ML20054H530
| ML20054H530 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/17/1982 |
| From: | Remshaw R CONSOLIDATED EDISON CO. OF NEW YORK, INC. |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-SP, NUDOCS 8206240169 | |
| Download: ML20054H530 (66) | |
Text
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RELATED COIUu:;3PONDENC3 S
d UNITED STATES OF AMERICA _
NUCLEAR REGULATORY COMMISSIOtl- ' 21 - ' 0'7 ATOMIC SAFETY AND LICENSING BOARD ,
Before Administrative Judges Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H. Paris
x In the Matter of : Docket Nos.
50-247 SP CONSOLIDATED EDISON COMPANY OF : 50-286 SP NEW YORK, INC. (Indian Point, Unit 2)
POWER AUTHORITY OF THE STATE OF NEW YORK June 17, 1982 (Indian Point, Unit No. 3) :
x CONSOLIDATED EDISON'S RESPONSES TO NRC STAFF INTERROGATORIES AND REQUEST FOR DOCUMENTS ATTORNEY FILING THIS DOCUMENT:
Brent L. Brandenburg CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
4 Irving Place New Yo,rA, New York 10003 (212) 460-4333 9206240169 820617 b
PDR G
ADOCK 0500024]
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O Interrogatory 1 (a) Provide all documents which relate to estimates of the incremental cost to the utility and its customers for the period extending over what would have been Indian Point Unit No. 2's remaining useful life, as-
- suming that the unit was permanently shut down effective mid-1983. Include in your response to this Interrogatory dccuments relating to estimates assuming both availability and unavailabi.ity of Indian Point Unit No. 3 for the re-mainder of its useful life.
(b) In your answer to 1(a) above, provide all documents relating to the cost differential for each im-pacted and identify total incremental cost on a 1983 present worth basis.
(c) In your answer to 1(a) above, provide all documents which identify the cost elements considered, e.g.,
differential in system production costs, and differential due to changes in capacity expansion plan.
(d) Identify the assumptions, data, and docu-ments relied upon in calculating the estimates contained in the documents called for by Interrogatory 1.
Response
Attached, in response to the Interrogatory, is a March 1982 study which was prepared by Con Edison and which utilized the General Electric MAPS program. This study responds to the questions except the permanent unit shutdown is started in mid 1982 instead of mid 1983. Con Edison and the Power Authority have retained Energy Manage-ment Associates (EMA) to conduct production cost studies utilizing their PROMOD III program. The results of the EMA studies will be submitted by Licensees as testimony in this proceeding.
E 9
STUDY OF ELECTRIC PRODUCTION COST IMPACTS OF A SHUTDOWN OF THE INDIAN POINT NUCLEAR UNITS 1
Generation Planning Dept.
Consolidated Edison Company
' of New York, Inc.
March, 1982
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3 I. Introduction l ; '; .
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II General Results of Studies 2 . ,,,,' i i.'N I A. Annual Electric Production Cost Increase '
l of a Shutdown of Indian Point 2 ,
B. Secondary Cost Increases j c 2 ,3 Sources of Replacement Energy for Indian ;'}
C. '
y Point Shutdown 3 .T' s, i "
III. Study Methodology t ', 4
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s A. Production Cost Program 4 , ,
B. Scenarios Otudied 5 C. Elements of Electric Production Cost Increa,ses 6 i IV. Study Assumptions 71s71 '
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A. tiYPP Generation Expansion Plans l' s ,s 7, \
B. \ \
C.
Indian Point Capacity' Factor .
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Fuel Prices -
s D. Coal Conversion l ,,'\ 8 E. High Sulfur Oil Test , , , l, 8 >
l F. Indian Point Operation and Maintenance Expense' 9 /.,
l G. Transfer Limits t 9 -
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V. Detailed Study Results ,,
10 . t 'y b A. Electric Production Cost Impact of Shutdown < lb B. Sources of Replacement Energy 12 VI. Other Factors , 14 i
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- I. INTRODUCTION l 1 The United States General Accounting Office (GAO) issued a report in 1980 which examined (and was entitled) the "Eco-1 nomic Impact of Closing the Indian Point Nuclear Facility." !
The electric production cost impacts of a shutdown of the 4
Indian Point nucicar units which were tabulated in that re-I port were obtained from simulations performed using the
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- General Electric Company's (GE ) Multi-Area Production Simula-4 tion Program (MAPS).
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(, Since the 1980 study, changes have been made both to the
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, i inputs to the model and to the model itself. GE has made changes that attempt to more accurately simulate actual system operations. These include program logic changes to imp' rove the modeling of pumped storage and Canadian economy 4
energy allocations, cost reconstructions and unit commit-N ments. In addition, since the earlier simulations did not
! adequately implement the logic for' simulating generating capacity which "must run" for area security purposes, this component of the model was modified as well.
! [ New production simulations have been run by Con Edison l ",
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which incorporate numerous revisions to the input data para- ;
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\/ . meters, the most significant of which is the revision of
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O 's fuel costs to reflect current estimates of long range fuel prices. Other changes to the data base include higher levels of Canadian economy _ energy expected to be available to the 1
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New York Power Pool, generally higher levels of transmission transfer capability across key interfaces, simulation of higher sulfur oil burning at Arthur Kill Units 2 and 3 and Ravenswood 3 prior to coal conversion, and lower NYPP load forecasts. Short term operation and maintenance expenses following a cessation of operations at Indiar Point have been excluded, since these are not readily quantifiable at this time.
The results of the new production simulations are presented in this report.
II. GENERAL RESULTS OF STUDIES The principal results of the new study of higher costs to electric consumers which would occur after a shutdown of Indian Point as determined by the revised electric production
- cost simulations are discussed below. The full results are discussed in more detail in Section V.
l A. Annual Electric Production Cost Increase of a Shutdown of Indian Point
- 1. The increased electric production cost to consumers in the Con Edison service area for the calendar year 1983, including inventory and working capital l
costs and taxes, is estimated to be S555 million.
- 2. Because of assumed escalation of fuel costs, the annual electric production cost increase incurred by consumers in the Con Edison service area, including
inventory and working capital costs and taxes, would increase to greater than Sl.1 billion by 1990 and to
- greater than S3.6 billion by 2000.
- 3. The electric production cost increase to New York State consumers as a whole would be similar to Con Edison service area increases with some variation i
from year to year depending on the changes in levels of economy energy transactions.
B. Sources of Replacement Energy for Indian Point Shutdown
- 1. More than 94 percent of the replacement energy would f
be generated by oil-fired generating units in 1983.
This would increase the-oil consumption in New York State by approximately 15.8 million barrels.
- 2. In 1983, approximately 40 percent of the additional oil consumed in the State would be residual oil burned f
in generating units owned by Con Edison and the Power i Authority.
III. STUDY METHODOLOGY A. Production Cost Program The computer program used to simulate the annual l
electric production cost impact of a shutdown of i the Ir. 'an Point units for the 1983-2000 study period was the GE Multi-Area Production Simulation Program (MAPS). MAPS simulates the actual opera-tion of the New York Power Pool (NYPP) electric [
generation system subject to transmission constraints under different assumptions of system conditions and unit availabilities. MAPS defines eleven load areas and ten separate transmission interfaces throughout the L~ ate. Transmission restrictions, based on transmission analysis, are defined so as to real-istically limit the flow of power from one area of the State to another. Each area is defined by its own bi-hourly load model and generating units.
Individual company ownership of generating units as weil as joint ownership of some units are denoted.
Generating units are represented by up to three loading segments, each with an incremental heat. rate.
The units are also represented by sustained ratings, historical forced and partial outages rates, and maintenance periods / "Must run" segments of gener-ating units as well as cycling abilities are also
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represented. Fuel and operating costs are defined for each generating unit. Provision is also made for NYPP purchases of firm and economy power from Canadian sources.
Subject to transmission limits, MAPS " dispatches" generating units throughout the state in order of increasing costs and recognizing reliability A
- constraints much as the NYPP system operator and the individual system operators do in real time.
MAPS is regularly utilized by Con Edison and other members of the NYPP for planning studies. The optional component of MAPS which reconstructs NYPP billing procedures for interutility purchases and sales was included so that production costs applicable to a given company were determined.
By virtue of this feature the benefits of economy energy exchanges in NYPP were considered. No distinction is made between PASNY and Con Edison within the Con Edison service area, although impacts on the two companies' customers could be significantly different.
Transmission transfer limits used in the program are the " normal limits" and assume all lines once in service are continuously available throughout the entire simulation period. This assumption tends to underestimate electric production cost increases which would result from a shutdown of Indian Point since in actuality transmission outages reduce transfer limits and the ability to replace genera-tion in Con Edison's Service Area.
l B. Scenario Studied Production cost simulations were performed for the study period 1983 through 2000, to determine electric production expenses with and without the Indian Point units in service.
C. Elements of Electric Production Cost Increases l The direct increases in electric production cost as a result of a shutdown of the Indian Point units were calculated by comparing differences in electric production costs with and without the Indian Point units in service. These direct electric production cost increases include changes in costs of operation of units in the Con Edison service area and the NYPP, as well as changes in costs of Canadian economy energy which is priced (in part ) on an avoided cost basis.
In addition to the annual direct electric production cost increases, inventory and working capital expenses as a result of additional residual oil requirements for Con Edison and PASNY in the service area were calculated. Gross revenue tax and sales tax were also considered to arrive at a total annual electric pro-duction increase.
IV. STUDY ASSUMPTIONS The Key assumptions made in the study are discussed below.
. A. NYPP Generation Expansion Plans Generation expansion plans for the State have been modeled in accordance with the plans presented by NYPP in its April 1, 1981 " Report of Member Electric Systems of the New York Power Pool Pursuant to Section 5-112 of the Energy Law of the State of New York."
B. Indian Point Availability Factor After consideration of required maintenance periods and partial and full forced outages, the Indian Point
! Units are assumed to have an annual capacity factor of
! 69 percent for each year of the study period. This 4
capacity factor is the same as that used by NYPP in long
! range planning studies. Analysis by the S.M. Stoller Corporation of historical data for Westinghouse PWR units 4
l indicates approximately this capacity factor after the first cycle and refueling. .
C. Fuel Prices The price of 0.3 percent sulfur oil assumed in the study was a starting price of S37.26 per barrel in 1982 including the 4 percent fuel use tax for fuel purchased in New York City. This fuel price was based on the ICF, Inc. estimates of long term prices contained in
.its February 1982 report proposed for use by members of of NYPP. ICF prices assumed for higher sulfur content oils were lower. ICF real price escalation on oil varied from i
1.9 percent to 2.6 percent per year above ICF inflation
. rates over the study period for the different sulfur content residual oils burned by NYPP member units.
1 ICF inflation rates which were used were 8.0 percent for 1983-85, 7.5 percent for 1986-90, 7.0 percent for 1991-95, and 6.5 percent for 1996-2000.
, Con Edison estimated coal prices for Ravenswood 3 in i
1982 is S2.73/MMBTU which is based on bids in hand.
Arthur Kill Units 2 and 3 coal prices will be somewhat lower due to lower transportation and handling costs.
Coal prices for other units in the state as well as escalation rates assumed over the study period were based on the ICF, Inc. estimates.
D. Coal Conversion The simulations assumed the conversion to coal burning of 3,665 MW of capacity within the state during the early to mid-1980's, o'f which about 1,750 Mw would i be Con Edison's Ravenswood 3 and Arthur Kill 2 and 3 generating units.
E. High Sulfur Oil Test Con Edicon currently burns 0.6 percent sulfur oil in
- Ravensucod 3 and Arthur Kill 2 and 3 on a temporary basis. The units were modeled in the studies as burn-ing 0.6 percent sulfur oil until they are converted to coal burning.
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. 1 F. Indian Point Operation and Maintenance Expense The analysis assumed that if Indian Point were shut down there would be no O&M expenses. This assumption results in calculated savings of the entire O&M expense, which in reality is not likely. At the very least, if the Indian Point units are closed prematurely there would be a pe-riod of time between shutdown and start of decommission-ing when significant O&M expenses would continue to be l incurred. The length of time and magnitude of such O&M expenses have not been estimated and were assumed to be zero.
G. Transmission Transfer Limits Normal transfer limits are used as input data to 4
the program for each of the ten transmission inter-
! faces in the state from 1983 through 2000. Such l transmission transfer -limi,ts do not reflect scheduled or unscheduled outages of transmission facilities.
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V. STUDY RESULTS A. Electric Production Cost Impact of Shutdown The electric production cost increase as a result of a shutdown of the Indian Point units was cal-culated by comparing differences in electric pro-duction costs from simulations run with and without the Indian Point units in service. The costs reflect
! changes in cost of operation of units in the Con l
Edison service area and the NYPP as well as changes in costs of Canadian economy energy.
- 1. Annual Electric Production Cost Impact
- a. Direct Electric Production Cost Increase Table 1 lists estimated annual electric pro-duction cost increases for customers in the Con Edison service area for the period 1983 through 2000. The direct electric production cost in-crease includes changes in fuel costs, variable O&M costs, start-up costs and the cost of Canadian economy energy.
- b. Increased Inventory Expense With a shutdown of Indian Point, additional fossil fuel would be required to be consumed, resulting in additional costs associated with an increase in inventory costs. Con Edison is required by the PSC to maintain a minimum fuel inventory equal to 75 percent of the projected maximum forty-five days of consecutive burn in any given year. An al-lowance for increased inventory expense for PASNY has also been included. The increased inventory expense is listed in Table 1.
- c. Working Capital Working capital is also largely a function of the fue'. expense. Such working capital for Con Edison is equal to one-eighth of the total annual fuel expense. Since a before tax return of about 20
- percent is allowed on working capital, incrementsi
- changes in fuel expenses result in an additional revenue burden to the consumer. Similarly, PASNY has a carrying charge in the order of 10 percent.
The total increase in working capital for the Service Area is listed in Table 1.
j d. Gross Revenue and Sales Taxes Gross revenue and sales taxes paid on electric bills by Con Edison's customers are a function of the magnitude of their electric bills. The revenue and sales taxes are nominally 6.1 percent and 8.25 percent in New York City, however, some of Con Edison's customers are located in Westchester County or may be exempt from some of these taxes.
PASNY's customers are not subject to either tax.
A composite tax for the Service Area of 6 percent was assumed. The cost is also tabulated in Table 1.
- e. Total Impact The total electric production cost impact of an Indian Point shutdown is the summation of the direct electric production cost increase, the increased inventory expense, the increased working capital and the gross revenue and sales
- taxes for the Service Area. This total for the Con Edison Service Area is shown in Table 1.
- 2. Impact on New York State Table 2 lists the electric production cost'in-creases to New York State for the study period.
Due to the complexity of estimating the increase in inventory and working capital expenses and the gross revenue and sales tax rates for other utili-ties, only the direct increase in electric pro-duction expense is shown.
- 3. Secondary Cost Increases A shutdown of Indian Point would significantly increase the demand for, and consequently the price of, residual oil on the East Coast. The impact of the additional cost increase wae, not reflected in the fuel prices used'in the simulation discussed above.
B. Sources of Energy Tables 3 and 4 illustrate the sources of energy which would replace Indian Point energy in the years 1983 and 1990. As shown in 1983, a loss of the Indian Point generating capacity would result in an increase i in oil consumption of approximately 15.8 million barrels of oil, 40 percent of which would be burned by Con Edison or PASNY oil fired generating units. Additional amounts of oil fueled replacement energy would be generated by Niagara Mohawk (20 percent) and LILCO (21 percent),
and lesser amounts generated by the remaining NYPP member companies.
Replacement oil consumption would decline if and when coal conversions are completed, particularly those L
at Con Edison's Arthur Kill and Ravenswodd generating stations, to a low of about 11.4 million barrels in 1987. Replacement energy from oil again increases to over 14.0 million barrels by 1995, due to load growth exceeding unit additions after 1987.
VI. OTHER FACTORS A. Coal Conversions To the extent that the conversions do not receive timely approval or are ultimately rejected, additional replacement energy for Indian Point would be generated by oil fired generating units during the 1980's, thereby further increasing residual oil consumption and costs to customers.
B. Existing Nuclear Units and Nuclear Units Under Construction This analysis assumes that all other nuclear plants in New York State continue to operate and that the two nucicar plants now under construction (Shoreham and Nine m
.ile Point 2) are completed on the dates presently scheduled. Loss of production from any of these nuclear plants would increase production cost penalties associated i with an Indian Point shutdown.
! C. Interpool Transactions 1
The shutdown of Indian Point would increase the-cost of economy energy purchased by NYPP from other pools since prices are based on avoided costs. Other neighboring power pools' cost would increase since less economy energy from plants within NYPP would be available for sale to those pools. The cost to electric customers in those pools and-the associated lost opportunity costs to the NYPP have not been quantified.
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TABLE I PRODUCTION COST INCREASES FOR INDIAN POINT SHUTDOWN CON EDISON SERVICE AREA (Millions of Dollars )
, Total Increased Increase Direct Increased Working Including Production Inventory Capital GRT/ GRT &
Year Cost Increase Expense Expense Sales Tax Sales Tax I 1983 509 5 10 31 555 1984 579 5 11 36 631 1985 625 5 12 39 681 1986 697 6 13 43 759 1987 680 5 13 42 740 l 1988 779 6 15 48 848 1989 872 7 17 54 950 1990 1020 9 19 63 1111 l 1991 1078 9 21 66 1174 1992 1163 10 22 72 1267 1993 1330 11 25 82 1448 1994 1480 11 28 91 1610 1995 1725 14 33 106 1878 1996 2037 15 39 125 2216 1997 2218 20 42 137 2417 1998 2481 20 48 153 2702
.1999 2934 24 56 181 3195 2000 3332 27 64 205 3628
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TABLE 2 .
4 DIRECT PRODUCTION COST ?ENALTIES FOR IllDIAt1 POINT SHUTDOWN STATEWIDE EFFECT (Millions of Dollars)
(1)
YEAR STATEWIDE PENALTY l 1983 506 1984 :579 1
l 1985 654 1986 723 1987 686 1988 808 1989 906 1990 984 1991 1110 1992 1199 1993 1349 1994 1479 1995 1693 1996 1966
, 1997 2193 1998 2451 j
1999 2789 2000 3178 (1) Exclusive of increased inventory and working capital expen-ses and taxes but inclusive of changes in cost of Canadian Economy Energy.
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TABLE 3 f SOURCES OF ENERGY TO REPLACE INDIAN POINT 1983 Residual Distillate Coal 011 Oil l
Company X 1000 Barrels X 1000 Barrels- X 1000 Tons Central Hudson 1877 0 0 (1)
! Con Edison 6372 27 65 LILCO 3276 34 0 NYSEG 0 0 129 Niagara Mohawk 3173 2 13
! O&R 773 0 36 Rochester 286 0 2 1
, Total NYPP 15757 63 245 1
1 (1) Includes the Power Authority's Astoria 6 Unit and Con Edison share of Bowline Point and Roseton Units.
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TABLE 4 SOURCES OF ENERGY TO REPLACE INDIAN POINT 1990 Residual Distillate Coal 011 Oil Company X 1000 Barrels X 1000 Barrels X 1000 Tons Central Hudson 848 0 64 I (1)
Con Edison 5947 1 521 LILCO 1207 2 53 NYSEG 0 0 155 Niagara Mohawk 3664 1 23 O&R 980 0 49 Rochester 401 0 5 Total NYPP 13047 4 870 (1) Includes the Power Authority's Astoria 6 Unit and Con Edison share of Bowline Point and Roseton Units.
Interrogatory 2 (a) Provide all documents which relate to estimates of likely outages to Indian Point Unit No. 2 and any other units (identifying such units by name) as a result of the proposed settlement agreement with EPA and NY PUC (re cooling system operations during biologically important periods).
(b) If Indian Point Units Nos. 2 and 3 were permanently shut down, would the other impacted units (iden-tified in 2(a), above) still be subject to the same outages?
If not, explain why the outages would differ making specific reference to each generating unit involved.
Response
The cooling tower settlement agreement has been approved by the New York Public Service Commission and is now in effect. The stations affected by the settlement agree-ment are Indian Point, Bowline Point and Roseton. Attachment A presents the estimates of likely outages to Indian Point and other impacted units.
If the Indian Point units were permanently shut down, the Bowline Point and Roseton generating station outage requirements under the settlement agreement would be alleviated by crediting forced outages at the Indian Point units against the required Bowline Point and Roseton outages. However, most of the outage requirements under the settlement agreement placed on these units would have been satisfied by selective scheduling of annual maintenance activities which would have required outages in any event. Thus, even though the obliga-tion under the settlement agreement to fulfill outage require-ments at those stations would be alleviated were Indian Point permanently shut down, those units would still have to be taken out of service periodically for maintenance activities.
l Attachment A Indian Point Units As part of the Settlement Agreement, Con Edison and PASNY have agreed to remove Indian Point Units 2 and 3 from service during the May 10.- August 10 period for a total of 60 unit-weeks over the next ten years commencing in May 1981. During this period, the units can be expected to be out of service due to various ,
reasons for the major portion of the required 60 unit-weeks.
Additional outages would be required to the extent normal unit outages are insufficient to satisfy the terms of the agreement.
This discussion quantifies the utilities exposure to such additional outages.
There are several methods which can be used to estimate the outages which can be expected to occur during the 10 years which will go toward satisfying the terms of the settlement agree-ment.
First, a purely probabilistic schedule can be considered.
Assuming a " normal" 18 month refueling cycle for the Indian Point units, with refuelings occurring randomly and lasting between eight (8 ) and ten (10) weeks, the expected refueling outages during the window period will range from 13.3* to 16.7 weeks for each unit over the 10 year period. Other outages are also likely to occur.
- 12 mos./yr. x 8 wks./ cycle x 0.25 window wks x 10 yrs. = 13.3 wks.
18 mos./ cycle yearly wks A-1
Using the New York Power Pool assumed forced outage rate for mature
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nuclear units, expected forced outages during the " window" periods over the ten years would range from 12.8 weeks to 12.5* weeks per unit, depending on refueling duration. For the two units expected outages over the 10 year period range from 52.2 to 58.4 weeks.
The total additional outage required would therefore range from 7.8 to 1.6 unit weeks.
The second methodology, a more deterministic estimate of expected outages during the " window" period, uses planned mainte-nance schedules for the Indian Point plants as currently projected.
Based on current refueling schedules, refuelings in the window pe-riod over the ten year time frame total 16 weeks for Indian point 2 and 12 weeks for Indian Point 3. Incorporating expected forced outages similar to above results in total outages over the ten year period of 28.5 weeks for Indian Polnt 2 and 25.0 weeks for Indian Point 3. Together these outages total 53.5 weeks which, when compared to the 60 week settlement requirement, yields 6.5 weeks of additional outages required over the ten year period.
A third method recognizes that both Con Edison and PASNY will exercise available control to obviate the need for additional outages. A single cycle length can be changed by one to two months with minor costs for re-design of the nuclear fuel cycle. Applying
((520 weeks x 0.25) - 13.3 wks.] x forced outage rate = 12.8 wks.
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such flexibility would increase the refueling outage for Indian Point 2 during the " window" period from 16 to 24 weeks. Adjusting any cycle of the Indian Point 3 schedule by only one month would have no effect on the 12 weeks of refueling which occurred in the
" window" period. When the effects of generic forced outages are added, the expected outage figures become 35.7 weeks for Indian Pont 2, and 25 weeks for Indian Point 3 for a total of 60.7 weeks
- which exceed the 60 week requirement.
A fourth methodology considers the actual forced outage data for Indian Point Units 2 and 3. Using these figures to esti-mate future outages, and considering adjusted refueling schedules, would result in total outages during the " window" period in excess of the 60 weeks requirement.
Table I summarizes the expected additional outages using the four methodologies.
Roseton and Bowline Point units The Settlement Agreement requires a thirty unit-day outage at either one or both of the Bowline Point units and at either one or both of the Roseton units between May 15 and June 30 of each year. Based on present maintenance outage requirementc, this provision of the agreement will result in no additional outages of either unit.
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The Settlement Agreement also provides for an additional outage of one Bowline Point unit for an aggregate of 31 unit-days during the month of July in each of the first five years of the agreement. At the end of five years the utilities will have the option to continue the Bowline Point July outages for the remaining five years of the settlement or to take a total of 14 additional unit-days of outages at Indian Point 2 and/or Indian Point 3 between May 10 and August 10 in addition to the other outages at these units, increasing the 10-year total outages at these units from 420 unit-days to 434 unit-days.
It is expected that the Bowline Point July-penalty outage will be in addition to the regular maintenance for these plants, thus reducing Bowline Point's overall availability by 31 days per year. ,
No decision has yet been made to date concerning the substitution of Indian Point outages for Bowline Point outages in the latter five years of the agreement.
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s TABLE I SETTLEMENT AGREEMENT IMPACT OF INDIAN POINT OUTAGES SUt1 MARY TABLE Method 1 Metho-1 2 Method 3 Method Refueling Outage Model Generic Probabilistic Standard Modified Modifie<
Dete rminis tic De te rministic Deterministic Forced Dutage Model Generic Generic Generic fli s tor i <
Weeks of Outage Du r ing Spawning Period IP2 IP3 IP2 IP3 IP2 IP3 IP2 IP3 Refueling Outages 13.3-16.7 13.3-16.7 16.0 12.0 24.0 12.0 24.0 12.0 Forced Outages 12.8-12.5 12.8-12.5 12.5 13.0 11.7 13.0 15.8 12.0 Total Outages 26.1-29.2 26.1-29.2 28.5 25.0 35.7 25.0 39.8 24.0 Total for IP2 & IP3 52.2 -
58.4 53.5 60.7 63.8 Additional Outage 7.8 -
1.6 6.5 0 0 A-5
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1 Interrogatory 3 f
! Provide a copy of your latest submittal.to j Northeast Power Coordinating Council response to ERA order '
l 411.
Response
The Northeast Power Coordinating Council submit-
[ tal is attached.*
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- A copy of this report may be examined upon request i
at Con Edison's of fices, 4 Irving Place, New York,
! New York 10003 I
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i Interrogatory 4 Provide latest copy of " Report of Member Electric Systems of the tiew York Power Pool and the Empire State Electric Energy Research Corporation."
Response
The 1982 submittal pursuant to Section 5-112 of the Energy Law of tiew York State is attached.*
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- A copy of this report may be examined upon request at Con Edison's offices, 4 Irving Place, New York, New York- 10003
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Interrogatory 5 Provide all documents which relate to estimates of the decommissioning cost for Indian Point Unit No. 2 assuming (a) decommissioning occurred at end of useful life, and (b) decommissioning occurred prematurely (i.e., consistent with mid-1983 shutdown). In your response to this Interroga-tory identify all of the data and assumptions used in develop-ing such cost estimates.
Response
Attached is a study by Nuclear Energy Services Inc.
dated April 1982 which describes decommissioning costs for Indian Point Unit 2 based on decommissioning in the Year 2006 entitled " Decommissioning Study of Prompt Dismantlement of Indian Point Unit 2".* Con Edison has not, as yet, studied the impact of premature decommissioning.
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- A copy of this report may be examined upon request i
request at Con Edison's offices, 4 Irving Place, New York, New York.
Interrogatory 6 ,
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Ilave any provisions or proposals, such as change in the rate base, been made by the Licensee, its agents or consultants to recover expected decommission- j ing costs for Indian Point Unit No. 2? If so, identify 1 i
such provisions or proposals and all documents relating to such provisions and proposals.
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Response
In Case 27353, in an opinion issued on April 6, 1979, the New York Public Service Commission determined the ,
annual decommissioning charges for the remaining service ,
life of Indian Point No. 2 which are to be reflected in_ #
rates. The annual charges increase over time, and are:
currently S3.14 million. The current annual charges are based upon a 1976 AIF generic study and would increase >
substantially if the Nuclear Energy Services, Inc. study '
provided in response to Interrogatory 5 were to be accepted for rate purposes.
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Interrogatory 7 If Indian Point Unit No. 2 or Unit No. 3, or both, were permanently shut down in 1983, would replace-ment power generation be needed? If so, identify for the period extending over what would have been the Indian Point Unit (s) remaining life the specific sources (noting the power output for each source) of power generation (whether existing or new construction) that would be neces-sary to taxe the place of the Indian Point Unit (s). Pro-vide for each identified source of such generation all do-cuments that describe the surrounding environment. Parti-cularly provide those documents which note the description of aquatic and terrestrial biota that might be affected by operation or construction of such replacement sources.
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Response
The replacement power for Indian Point Units 2 and 1 generation, estimated to be approximately 11 million megawatt hours annually, would be generated by Con Edison as well as by other member utilities of the.New York Power Pool.*
The replacement generation would be obtained l
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, Power-Pool System, subject to transmission limitations, to the l
l Con Edison franchise area. All Power Pool members dispatch their generating units through a central system, and it is, t b e 're fore ,
not realistic to identify the incremental dispatch of more l
than 100 generating units throughout the state at any given time.
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i New York Power Pool members are: Central Hudson Gas &
I Electric Corporation, Consolidated Edison Company, Long
! Island Lighting Co., New York State Electric and Gas Company, Niagara Mohawk Power Corporation, Orange and Rockland Utilities, Power Authority of the State of New York, and Rochester Gas & Electric Co.
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1 Response 7 (cont'd)
However, current estimates are that approximately 40% of the replacement power for Indian Point Units 2 and 3 during the next 10 years would be generated within Con Edison system.
The water bodies that might be affected by in-creased power production by Con Edison's generating units include the riudson River, East River, and the Arthur Kill.
Other Power Pool member generating stations are on Lake Erie Lake Ontario, the Niagara River, Long Island Sound, and the Atlantic Ocean.
Listed below are the titles of documents which contain descriptions of the environment at or in the vicinity of existing generating stations in the New York metropolitan area which may provide portions of the replacement jeneration capacity should the Indian Point Units No. 2 and 3 be shut down.
Draft Environmental Impact Statement
- For Coal Reconversion at Ravenswood Unit 3 l Queens County, N.Y.
l Draft Environmental Impact Statement
- For Coal Reconversion at Arthur Kill Units 2 and 3 Richmond County, N.Y.
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- Copies of these documents may be examined upon request at Con Edison's offices, 4 Irving Place, New York, New York, 10003.
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- Interrogatory 7 (Cont'd)
Air Quality Analysis of Con Edison's Energy Strategy for the 1980's -
Reconversion of Ravenswood Unit 3 and Arthur Kill Units 2 and 3 to fligher Sulf ur Fuels
- In addition, the document
- identified below contains a description of the environment of . the !!udson River i
estuary along which arc located generating stations which could provide portions of replacement generation should the Indian Point generating Units 2 and 3 be shut down.
Influence of the Proposed Cornwall*
Pumped Storage Project and Steam Electric Generating Plants on the liudson River Estuary with Emphasis on Striped Bass and other Fish Populations Revised.
Con Edison does not have environmental reports for units owned by other members of the New York Power Pool.
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- A copy of this document may be examined upon request at Con Edison's offices, 4 Irving Place, New York, New York, 10003.
Interrogatory 8 A. For the year 1980 and, if available, the year 1981 provide the annual fixed charges on the capital invest-ment attributed to Indian Point Unit No. 2 and any other fixed costs of the utility which are allocable to Indian Point 2 (given the bases for their computation), including but not neces-sarily limited to the following:
- 1) depreciation
- 2) return on investment (excluding interest)
- 3) interest ,
- 4) income taxes
- 5) property taxes
- 6) other state and local taxes
- 7) interim replacement allowance 4 8) property insurance premium
, 9) nuclear liability insurance premium
- 10) non-nuclear liability insurance premium
- 11) general administrative costs (excluding fixed operation and maintenance cost)
- 12) other fixed costs (specify if possible )
B. Indicate which, if any, of the costs in your response to Interrogatory 8 will vary from year to year and the amount of decrease or increase, assuming Indian Point 2 continues to operate.
C. In your response to 8.A.2) and 3), indicate how the return on investment and interest is computed.
D. Identify the kinds of state and local taxes attributed to Indian Point Unit 2 paid by Con Edison.
E. 1) In your response to B.A.ll) explain how general administrative expense was determined.
- 2) State whether Con Edison conducts any nuclear planning or research activity not specifically tied l
with Indian Point 2, the cost of such activity, whether that l cost was included in general administrative expense, and to
! what extent the shutdown of Indian Point 2 could be expected
! to affect that cost.
Response 8A The annual fixed charges for the year 1981 on the capital investment attributed to Indian Point Unit No. 2 are shown on the following table.
. Response 8A (Cont'd)
Annual Fixed Charges for the Year 1981 Indian Point Unit 2 (including allocation of Unit 1)
W/O PSC Authorized With PSC Authorized Decommissioning Decommissioning Allowance (1) Allowance (1)
Percent Thou- Percent Thou-of sands in of sands in i Book Cost Dollars Book Cost Dollars
- 1. Depreciation 2.80 10,185 3.66 13,313
- 2. Equity Return 4.55 16,550 4.30 15,641
- 3. Interest Return 2.27 8,257 2.15 7,820
- 4. Income Tax 4.31 15,677 4.10 14,913
- 5. Property Tax 2.67 9,702 2.67 9,702
- 6. Other State & Local 1.32* 4,80l* 1.34* 4,874*
Tax 1.36 4,947 1.38
- 7. Interim Replacements N/A (2) N/A (2)
- 8. Property Insurance .36* 1,309* .36* 1,309*
.48 1,746 .48 1,746 9 - 10. Liability Insurance .16* 582* .16* 582*
.72 2,619 .72 2,619
- 11. General Administra- 3.19 11,603 3.19 11,603 tion
- 12. Other Fixed Costs (3) - -
Annual Fixed Charges (Indian Point shutdown) 21.63* 78,660* 21.93* 79,767*
Annual Fixed Charges (Indian Point _in Ope-ration) 22.35 81,286 22.65 82,377 (1) Allowance assumes normal retirement date.
(2) Note, however, that accrued depreciation accrual provides to the same extent for interim replacement.
(3) Annual carrying charges on fuel pre-payments not included since they are not classified as a fixed plant asset on the Company's balance sheet.
- Values reflect estimate of decline in costs due to closing operations.
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Response 8B
. All of the fixed charges indicated in response 8A would vary from year to year, some would be higher, others would be lower. Con Edison has not calculated fixed charges for other years on a directly comparable basis.
Response 8C The return on investment of 4.55% without the de-commissioning allowance shown in Response to Interrogatory 8A was calculated as follows:
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- 1. 363,741 Average Book Cost
- 91,351 Average Accrued Depreciation 272,390 Book Value
- 2. Ratio of Book Value to Book Cost = 272,390 = 74.85 363,741
- 3. 74.88 - 7.6% (ADRN*) = 67.29% Net Book Value
- Asset Depreciation Range Normalization
- 4. 67.29 x 6.76 (Weighted Cost of Equity, see below) = 4.55 Equity Return The interest without decommissioning allowance was 1
calculated as follows:
67.29 x 3.37 (Weighted Cost of Debt, see below) = 2.27 Interest Return l
Bases for Rate of Return Calculation - Return Allowed in Case #27744 Capitalization Structure Ratio Cost Return De bt & Customer Deposits 53.44 6.30 3.37 Common & Preferred Equity 41.56 14.51 6.76 l
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- Response 8D State and local real estate taxes paid by Con Edison and attributed to Indian Point 2 were S9,688,116 for 1981. Details of these taxes are shown in the response to Interrogatory 12.
Response 8E
- 1) Average General and Administrative Expense are calculated using total company (actual) expenses incurred.
Accounting procedures do not keep company locations separate for these expenses.
Average Company Administrative Average Plant in Service and General Expenses for the for the year 198.
year 1981 245,591,000 7,699,801,000 = 3.19%
- 2) Con Edison does conduct nuclear related research activity not specifically tied with Indian Point 2. There were no expenditures for these activities for the year 1980 nor for for the year 1931. The program involved is the Liquid Metal Fast Breeder Reactor Program. Further expenditures on this pro-gram are currently estimated to be approximately S800,000 per year These costs would not be included in the general administrative expense. Shutdown of Indian Point 2 would not be expected to affect these activities.
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Interrogatory 9 Identify the original book cost and present book cost of Indian Point 2.
Response
The average book cost of Indian. Point 2 including i
common f acilities for 1981 was S363,741,000. An original book cost on a comparable basis has not been calculated due to the retirement of Indian Point Unit No. 1 and subsequent allocation 1
to Indian Point 2 of common facilities used by both plants.
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Interrogatory 10 Indicate which, if any, of the costs in Inter-rogatory 8 would cease in the event of a shutdown of Indian Point Unit No. 2 and which, if any, of the costs in Inter-rogatory 8 would decline, and by what amount if Indian Point Unit No. 2 ceased operation.
Response
1 Fixed costs do not vary with the operation of the plant. With the exception of a minor reduction in the cost of insurance and some taxes even if the plant were per-manently shutdown with no expectation of reopening, these fixed costs would continue. See Response to Interrogatory 8.
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Interrogatory 11 Do you expect the New York Public Service Commission would continue to permit the inclusion of the fixed charges for Indian Point No. 2 in the rate base if Indian Point Unit No. 2 ceased operation. Provide the basis for your response.
Response
The New York PSC would not permit the Company to continue recovering these costs from ratepayers. In the event of a permanent shutdown, the Company would request the PSC to treat the remaining unrecovered investment in Indian Point 2 as an extraordinary property loss and allow the Company to amortize the remaining investment over a period of years with the unamortized balance included in rate base until the end of the amortization period. A proposal for full extraordinary property loss treatment for the Indian Point 2 investment would probably be contested in the ap-propriate ratemaking proceeding.
Interrogatory 12 Indicate for Indian Point Unit No. 2 the 1980 real property tax payments to the State and the 1980 real property tax (or in lieu) payments to the following juris-dictions: Westchester County, Town of Cortlandt, Village of Buchanan, Henrik Hudson School District, Verplanck Water District, and the Verplanck Fire Protection District. In your response to this Interrogatory reflect the value of property exclusive of offsite transmission lines.
Response
The table below shows real property tax payments for 1980 and 1981.
1981 Payments 1980 Payments New York State -
S 10,712 Westchester County S 2,638,323 2,643,952 Town of Cortlandt 386,979 377,846 Village of Buchanan 866,750 822,776 Montrose (Hendrick Hudson)
School District. 5,652,651 5,151,322 Verplanck Water District - -
Verplanck Fire District 143,413 144,127 Total S 9,688,116 S 9,150,735 l
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. Interrogatory 13 Indicate for Indian Point Unit No. 2 all payments to the State and to local jurisdictions, other than real property tax and in-lieu payments. In your res-ponse to this Interrogatory specifically identify the amount of each payment.
Response
Con Edison pays gross receipt taxes to the State of New York on sales of electricity and sales taxes on pur-chases.- A breakdown of these taxes by localities is not available.
Neither the Town of Cortlandt nor the Village of Buchanan imposes a gross receipts tax on the sales of elec-tricity, and Con Edison did not pay any local sales taxes on purchases to the Town or Village in 1981.
Interrogatory 14 Indicate for Indian Point Unit No. 2 the number of employees at the site and the number of contractor person-nel (security, maintenance) who are regularly stationed at the site. For the former group, also indicate the job cate-gories of employees, the residential location of each indivi-dual and the 1981 dollar value of each contract. (County level addresses will satisfy the residential location informa-tion request.)
Response
The attached table lists the various locations of the Con Edison workers who are assigned to the Indian Point Unit 2 site as of December 31, 1981. Con Edison management personnel are responsible for plant management, administration, technical, professional and secretarial duties required in the operation of Indian Point Unit 2. Con Edison union personnel's-duties include plant operation, instrumentation, mechanical and electrical technology operations as well as health physics. The figures do not include Company or contractor construction forces who are used for various projects.
In addition to the employees who are working at the site, it should be noted that there are employees at l
, other locations who provide support for the operation of 1
the Indian Point unit. The number of such support personnel for 1981 is estimated to be approximately 50 full time people for Indian Point 2.
Response 14 (cont'd)
. Indian Point Unit No. 2 Nuclear Power Contract Guards Number of Employees Total 390* 168 Mgmt 131 Union 259 Annual Salary (1981)
Total S12,500,000 Mgmt S 3,700,000 Union S 8,800,000 Contract (1982 estimate) S5,000,000 Residence New York Brooklyn 0 'O Bronx 6 1 Dutchess 135 57 Nassau 0 0 Manhattan 1 0 Orange 39 35 Putnam 54 18 Queens l' 0 Richmond 0 0 Rockland 18 8 Sullivan 1 0 Ulster 1 0 Westchester 126 68 t
Connecticut 6 0 New Jersey 2 0 I'
Total 390 168
- As of . Decembe r 31, 1981 Interrogatory 15 Indicate with respect to operation of Indian Point Unit No. 2 the kind and value of materials and services purchased in Westchester and Rockland Counties and New York City during 1981.
Response
Expenditures in 1980 for materials and services pur-chased in Westchester County, Rockland County and New York City (including New York, Kings, Queens, Bronx and Richmond Counties) are listed below for Con Edison's Indian Point 2. Included are expenditures for equipment, professional and general ser-vices, repair and maintenance, construction, automotive, office supplies, mechanical and electrical material, spare parts, EDP equipment, etc. Not included are expenditures for fuel, legal services and financial services.
Indian Point 2 Westchester S24 million Rockland S 0 New York City $ 5 million Expenditures for 1981 were not readily available broken down by locality.
Interrogatory 17 (a) Is it physically possible to construct at the Indian Point site one or more coal-fueled facilities generating a total of 1800 MW. -
(b) If it would not be possible to locate such coal-fired generating capacity at Indian Point, state whether there are any sites available within a 10-mile radius of the Indian Point Units that could be used for construction of such coal-fired capacity. In addition, identify the location of such sites.
Response
It may be physically possible to construct a coal-fired facility generating a total of 1800 MW at Indian Point, however it would require at least six years to decommission and dismantle the nuclear units and six or more years additional to license and construct coal units. There would likely be extensive delays in obtaining environmental approvals for a coal-fired facility at the site.
Con Edison knows of no other sites within a 10-mile radius of the Indian Point units that could be used for construc-tion of such coal-fired capacity.
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't Interrogatory 18 i,
j Using the most recent " capability period," provide -
the current operating reserve requirement for the NYPP, and in-2 dicate the magnitude of each member's share of this require-j _ ment.
1 i Response j See attached table.
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Issued 4/12/82 Effecti7e 4/25/82 k,.;ge/ . .
.. NEtt YORK PCs ER POOL - OP'IRATI NG RESERV E TA BLE OP-2-A '
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SUMMER 1982 C AP AB IL ITY P ER10 0 - -
F I R ST' . . . -
CON TI NGENCY LILCO CO N ED ORU CHGC E NM P NYSEG RGSE NYPP TOT IICCO' f41N SY NCH -99 -
237 21 24 199 '
8S 38- 703.
M :,,.v. ' MAX NO N SYNCH 98 236 20 24 198 - 64 .37 697
'r*H>..10- MINUTE RES 197 473 ~ 41 48 397 . 169:. - { 75 1400 30-MINUTC RCO 00 ~237- 21 25 100 ' C4 37 70C TOT OPER RES 295 710 62 73 595 2 63 112 2100
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1300 MIN SYNCH 92 220 20 23 .184 79 35
" A X-NGM-SYNC M 0; 2 '. O 653 10 2-2 104 70 L v47
- 10 MINUTE RES 183. 439 -
39 45 '368 .157 - ' 69 1300
$ 30 MINUTE RES 98 237- 20 24 -199 ^ ! 64 '26 700
- ' mTOT ' OPER RES. 281 676 59- 69 567 241 107 '20C0 1200 MI N SY NCH 85 203 18 21 170 73 32 MAX NON SY NC H 84 202 18 602
- 20. 170 72 32 598 10 M IN UTE RE S 169 405 36 41 340 145 64 . 1200 30-*iMvFC 'C O O4 200 ;o 2i ;- 70 72 CZ a00
.- ., TOT. OP ER RES? 253, 608 54 ,62- 5 10 2.17 , ,. 96 1800-1100 MIN SYNCH J -
17- . ,- -
77 186 19 - 156 66'
- 30 MtX-NO N-SYNC ; . 7' 100 *t 551 1-0 150 GG '_S 0%
10 MINUTE RES 154 .372 33 36 3 12 132 59 1100 30 MINUTE RE S 65 202 17 21 1 70 73 32 600 T3T OP ER RES 239 574 50 59 482 205 591 1700 MIN SYNCH 70 169 15 18 ~ 142- t . 61 - 27 MAX NON SY NC H- 70 169 502
- IS' 17 141- 60- 26 498
- 10 MINUTE RES . 140- . 338- 30 35 283 " 121 ' 53 . .1000 30-M-it+UTC RC O M 200 14 t-7 1-4C GG 27 .C0 TOT OP ER RES 211 507 - 44 52 425 181 80 1500 900 MIN SY NCH 6 3, 152 14 16 '
128 SS 3 y. . -- , _- n .
2,4 .
452
- - '10 MINUTE RE S 126 '304- 27 31 2 66 J30 MINUTE RES 71 ~ 169
' ' 109- -. 48. 900 14 17 142 60- l 27' 500 ~
. ' ~ TOT OP ER .RES 197 473 41 -
4 8 ' ,, 397 169 :75 1400.
s 600 MIN SY NCH 56 135 12 14 1 14 48 22 401 MA X NO N SYNCH 56 135 12 14 113 48 21 399 10 MIN UTE RES 112 270 24 - 28 227 96 43 800 30-*1P+uTC RC O 07 13 iC 12 1 1.; 40 21 400
..TO T. OP ER RES 169. 405 3-36 - 4L 340 .145...
. 73,
,.64 1200 700 MIN SY NCH 49 119 ' 11 - 22 2 99 L42 :19- 351
" A-X-NON-SYNC ; .
40 2-2 0 1C 1-2 10 MIN UTE RES 98 237 21 24 198 OO 42 17 26 .
30 M IN UT E RES 56 84 38 700 135 12 14 114 46 21 400 TO T OP ER RES 154 372 33 38 312 132 59 1100
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.IGOG MIN SY NCH .42 102 I,:'.- MAX NON SYNCH 42 101.
. - 9 9 - 10 li> 85 85 36 36, 16 -- 30i
(' ~ . 10 - MIN UTE RE S 84 16 299 203 18- 21 170 -
72 32 000 30-M IMOTE---R E-S ^2 101 ? 10 00 37 ' 10 TO T OP ER RES 126 304 20c 27 31 255 109 48 900 500 MIN SY NCH- 3,5 85 9 14
_ gg g3_gyggo c n , 8, m 7,1 3 0., ,
252- _
10 . MINUTE RES 70 169 15 - 17 142- 60 27 500 MIN UTE- RE S 42 - 101 9.
(7f(rm)30 _ 11 '
85- ~ 36 16' 300' STOT OPER RES - 112 270 . 24 28 227,- 96, 43 800
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Interrogatory 19 Provide all documents which relate to the NYPP policy regarding distribution of operating reserve.
Response
See attachment.
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.-- NEW YORK POWER PCOL OPERATING POLICY m2-13
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SUBJECT:
Operating Reserve Policy t
APPROVED BY: the Operating Committee on Cecember 17, 1981 l to become effective December 22, 1981 ;
._ SUPERSEDES: Operating Policy #2-12
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REFERENCES:
NERC-0C 0perating Manual MINIMUM OPERATING RESERVE REQUIREMENT -- - - - - - - -
The Minimum Operating Reserve Requirement of the New York Power Pool' shall be the sum of: ;
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- 1. Sufficient Ten-Minute Reserve to replace the operating i
.. capability loss caused by the most severe single contingency within the Pool. A single contingency is considered to be a' forced outage of generation due to the loss of a generator, bus section, transmission line or transformer. -
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- 2. Sufficient Thirty-Minute Reserve equal to one-half of the (9 . Ten-Minute Reserve. 'I AVAILABILITY AND CATEGORY ._
- l. The Ten-Minute Reserve portion of the Pool's Minimum Operating Reservd Requirement shall be fully available within ten minutes and shall be in the following categories:
a) Synchronized Reserve - At least one-half of the /
Ten-Minute Reserve will consist of unused generating .
capability which is synchronized and ready to pick up load or generating capability which can be made -
available by curtailing pumping hydro units.
b) Non-Synchronized Reserve - The remainder of the Ten-Minute Reserve may be ccmposed of non-synchronized capability such as hydro, pumped storage hydro and quick start combustion ~ generation which can be syn-chronized and loaded to claimed capability in ten minutes or less.
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- 2. The Thirty-fiinute Reserve portion of the Pool's Operating Reserve Requirement is that portion of unused generating cacability which 4 can and will be made fully available as prcmptly as possible, but in g
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no more than thirty minutes. ---
- 3. Generating capability associated with the delivery of interruptible sales to adjacent pools may be included as Operating Reserve in the category agreed upon by the purchaser.
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ADVANCED PLANNING. SCHEDULING AND C0f1PUTING RESERVE
- 1. Each member shall notify the Pool of its forecasted Operating .
Capability, load, firm transactions and capability loss associated with its worst single contingency. . . _ _ _ . . _ _ _ _ . _ , . _ _
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---2. - The Pool shall notify each member of the Pool's Minimum Reserve Requirement. ,
- 3. Each member shall make every effort to provide its share, as determined --
from table OP 2-A, of the Pool Minimum Operating Reserve Requirement.
- 4. Each member shall schedule the coeration of surplus capability, which is available but not scheduled to run, when called upon to do so 'by the Pool in order to meet Pool Minimum Operating Capability Require-ments. .,
- 5. The Pool shall be respon'ible s for scheduling or purchasir.g sufficient operating capability from neighboring Pools to meet the Pool load and hf
- minimum Operating Reserve Requirements.
- 6. Generating capability which is not available in the prescribed time limits for Ten-Minute and Thirty-Minute Reserve because of response rates or transmission system limitations shall not be credited in meeting the Pool Minimum Operating Reserve Requirement.
- 7. The distribution of both Ten-Minute and Thirty-Minute Reserve on units within the Pool must be such that it can be delivered within the guide-lines specified in the NYPP Desian Standards for Lono Range Planninc and Studies of Short Range 00erating Limits.
- 8. Generating Capability which is restricted for a member's .own use shall not be included as part of the Pool's Operating Reserve and not be included in that member's surplus Operating Capability.
OPERATIONS
, l. The Pool shall monitor the Operating Reserve to assure that it meets
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or exceeds the minimum criteria in this policy. Each member shall keep the Pool informed at all times as to the status and operating limits associated with its generating equipment.
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- 2. When the Pool Operating Reserve is ecual to or exceeds the Pool O
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Minimum Operating Reserve Requirement!, and when a memcer or W
members are deficient, the deficiency will be supplied from Pool excess capaoility. _..
- 3. When the Pool becomes deficient in meeting the TEN-MINUTE RESERVE portion. of the Minimum Operating Reserve Requirement, the SPD
-shall immediately direct the conversion of sufficient THIRTY-MINUTE RESERVE to the TEN-MINUTE RESERVE category to ieestablish
.__ the required level of TEN-MINUTE RESERVE while insuring that the
.. .. required THIRTY-MINUTE RESERVE is maintained.
- 4. ~When the Pool becomes deficient in meeting the THIRTY-MINUTE RESERVE portion of the Minimum Operating Reserve Requirement,
__.the SPD shall immediately direct conversion of sufficient OPERATING CAPABILITY to the THIRTY-MINUTE RESERVE category
. utilizing only that capability which can be converted within Thirty Minutes.
- 5. As soon as it is determined that (i) the conversion to any portion of the MINIMUM OPERATING RESERVE REQUIREMENT cannot be completed in the designated time, (ii) the available '
OPERATING CAPABILITY is less than required to re-establish the minimum OPERATING RESERVE, or (iii) the remaining OPERATING CAPABILITY is energy limit-d and should be with-held if possible, the SPD shall immediately attempt to purchase the required OPERATING RESERVE.
6.. During the shortages of OPERATING RESERVE, the Senior Pool Dis-patcher has the authority to depart from economic dispatch, to utilize reserve pickup, full unit OPERATING CAPABILITY or member
' directed dispatch, as required.
- 7. Emergency Transfer Limit criteria may be invoked to provide trans-mission capability to deliver Operating Reserve to an area deficient in Operating Reserve. The Senior Pool Dispatcher shall notify all mem-bers that Emergency Transfer Limit criteria have been invoked and.mem-bers in the deficient area should be prepared to take all measures up to and including load shedding to return facilities to appropriate ratings within fifteen minutes should such ratings be exceeded.
- 8. When, after Emergency Transfer Limit criteria have been invoked and all available capability, including purchases from neighboring pools or companies has been utili:ed, lead relief attainable by quick response voltage reduction shall be classified as Ten-Minute Reserve.
- 9. If, after the above action, a shortage of Ten-Minute Reserve still exists, the Senior Pool Dispatcher shall direct that load relief ,
procedures be implemented in accordance with NYPP Operating Policy No. 3 - Vol tage Reduction Policy.
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es ACTIVATION OF RESERVE Ten-Minute Reserve shall be maintained or re-established as rapidly as possible subsequent to a disturbance which has initiated a reserve pickup. Sufficient Thirty-Minute Reserve shall be converted to the Ten-Minute Reserve category so that as the pickup proceeds, the Pool
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will not become deficient in Ten-Minute Reserve. This may involve initiating the conversion of Thirty-Minute Reserve to the Ten-Minute Reserve status at the same time the original ' Ten-Minute Reserve is picked up. This will insure that '
the Ten-liinute Reserve will be fully re-established not later than thirty )
minutes after the initial incident.
. When the loss of generation causes the NYPP control error to exceed 3Ld
- it is the responsibility of the Senior Pool Dispatcher to initiate action!
promptly, taking whataever actions are necessary, to insure that the NPCC reserve pickup requirements are achieved. When NYPP reserve pickup is required,
,, one of the following methods will be used: ; .. .
.l. WITH NYPP COMPUTER DIRECTED DISPATCH !
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The Senior Pool Dispatcher will terminate Economic Dispatch and execute the computer programs which determine new basepoints for selected dispatchable units to return the NYPP interchange to schedule. The Senior Pool Dispatchers will notify all members, via the hot-line, that a reserve pickup has beerT init-iated. He will also indicate the required reserve pickup for each member and direct them to move their generation at emergency response rates to achieve the desired pickup. It is the responsibility of the Senior Pool Dispatcher to initiate action to maintain, if possible, or to quickly re-establish Ten-Minute Reserve during and following the reserve pickup. -
Economic Dispatch will be re-initiated as expeditiously as possible.
- 2. WITHOUT NYPP COMPUTER DIRECTED DISPATCH
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The Senior Pool Dispatcher shall direct each member to pick up his pdrtion Q
of the generation deficiency in accordance with Reserve Pickup Table 2-B. .
It is the responsibility of the individual members to initiate actionito maintain or quickly re-establish Ten-Minute Reserve whenever they are or will likely become deficient in Ten-Minute Reserve and to notify the Senior Pool Dispatcher of any resulting deficiencies. ]
To insure that the Pool tiinimum Operating Reserve Requirement is main
, tained during Economy Energy transactions, the buyer must maintain Operating Capability that he is buying against in the same reserve category as that:
from which the seller is selling. The seller must inform the Senior Pool Dispatcher of any reserve category changes so that all categories of Operati.ng Reserve are maintained. .
Upon the pickup of reserve, the Senior Pool Dispatcher will rionitor the NYPP Operating Reserve and take whatever actions are necessary, as set forth in the Operations section of this policy, in order to re-establish the Minimum Operating Reserve Requirement.
AUDITS OF RESERVE RESPONSE -
The Senior Pool Dispatcher, when he deems it ncessary, may direct the As defined in NERC-0C (NAPSIC) Control Performance Criteria
- Sheet 5 of L following types of Reserve demonstrations:
- 1. Selected Unit Resconse - A Ten-Miriute Reserve pickup, a demonstration of l]
y claimed Operating Capacility, or both, may be directed on any unit syn-chronized or non-synchronized claimed .for Daily Operating Capability.
Should the selected unit be unable to demonstrate the amcunt of capability claimed, the Senior Pool Dispatcher shall direct the cwning member to derate. the unit as required. .
- 2. Synchronized Reserve Resoonse - A member may be directed to demonstr$te
. . _ _ . its Syncnronizec Reserve. -
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If a membei~ fails to demonstrate the ability to pickup his portion of
- Synchronized Reserve, the Senior Pool Dispatcher will do one of the following:
a) Instruct the memcer to transfer capability from the Non- l Synchronized or Thirty-Minute category to the Synchronized '
category. A member transferring capability from one categcry i to another is stil'. r t, ligated to maintain his portion of the Pool tiinimum Operatti g Reserve Requirement. ,
s b) If a member fails to demonstrate his Synchronized Reserve l and is deficient, and capability is available fecm other sources, arrangements will be made to purchase capability -
to cover the deficiency. The deficient member will be ob-ligated to take the assigned purchase. -
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- 3. Actual Response - For purposes of measuring NYPP perfomance and the-b@ response of incividual members to d required reserve pickup, selected, audits of actual response to a unit loss will be conducted.
RESERVE REOUIREMENTS WHEN COMMISSIONING NEW GENERATING UNITS i Pool Ten-Minute Reserve may be used to cover the loss of test generatio'n on a non-commercial unit, making it unnecessary for the Installing Ccmpany(fes) to carry additional Ten-Minute Reserve above their normal Pool Requirement.,'
The Operating Capability of a unit on test shall not be included in the Op-
, erating Reserve of the Installing Company (ies) and, therefore, the Installing Company (ies) will be required to carry additional Thirty-Minute Reserve equal to the generation of the unit undergoing test.
When size and output of a non-commercial unit en test increases the Pool's Ten-Minute or Thirty-Minute Reserve Requirement, the Installing Company (ies) will be obligated to provide the additional required reserve.
ALLOCATION
- The allocation of the Pool Minimum Operating Reserve Obligation is contained in Appendix 2-C. ,
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Sheet 6 of 6 .]
NYPP RE5ERVE OBLIGATICN TO NEIGHBORING PCOLE
- 1. NYPP will transfer cacability frcm its Thirty-Minute Reserve to the Ten-Minute Reserve category in order to re-establish the reserve of h) another NPCC Area in a similar category to the tiYPP Ten-Minute. Such Operating Reserve, once established in the Ten-Minute Reserve category, will be made available upon request in ten minutes.
- 2. NYPP will provide Emergency Energy from its Operating Reserve to other ?
NPCC Area to avoid interruption of service in the deficient areas. !
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- 3. When an NPCC Area experiences contingencies in excess of its initial' Reserve response, the Operating Reserve of NYPP may be used to return
'[y the loading of the tiPCC ties to adjacent Pools to normal within a .j ten-minute period. j K
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- 4. When a shortage of Operating Reserve exists throughout tiPCC, availabie energy may be transferred between areas to provide for a proper dis .
tribution of the remaining Operating Reserve. l; I
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- 5. The NYPP Control Center has administrative responsibility for the NPCC ;.
Operating Reserve Policy. '
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AUTHORITY The New York Power Pool Control Center has the responsibility for
. 'Ii administering this Operating Reserve Policy and the Senior Pool Dispatcher has the authority to direct the actions required as set forth above.
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r OPERATING POLICY 52-13 , 'l 1
Acoroved by: y 3
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Central Hudson 9m r j .; .
Niagara Mohawk d vM. L Con Edison . R IN, - . -
.- e LILCO t W - odd- N PASNY Not Required NYSE&G / / Rochester b ' 1 d d.
- i U ~YPP N Operati, nanagerG7 &.D.' . s 2.Y.,P.u ff-b
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AppeEdfx 2-C
.-., ; . . Effectivo: 4/27/80
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NEW YORK PCWER POOL OPERATING RESERVE POLICY ALLOCATION OF REGUIRED OPERATING RESERVE The share of. the Pool Minimum Operating Reserve Requirement obligation :o be allccated to each member ccmpany for the current capability period, shall be determined by multiplying the total ? col res?rve requirement in each catagcry by the ratio of the member's maximum one hcur independent net lead during the last capability period to tne sum of the maximum one hour inde;ancan net loads of each member for the last capability pericd.
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Interrogatory 20 Provide all documents which relate to Consolidated Edison's (Con Ed) policy regarding distribution of operating reserve.
Response
NYPP system operators load Con Edison units on an economics basis considering the Company's operating reserve requirement. Attached is a Con Edison document which describes the Company's spinning reserve policy.
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.h a k4 ' 'S* $ , 7. ',' I , M' %- ' ' 't , s. %M ( *M~r . . , , . gt 5 g.. gg ,) -
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'.d.:,;$.d. l! Operau..n g D w.eci..!ve
. SUDJECT --
LOH. EnISO2i. SPIEMJ.NG RESERVE . # .
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i 1.0 PROCEDUT:E 1.1 All of the con Edison 10 minute spinning reserve (both nynchronired and non-synchronized) shall be.
cariric'd on tho dri c3 ty' unit's only.
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. . . /. . ,e l ,2 At 3 cast one.ba3f of .the. spinning.renerve.shall .
.*. ! '4* be synchronized and carried on the steata units.
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~1.3' ~ The r~cma'inder cc n be non-synchronized jet entyine - -
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. . f type gas turbine units provided their remote start *
. . . . T T T ! U . .cqu.iprann t , i s. A r) service. , ,
- - W 1. 4 Gas turbines shall not b6 ' spinning at rainimum Ibad
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. as.nas been past practices for carrying.npinning. . . _
.: :. : - . reserve. '
2.' :- : :.-
Wheri oh m' ember di'redted or statewide ~ EDC the-
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P: : - - " Operators High"
- 1imit on the Economic Dispatch
! d: * .;;~ :)"RevicQ T Progr.nm ( F.C 1,5 ) shall be Inodified to in- *
- .e c: 7. t ! - .clude'cach unit's share of the spinning rcscrve.
This high limit shall a3so bo used on the Short
- ;- -- ;- Range Transaction- Program- (FC .31). tofrof1cct the. . .
D47;'**.2
- earlier use of gas turbines. .
Tne 2 :j',g e: f5dli dadcN-s1761flentcE ~t60 'Wase'da p acity of jet -
"# C M- ' ' ' - *. %igine type gas turbines units in the computer on -
, FC 0,.pnge 4,. points 143 and 144. .This capacity need not be change 6 as t.he gas turbines come on ,
line, since the computer automatically accounts for them in tho spinnincJ reserve calculation-. .' .
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, Re(c.rc.ncc: - .NYPP OP-2;
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- - - . . . .... ___ - - - = . ._. ... -_.., -. . _ - _ --. -
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- Interrogatory 21 '
t i Provide copies of all agreements between PASNY j and Con Edison related to providing backup support should either utility be unable to meet its customer's require-ments. ,
Response
Attached are copies of the requested agreements.*
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The agreements are based upon the continued availability of !
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both of the Indian Point units.
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4 Copies of these agreements will be made available at Con Edison's offices at 4 Irving Place, New York, New i York, upon request.
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Interrogatory 22 Provide current status of NYPP coal conversion program. In responding to this question utilize pp. 31-36 1 of the April 1981 Report of Member Electric Systems of the NYPP, Volume 1. Identify all changes in plans and schedules since that information was prepared. Specifically, indicate how Table 6 must be changed to redect all units currently i planned for conversion, earliest concersion date, and cost to convert. In your response to this Interrogatory identify all assumptions including any legal requirements, necessary regulatory approvals, and other factors relevant to the j timing and success of accomplishing the conversion.
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Response
Page 12 of the document supplied in response to l '
l Interrogatory 4 lists the 1982 projected schedule for coal conversions. Subsequent to that filing Con Edison has up-i dated its target dates for conversion of Ravenswood 3 and Arthur Kill 2 and 3. The current targets are June 1983 for Ravenswood 3, November 1985 for Arthur Kill 3 and July 1986 for Arthur Kill 2. Con Edison does not have information re-P garding any possible revisions to the coal conversion plans i of other NYPP members.
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Interrogatory 23 Provide an estimate of the approximate down-time required to convert a typical unit.
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Response
The following table lists approximate downtime for Con Edison units in the NYPP coal conversion program.
Net Maximum Duration of j Summer Capacity In Service Conve rsion Units on Coal - Mw Date on Coal Outage
- Ravenswood 3 928 6/83 2 Months j Arthur Kill 3 491 11/85 3 Months
- Arthur Kill 2 335 7/86 3 Months i
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Interrogatory 24 For each oil unit not included in NYPP's conver-sion plan (but for which conversion is technically feasible) provide an estimate of the capital cost of conversion and an estimate of the remaining useful life of the unit.
Response
Con Edison does not have information on other NYPP member utilities' coal conversion cost estimates. In the case of Ravenswood Units 1 & 2, a January 1981 conceptual study estimated that their conversion cost would be approximately S97 million (1980 dollars) for each unit with possible con-version dates of 1990 for Unit 1 and 1991 for Unit 2. The ultimate decision to proceed with the possible conversions will depend largely on the success and impact of conversion of Ravenswood Unit 3, and Arthur Kill Units 2 and 3. Air quality studies af ter conversion of these units will weigh heavily in the feasibility of converting Ravenswood Units 1 and 2. Based on a typical base load unit life of 45 years, Ravenswood 1 & 2 would be retired in the year 2008.
Interrogatory 25 Identify the difficulties and estimate the costs associated with converting boilers not sized to burn coal (i.e., Astoria 6, Bowline 1 & 2, Roseton 1 & 2 and Oswego 5
& 6).
Response
Con Edison has not estimated the costs associated with converting the above-named units to coal.
VERIFICATION STATE OF NEW YORK )
) ss.:
COUNTY OF NEW YORK )
RICHARD P. REMSHAW, being duly sworn, deposes and says:
That he is the Project Manager - Indian Point Hearings for Consolidated Edison Company of New York, Inc., licensee of Indian Point Nuclear Generating Station, Unit No. 2; that he is authorized to make this verification on behalf of said corporation; and that the foregoing answers to interrogatories were prepared under his direction and supervision and are true and correct to the best of his knowledge, information and belief.
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- W RICHARD P. REMSli>Qi Sworn to before me this
/[*cTayofs44, 1982.
Y 0/ .ll(dL(.;)}'f 'u" l f-it N
G N6tary Public PO?I27 S!tYA Nc'ory Pubbe, State of New York No. 8917645 Cwolif+ed in New York County .,
Comemssion bpires March 30,19 .
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Respectfully submitted,
?l10~ .
lThom J. Farr ly i CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
Licensee of. Indian Point Unit 2 <
4 Irving Place New York, New York 10003 l
1 (212) 460-4333 l
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- June 17 1982 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Louis J. Carter, Chairman Dr. Oscar H. Paris Frederick J. Shon
x CONSOLIDATED EDISON COMPANY OF :
NEW YORK, INC. (Indian Point, Docket Hos. 50-247 SP Unit No. 2) :
50-286 SP POWER AUTHORITY OF THE STATE OF :
NEW YORK, (Indian Point, Unit No. 3) :
x CERTIFICATE OF SERVICE I certify that I have served copies of Consolidated Edison's Response to NRC Staf f Interrogatories and Request for Documents on the following parties by deposit in the United States mail, postage prepaid, this 17th day of June 1982.
Docketing and Service Branch Dr. Oscar H. Paris Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Louis J. Carter, Esq., Chairman Washington, D.C. 20555 Administrative Judge Atomic Safety and Licensing Mr. Frederick J. Schon Board Administrative Judge 7300 City Line Avenue - Suite 120 Atomic Safety and Licensing Philadelphia, Pennsulvania 19151 Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
. Janice Moore, Esq. Charles J. Maikish, Esq.
Office of the Executive Litigation Division '
Legal Director The Port Authority of U.S. Nuclear Regulatory New York and New Jersey Commission One World Trade Center Washington, D. C. 20555 New York, New York 10048 Paul F. Colarulli, Esq. Ezra I. Bialik, Esq.
Joseph J. Levin, Jr., Esq. Steve Leipsiz, Esq.
Pamela S. Horowitz, Esq. New York State Attorney Charles Morgan, Jr., Esq. General's Office Morgan Associates, Chartered Two World Trade Center 1899 L Street, N.W. . 'New York, New York 10047 Washington, D. C. 20036 Alfred B. Del Bello Charles M. Pratt, Esq. Westchester County Executive Thomas R. Frey, Esq. 148 Martine Avenue Power Authority of the State White Plains, New York 10601 of New York 10 Columbus Circle Andrew S. Roffe, Esq.
New York, New York 10019 New York State Assembly Albany, New York 12248 Ellyn R. Weiss, Esq.
William S. Jordan, III, Esq. Renee Schwartz, Esq.
Ha rmo n & Weiss Paul Chessin, Esq.
1725 I Street, N.W., Suite 506 Laurens R. Schwartz, Esq.
Washington, D. C. 20006 Botein, Hays, Sklar & Herzberg 200 Park Avenue Joan Holt, Project Director New York, New York 10166 Indian Point Project New York Public Interest Stanley B. Klimberg Research Group New York State Energy Office 9 Murray Street 2 Rockefeller State Plaza New York, New York 10007 Albany, New York 12223 John Gilroy, Westchester Ruth Messinger Coordinator Member of the Council of the Indian Point Project City of New York New York Public Interest District #4 Research Group City Hall 240 Central Avenue New York, New York 10007 White Plains, New York 10606 Marc L. Parris, Esq.
Jeffrey M. Blum County Attorney New York University Law School County of Rockland 423 Vanderbilt Hall 11 New Hempstead Road Washington Square South New City, New York 10010 New York, New York 10012 Donald Davidoff, Director Radiological Preparedness Group Empire State Plaza Tower Building - Room 1750 Albany, New York 12237
Joan Miles Alan Latman, Esq.
Indian Point Coordinator 44 Sunsent Drive New York City Audubon Society Croton-on-Hudson, New York 10520 71 W. 23rd Street, Suite 1323 New York, New York 10010 Richard M. Hartzman, Esq.
Lorna Salzman Greater New York Council on Friends of the Earth, Inc.
Energy 208 West 13th Street c/o Dean R. Corren, Director New York, New York 10011 New York University 26 Stuyvesant Street Zipporah S. Fleisher New York, New York 10003 West Branch Conservation
.- Association Atomic Safety and Licensing 443 Buena Vista Road Board Panel New City, New York 10956 U.S. Nuclear Regulatory Commission Mayor F. Webster Pierce Washington, D. C. 20555 Village of Buchanan 236 Tate Avenue Atomic Safety and Licensing Buchanan, New York 10511 Appeal Board Panel U.S. Nuclear Regulatory Judith Kessler, Coordinator Commission Rockland Citizens for Safe Washington, D. C. 20555 Energy 300 New Hempstead Road Richard L. Brodsky New City, New York 10956 Member of the County Legislature Westchester County David H. Pikus, Esq.
County Office Building Richard F. Czaja, Esq.
White Plains, New York 10601 330 Madison Avenue New York, New York 10017 Pat Posner, Spokesman Parents Concerned Abouc Amanda Potterfield, Esq.
Indian Point Box 384 P.O. Box 125 Village Station Croton-on-Hudson, New York 10520 New York, New York 10038 Charles A. Scheiner, Co-Chairperson Ruthanne G. Miller, Esq.
Westchester People 's Action Atomic Safety and Licensing Coalition, Inc. Board Panel P.O. Box 488 U.S. Nuclear Regulatory White Plains, New York 10602 Commission Washington, D. C. 20555 Dated: June-17, 1982 New York, New York (
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