ML20028A049

Response to 820526 Interrogatories & Document Requests Re Question 6.Interrogatories Received on 821015

ML20028A049
Person / Time
Site:	Indian Point
Issue date:	11/03/1982
From:	Corren D GREATER NEW YORK COUNCIL ON ENERGY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-SP, NUDOCS 8211160320
Download: ML20028A049 (8)

Text

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00tgTED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -

BEFORETHEATOMICSAFETYANDLICENbG O D

'F G phtY In the Matter ~of ) C'i I ;, g cq

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CONSOLIDATED EDISON COMPANY ) Docke t Nos . 50-247-S P OF NEW YHORK (Indian Point, Unit 2) ) 50-286-SP

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POWER AUTHORITY OF THE STATE OF )

NEW YORK (Indian Point, Unit 3) November 3, 1982

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RESPONSE OF GNYCE TO NRC STAFF INTERROGATORIES AND DOCUMENT REQUESTS REGARDING QUESTION 6 GNYCE herein responds to NRC Staff interrogatories, dateu May 26, 1982, which were received by GNYCE on October 15, 1982, an earlier mailing apparently having been lost in the mails. GNYCE has already supplied one document, The Potential for Cogeneration in New York City, in response to an informal discovery request by NRC Staff Counsel, Henry McGurren, in the spring.

Interrogatory 1 .

l Identify all documentary or other material that you intend to use during this proceeding to support Contention 6.3 and that you may offer as exhibits on these contentions or refer to during your cross-examination of witnesses presented by Consolidated Edison Company of New York, Inc.,

Power Authority of The State of New York, or the NRC Staff. i

Response

GNYCE will use a report currently being prepared by Energy Systems Research Group, Inc. (ESRG) on the economic impact of an early shutdown of the Indian Point plants, and tes timony prepared by I'an Anderson on the economics of accepting the liability of operating the Indian voint plants.

C211160320 821103 PDR ADOCK 05000247 O PDR

Intbrrogatory 2 l a) Upon what person or persons do you rely

• to substantiate in whole ~

or in part your case on Contention 6.37 b) Provide the address and education and professional

• k qualifications of any persons named in your response to 2a; above.,

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i c) Identify" which of the above persons or any other persons you may  !

call as witnesses on Contention 6.3e

Response

a):

GNYCE will rely on various members of ESRG and Dan R. Anderson.

b):

The address of ESRG is 120 Milk St., Boston, Mass. 02109. The '

address of Dan R. Anderson is, School of Business, University of Wisconsin, Madison, Wisconsin 53706.

Professional qualifications of these individuals are as follows.

The list of ESRG members is tentative.

Energy Systems Research Group's Senior Research Staff I

STEPHEN S. BERNOW PAUL D. RASKIN (Ph.D., Columbia University; (Ph.D., Columbia University;  ;

Experimental Physics) Theoretical Physics) ;

An energy systems analyst, Bernow has extensive '. Raskin is the President of Energy Systems Research .

experience in modelling district heating, cogeneration i Group. He has taken lead responsibility fordeveloping i

l and other energy supply technologies, electric utility j ESRG's Electric Demand Forecasting Model, and has I operations and plinning, and energy dernand-supply i directed studies in the areas of industrial energy con-interactio'ns. Educated as an electrical engineer and i servation, and energy policies and programs. Prior to l t

physicist, Bernow served on the faculties of Rutgers  ! ioining ESRG, Raskin taught at the City University of  !

l University and the State University of New York at New York and at the State University of New York at .

Albany before joining ESRG. He has published in the Albany (where he was faculty chairman of an inter- l areas of nuclear physics and the social dimensions of  ; discipImary program) He has written on the social ,

science and technology. Bernow is Vice-President of  ; dimensions of science as well as on problems in theo.

EsRG. retical physics.

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RICHARD A. ROSEN ESRG Staff Associates (Ph.D., Columbia University '

Theoretical Physics) ,

T Rosen has specialized in industrial process energy use i b 0. (v.HOMAS D. AUSTIN

.S., Clark University;

! Economics) and in modelling electric utility production costing and generation expansion programs. He has also ^ 3Pecialist in electricity supply modelling. Austin has studied such related areas as cogeneration and indus-l assisted in the development and application of ESRC's trial energy conservation and has developed ESRC's Electric Systems Ceneration Expansion Model. He has Demand Curtailment Model. Before joining Energy ' .been engaged in the development of production Systems Research Group, Rosen engaged in modelling * '"8 ""d costef-service models for utility systems.

work at NASA's Coddard Institute for Space Studies, .

nr 1 inmg ESRC. Austin researched theimpact of and was a staff sckntist at the National Center for the fateefeturn regulation on utility planning decisions.

. Analysis of Energy Systems of Brookhaven National Laboratory. He is Executive Vice-President of ESRC DAN R. ANDERSON Professor & Chairman of

. Risk Management and Insurance Depart 2nent School of Business University of Wisconsin Madison, Wisconsin I. PERSONAL INFORMATION Office: 195 Bascom Hall Phone: (608) 263-5717 Home: 1915 Adams Street Phone: (608) 256-5847 Madison, Wisconsin 53711 Birthdate: December 14, 1942 Birthplace: Rockford, Illinois Wife: Kathleen Holt Anderson Children: Robin Shepard Anderson Kristin Holt Anderson ,

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f II. EDUCATIONAL BACKGROUND Year School Attended Major Degreo Granted DeKalb Senior High School College Prep Diploma 1961 DeKalb, Illinois Yale University ' American B. A. 1965 New Haven, Connecticut Studies University of Wisconsin Risk and M.B.A. 1967 Madison, Wisconsin Insurance University of Wisconsin Risk and Ph.D. 1970 Madison, Wisconsin Insurance Title of Thesis: "An Analysis of the Effects of Under-evaluations and Overevaluations in Ioss Reserves, Relative to Those of Under-writing Results and Variable Asset values, Upon Policyholders' Surplus" III. TEACIIING POSITIONS HELD University of Wisconsin School of Business Teaching Assistant (Risk Management & Insurance) 1967-1969 Iccturer (Risk Management & Insurance) 1969-1970 Assistant Professor (Risk Management & Insurance) 1970-1975 .

Associate Professor (Risk Management & Insurance) 1975-1980 Professor (Rick Management & Insurance) 1980-Present San Diego State University School of Business Administration Visiting Accociate Professor (Risk Management & 1978-1979 Insurance) 2c.

Any of the above may be presenting testimony as witnesses on contention 6.3, but it has not yet been established as to precisel.y who.

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Interrogatory 3 -

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On page 3 of your April 9,1982 filing entitled "Augmen'tation By -

the GNYCE of the Basis for its First Contention" you identify potential conservation savings of 5.7 billion kWh.

a. What portion'of these savings do you estimate (1) have been achieved to date, and (2) are accounted for in Con Ed's latest official forecast.

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' b. For that portion of your estimated conservation savings above ,and beyond that.iden.tified in you response to Interrogatory 3a. provide b

(1) all underlying assumptions leading to your estimate; ..

the time frame over which you expect these savings to be (2) realized; (3) estimate of savings by consuming sector and by.end use; (4) estimate of the economic cost of the conservation effort being projected; and (5) the extent to which government subsidies (eA, low cost loans and tax incentives) and government mancatory programs are expected to contribute to these conservation savings.

Responte:

3a. This electric conservation potential was reported by the City Energy Office in Energy Consumption in New York City based on figures for 1979. Over the past five years, the number of Con Edison's electric customers has increased 0.83%. During the same period, its electric sales have declined 2.37 % while its rates have increased 54%. It is not unreasonable to expect that the 2.86% reduction in per customer consumption is simply a result of short-term price elasticity (i.e., curtailment rather than efficiency improvement), and thus the 5.7 billion kWh, or 20% consumption reduction potential cited by the CEO is probably 3

all still available.

The options for conservation explored in Con Edison's demand projections, as reported in its 1981 and 198,2 New York Power ,

Pool reports, are largely mutually exclusive' with those cited by the CEO. Con Edison concentrates on load curtailment methods rather than efficiency increases, and technologies that would '

actually increase electric use inappropriately such as heat pumps and electric vehicles. The only area of overlap we have identified is in the increase in residential appliance efficiencies.

Con Edison's forecasts can therefore be expected to include only a fraction of the conservation potential cited by the CEO.

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i 3b. This information is best acquired by reviewing the above City Energy Office report which is available from the New York City Energy Of fice, Offic of Economic Development,17 John St. ,

New York, N.Y. 10038, (212) 566-4152 Interrogatory 4 _.

On page 3 of your April 9,1982 filing , you indicate conservation would save over $550 million. Provide all underlying assumptions for this estimate and explain its basis. Also, over what time period will these savings occur.

Response: This ag .in was based on the City Energy Office report figure of $551 million for annual savings at the prevailing price of electricity and the level of conservation cited above.

Interrogatory 5 In your April 9, 1982 finding, you state that conservation will displace 71% of Indian Point generation value. Are you suggesting that these projected conservation savings will displace Indian Point .

. generation? If yes, explain why it would not displace con Ed's and PASNY's. reliance on its marginal 'ost source of generation, i.e., oil.

Response: The percentage cited is a commensuration for the purpose of comparing energy impacts. See also the response to Interrogatory 8 below.

Interrogatory 6 Provide your basis and assumptions used in c"oncluding in your  ;

April 9,1982 filing, that 1500 MW of gas fired cogeneration capacity

_could be built within 5 years. l Response: Typical cogenration system lead times are less t'han five years. Recent legislation and regulatory rulings (e.g . ,

PURPA, N.Y. State law setting a minimum cogeneration buy-back rate, N.Y.S. PSC ruling on cogeneration rates) serve to clear the remaining institutional roadblocks to highly economical cogeneration facilities. The City should and can casily encou-rage cogeneration expansion in keeping with market forces.

Various estimates of potential cogeneration capacity in New York city have exceeded 1500MW.

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, . Interrgatory 7

, Identify environmental isnpacts and estimate the economic cost associated with this cogeneration effort (1500 MW of gas fired cogenerationcapacity).

Responeo: The inevitable and desirable near-future increases in conservation and gas-fired cogeneration will result in large net reductions in oil combustion for electric and heat loads in New York City. The net environmental impact will be a beneficial. reduction in sulfates and particulates.

There will be no " economic cost" associated with the expansion of cogeneration. There will be private and perhaps public investments in cost-effective facilities on the order of $1.5 billion which will provide high rates of return as a result of reducing dollar exports for fuel from New York's economy. The secondary and higher order effects will also be beneficial to New York's economy and society.

interrogatory 8 )

a, Provide your basis for concluding in your April 9,1982. filing that savings of $600 million per year in fuel costs can be realized. Doesn't this assume cogeneration will phase out Con Ed's and PASNY's reliince on oil, and if so, how can this alter the replacement energy cost estimates for Indian Point? .

l Response: As the Staff implies, the savings from cogeneration are independent of the disposition of Indian Point. However, the availability of energy savings in N.Y.C. is very important, if, as the licensees seem to propose, there is a threshold

, value for absolute energy cost beyond which lies economic

!. disaster. Even prior to detailed analysis of Indian Point's

! costs, it is clear that with appropriate mitigating actions no new energy cost threshold need be passed when Indian Point;is closed. If a total energy cost threshold is used by the Board l

to judge the viability of closing Indian Point (if desirable on safety grounds), then any mitigating factors are of importance to the shutdown issce, even if they do not directly impact on the Indian Point plants.

Of course, we believe, based on the errors in the GAO and ' Rand studies, that a proper economic analysis of the Indian Point plants will show small impacts even without mitigating factors.

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Dated: November 12, 1982 l Dean R. Corren Director, GNYCE i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

1 CONSOLIDATED EDISON COMPANY ) Docket Nos. 50-247-SP OF NEW YORK (Indian Point, Unit 2 ) 50-286-SP

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POWER AUTHORITY OF THE STATE OF )

NEW YORK (Indian Point, Unit 3) )

CERTIFICATE OF SERVICE ,

I hereby certify that copics of " Response of GYNCE to NRC Staff Interrogatories and Document Requests Regarding Question 6" in the above-captioned proceeding have been served on the official service list by deposit in the United States mail, first class, this 12th day of November, 1982 q

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Dean R. Corren Director, GNYCE le.

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