal 1.y, the accidental radiation risks to workers and populations near ACNGS. Use of "Away From Reactor" storage facilities for interim containment of spent fuel, as proposed by current legislation pending in Congress, will increase the number of at-risk populations by re=oving the spent fuel from the area of the power facility.
Natural gas entails no such disposal proble=s.
V. Atmospheric releases.
Natural gas generation releases virtually zero sulfur dioxide and particulates.
Slight emissions of NO are reported, but these are manageable because as the x
USFWS notes such levels are below the threshold of biological effect. (See
" Impacts of Coal-Fired Power Plants on Fish, Wildlife and Their Habitats,"
FWS/obs-78-29, p.155 and p. 58).
Nuclear facilities release radioactive materials into the air.
Such normal radioactive releases may have little impact; but their is some uncertainty as to the precise effects of low levels of ionizing radiation.
Accidental releases of radioactive materials, such as accident classes 1-8, may release substantially more low level radiation.
Low probability, high con-sequence accidents, class 9, may involve large numbers of death and injury to rearby populations. As the NRC notes in its latest policy statement en the environmental impact consideration of class 9 accidents, there are considerable bands of uncertainty as to the precise probability of class 9 accidents.
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4.
I would conclude that the range of opinion would find natural gas electrical generation atmospheric releases to range from "similar" to "significantly less" than the impacts of releases from nuclear generating stations, depending upon ones assumptions as to the risk probabilities of low level radiation and radiological accidents.
VI. Decommissioning.
Because of radioactive residue within the nuclear reactor, the decommissioning of a nuclear facility involves significantly more environmental and social impact than other power plant terminations.
The NRC allows entombcent, dismantling, and mothbolling as the alternative methods of decommissioning. Dismantling at the end of life entails considerable occupational risk of radiation exposure and will likely be very costly.
Entombment and cothbolling places the nearby population at risk for several hundred years at least. Failure to properly care for or secure the facility during that time period could result in accidental radiation exposure to human populations. The probability of such failure is very uncertain, especially since it involves prediction of organizational stability over long lengths of ti=e.
Also of course, entombment and mothbolling continue to prevent land from being from placed back into production for several hundred years.
A natural gas facility cay be decommissioned in the same =anner as any large structure, and involves no such uncertainties as described above.
There is very little environmental impact to natural gas decommissioning.
VII.
SUMMARY
On balance, I think it's clear that natural gas generation is obviously superior to nuclear generation in terms of environmental impacts. There is considerably less impact in water consumption from natural gas, as well as much less land consumption. The uranium fuel cycle appears to be marginally to subtantially worse in the "frent end" and considerably worse in the "back end", relative to environmental impacts. Atmospheric release impacts from both for=s may be similar, with perhaps nuclear generation involving more risk. And the decommissioning of nuclear facilities involves greater en-viron= ental impacts.
ECONOMICS OF BOTH FORMS In order to find that an alternative is preferable to nuclear generation, the alternative must be economically feasible.
According to my calculations, the.present discounted value per unit of electricity is lower for natural gas generation.
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My calculation indicates a constant dollar (1985 dollars) present discounted worth of 19.7 mills /kwh for natural gas generation and 24.96 mills /kwh for nuclear generation over a 25 year lifetime.
My calculation is based upon the following assumptions:
(1) constant dollars--this is considered an appropriate and standard way of comparing two projects into the future, with an assumption of relative price differentials remaining the same. Unless there is evidence that one or the other project will involve costs greater or less than the overall 4
inflation rate, use of escalttors is unnecessary.
q (2) discount rate--A real dollar discount rate of 7 % is assumed. This discount rate excludes the effects of inflation on the interest rate.
The real return to capital for the United States has fluctuated somewhat over the past century.
However, in my judgement, seven percent is well within reason based upon such experience. The inflation rate has average about 9 % over the last decade, and an inflation rate of -that amount plus 7 % is equivalent to sn interest 1
rate of 15 or 16 %.
The prime rate exceeded 16 % this past year, even though admittedly this has probably been an extreme year. The effective discount rate for consumers who pay for the electricity (residential users) has regularly been on the order of 17 percent this decade, based upon effective interest i
rates for consumer credit.
t (3) capital costs--The initial estimate for ACNGS is assumed to be $1.6 billion (based upon being issued a construction permit in late 1982, according to l-the appendix chart in HLSP's study, Allens Creek: A Coal Alternative, Jan. 1980).
l The average rate of nuclear power plant escalation is 20 % per year, as stated in the HL&P document, South Texas Electric Generating Station Task Force Report. Conservatively, I have assumed a five year construction period with a 15 % escalation / year for four of those-years. The total cost is $2.7 billion; and with equal expenditures per year, a present discounted worth of $2.183 billion.
The capital cost of natural gas generation is set at $295/kw, based upon the HL&P W.A. Parish Unit 3 cost of $114/kw in 1974 (Turner. testimony, HL&P rate filing,-Docket 2676, Texas PUC) escalated at 10 %/ year up to 1985. With equal
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expenditures in a four year construction period, the present discounted value i
for natural gas construction is $273.5 million.
.(4) fuel costs--The uranium fuel cycle cost is estimated at 10.2 mills /kwh, based upon the Applicant's projection in the ER Supplement SH-109.
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Unit 3 recorded 10,149 BTU / net kwh last year (HL&P FERC Form 1, Dec. 31, 1979).
In the present PUC rate case pending, HL&P response to TexPIRG Request for Information #2 projects a natural gas price of $3.71 per million BTU in 1985. This calculates to a fuel cost of $292 million per year.
(5) capacity f actors--ACNGS is assumed to have an average capacity factor of 45 ".. This is justified by the capacity factors calculated for similar BWR3 in NUREG CR 0382. The natural gas facility is assumed to have a capacity factor of 75 %.
(6) Total rated capacity--the same for each.
I have just examined 2 report which appears to provide subatantiation to my calculations of lower costs for natural gas generation of electricity coc: pared to nuclear generation. Page B-21 of " Report of the Advisory Committee on Industrial and Electric Utility Fuel Use Policy," June 11, 1980, Texas Energy and Natural Resources Committee Advisory Council, indicates that the average cost of service for the Electric Reliability Council of Texas region (for which HL&P is a member) will be 16.3 mills /kwh in 1995 without the phase-out of natural gas boilers for electric generation and 27.7 mills /kwh with the phase-out, and only a slightly higher one-tenth mill higher cost in 2000 for the with natural gas boiler case.
I think these figures and calculations outlined in this section show that natural gas generation of power is economically feasible relative to. nuclear generation.
Even assuming different assumptions than those I've made, I think it's obvious that natural gas and nuclear power are not extremely different in overall costs, even in the longterm.
FEASIBILITY An environmentally preferred alternative need only be considered under NEPA if it is " reasonable" or put another way, " meets the rule of reason."
For instance, if one proposed that all anti-trust laws be repealed as a NEPA alternative, that would not generally be con-sidered as a " reasonable" alternative.
However. in this instance, the alternative of natural gas fired facilities meets this initial test of " reasonableness."
7.
Natural gas generation of power may be considered in one of two ways.
First of all, serviceable natural gas facilities presently planned to be retired early due to mandates of the Power Plant and Industrial Fuel Use Act could be extended in lifetime, allowing the Allens Creek facility (or that assigned capacity) to be delayed for ten to fifteen years.
Alternatively, a new natural gas facility could be constructed to meet that capacity requirement.
Either scenario is a reasonable alternative which could be accinplished through federal acticn altering or performing rulemai y; under the Industrial Fuel Use Act.
The usefulness c7 extending the lifetime of presently operable natural gas facili;ies can be seen when one realizes that the purpose of ACNGS is to allow retirement of natural gas facilities by 1990.
In Table S.S.14 of the Final Supplement to the FES, HL&P is shown to have forecasted demand at 13,775 MWe in 1987 with capacity of 15,560.
That capacity includes all the facilities of Table S.8.13.
That last additions shown there are Allens Creek and ", Undetermined 1 and Undetermined 2."
each of 375 MWe (scheduled for 1983 and 1984).
Those " undetermined units" were originally projected shares in the joint HL&P-Dow venture which was not consummated.
In its place, the company is constructing the Limestone Lignite Plant for a total of 1500 MWe.
As the company noted in several responses to TexTIRG fnterrogatories, this means that the aforementioned tables do not include 750 MWe of capacity which will be available.
In addition, in its latest rate filing, Docket 3320 (PUC), HL&P has stated that yet another coal facility called " Site X" is expected to be on line for another 1500 MWe capacity prior to the censtruction of Allens Creek.
Thus, Allens Creek is really no longer needed to fulfill strictly demand components of the plant system outlined in Tables S.8.14 and bec'mes clearer that Allens Creek is additional capacity S.8.1).
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scheduled before the end of the decade in order to allow HL&P to phase out natural gas plants by 1990.
Therefore, extending the useful lifetime of natural gas capacity beyond 1990 would permit subtantial delay in the scheduled capacity additions, in turn permittirr several more years of
a 8.
use of the environmentally superior gas facilities.
An examination of HL&P's FERC Form i shows that well more that 1,200 MWe capacity (equivalent to ACNGS) of natural gas generation was built recently enough to have useful forty year lives up to or past the end of the century.
The political elements of this alternative are also reasonable.
The Power Plant and Industrial Fuel Use Act clearly allows exemptions to the 1990 phase-out if D.O.E.
finds such exemption to be in the public interest.
Some exemptions are discretionary and an exemption when a replacing facility will violate federal environmental laws is mandatory.
Alternately, the statute could be amended to allow burning of natural gas in the Southwest where such fuel use is economical.
The viability of this alternative is shown by proposed legislation which har assed the U.S.
Senate permitting existing natural gas facilities to continue using natural gas past 1990 in cartain areas of the Southwest.
The reasonableness of such an action as amending the Fuel Use Act is shown by the recent recommendation of the Texas Energy and Natural Resources Advisory Council's Advisory Committee on Industrial and Electric Utility Fuel Use Policy which states:
(Congress should) " repeal or amendment of Section 301 ( a) (_l) of the Act to allow natural gas burning plants to continue to burn natural gas for the remainder of their useful lives or until and unless a scarcity of' natural gas can be demonstrated."
T.E.N.R.A.C.
is a state agency which assists in the formation of state energy policy.
As the advisory committee's report further notes continued use of natural gas plants would enable them to be available when gasified coal may become useable in the 1990's, and that some utilities are planning to modify natural gas systems to permit solar " hybrid" systems.
Finally, the Act could be amended to allow construction of new gas facilities as an alternative.
The basis for the reasonable-ness of this alternative is that a shortage of natural gas is
e 9.
no longer present, and that sufficient reserves appear to exist in this hemisphere.
The U.S.
Environmental Protection Agency has estimated that Federal Power Commission projections of natural gas production from 1979 to 1990 are underestimated by 2-3 quads simply due to passage of the Natural Gas Policy Act.
Furthermore, such natural gas facilities be capable of using gasified coal once that becomes available.
In the face of such factors now present which were n,*
as visible at the time of the passage of the Power Plant and Industrial Fuel Use Act of 1978, an alternative federa. cetion of amending the federal act to allow utilities to construct natural gas i
facilities appears reasonable.
SUMMARY
The use of natural gas fuel is a reasonable alternative to nuclear fission generation.
Natural gas generation of power is economically competitive with nuclear generation.
- Also, natural gas generation of power has been shown by the foregoing to be envirlonmentally superior to nuclear fission as represented by Allens Creek.
Therefore, I would conclude th' t natural a
gas generation of electrical power is an obviously superior alternative to the proposed Allens Creek Nuclear Generating Station.
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A STATE OF TEXAS COUtEl CF TPAVIS BEEDRE :E, the undersigned authority, on this day persorally appeared Clarence Johnsen, who being by me duly sw rn, upon oath says that he prepared the foregoing affaddvit and that the facts and opinions stated therein are true and correct to the best of his knowl and belief.
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A Clarence Johnse Subscribed and Sworn to Before Me by the said Clarence Johnson this the 9th day of Septeber,1980, to certify utlich witness nff erd and F
seal of office.
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' ABUNDANT ENERGY TH.E NATURAT; a
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I' FRED J. COOK r
L Natural gas reserves are so huge that they I'-
amount to "about ten times the energy value of all (previous] oil, gas and coal reserves in the United States combined," according to Dr. Vin-cent McElvay, director of the U.S. Geological Survey, in a speech in Boston in 1977. Dr.
McElvay was reflecting on the findings of a geo.
logical survey which concluded that zon.is of seabed along the Louisiana and Texas coasts alone beld 24,000 trillion cubic feet of gas-the f
equivalent of 4 trillion barrels of oil, roughly '
I twice the estimate of the ultimate world re-
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sources in petroleum.
According to Dr. Paul H. Jones lit 1978:
"There's good scientific evidence that this brine (in the Tuscaloosa Trend along the Louisiana-Texas coasts] could contain as much as 50,000 l
trillion cubic feet of [naturall gas. That's equal to 1,500 times our present vearly production."
Dr. Jones, a veteran geologist widely respected as the foremost authority on the area, later
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changed this estimate to 100.000 trillion cubic
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l r) feet. "From all I hear now, my 50.000 trillion I
prediction looks conservative," he said in May f
1980.
"The Greater Anadarko Basin [a broad strip stretching across lower Oklahoma and the Texas l
Panhandle] ranks right up there with the Gulf f.
s Coast for its gas resources," said Bill Dutcher,
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associate of Robert Heffner Ill, pioneer wildcat-
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ter of the Anadarko and chairman of the' American Gas Association's Independent, Gas-i j
Producers' Committee. Heffner has predicted
,,3i that deep-drilling in the Anadarko (not counting' ',,
>f a veritaole pincushion of shallow, conventic,aal i
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wells) could yield some 60 trillion to 300 trillio((
i cubic feet of gas.
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