ML20054H541

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Responses to NRC Interrogatories & Document Requests. Certificate of Svc Encl.Related Correspondence
ML20054H541
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/17/1982
From: Pratt C
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-SP, NUDOCS 8206240185
Download: ML20054H541 (45)


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, asuTED CORRESPONDEmf UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION y 7 ATOMIC SAFETY AND LICENSING BOARD [f Before Administrative Judges:

Louis J. Carter, Chairman Frederick J. Shon Dr. Oscar H. Paris


x In the Matter of  :

, Docket Nos.

CONSOLIDATED EDISON COMPANY OF NEW YORK,  :

INC. (Indian Point, Unit No. 2)  : 50-247 SP

50-286 SP POWER AUTHORITY OF THE STATE OF NEW YORK  :

(Indian Point, Unit No. 3)  : June 17, 1982


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POWER AUTHORITY'S RESPONSES TO INTERROGATORIES AND DOCUMENT REQUESTS PROPOUNDED BY THE NRC STAFF l

ATTORNEY FILING THIS DOCUMENT:

Charles Morgan, Jr.

MORGAN ASSOCIATES, CHARTERED 1899 L Street, N.W.

Washington, D.C. 20036 (202) 466-7000 8206240185 820617 PDR ADOCK 05000247

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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.

3's remaining useful life, assuming that the unit was permanently shut down effective mid-1983. Include in your response to this Interrogatory documents relating to estimates assuming both availability and unavailability of Indian Point Unit No. 2 for the remainder of its useful life.

(b) In your answer to 1(a) above, provide all documents relating to the cost differential for each year impacted 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 and sys,t,em production costs and differential due to changes in capacity expansion plan. ,

(d) Identify the assumptions, data, and documents relied upon in calculating the estimates contained in the documents called for by Interrogatory 1.

RESPONSE

The Power Authority and Con Edison have retained Energy Management Associates of Atlanta, Georgia, to conduct produc' tion cost analyses which will estimate the incremental cost penalty associated with a shutdown of Indian Point Units No. 2 and 3.

The estimates and supporting documentation will be made available upon completion of the analyses.

INTERROGATORY 2 (a) Provide all documents which relate to ' estimates of likely outages to Indian Point Unit No. 3 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 Unit Nos. 2 and 3 were premanently shut down, would the other impacted units (identified 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

(a) The cooling tower settlement agreement has been approved by the New York Public Service Commission and is now in effect. The plants affected by the settlement agreement are l Indian Point, Bowline Point and Roseton. Attachment A presents l

the estimates of likely outages to Indian Point and other impacted units.

(b) If the Indian Point units were permanently l

shutdown, 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 j aareement placed on these units would have been satisfied by selective scheduling of annual maintenance activities which l

would have required outages in any event. Thus, even though the obligation under the settlement agreement to fulfill outage requirements at those stations would be alleviated were Indian Point permanently shutdown, those units would still have to be taken out of service periodically for maintenance activities.

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!.4 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 18 mos./ cycle x 10 yrs. =

13.3 wks.

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i nuclear units, expected forced outages during the " window"'pbriods E

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- I 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 r

2 and 12 weeks for Indian Point 3. Incorporating expected forced outages similar to above results in total outages over the ten l year period of 28.5 weeks for Indian Point 2 and 25.0 weeks for Indian Point 3. Tog 6ther 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" pe riod. 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 refuel.ing 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 methodol'ogies. - s Roseton and Bowline Point units l

1 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 . 4 of each year. Based on present maintenance outage requirements, 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 i during the month of July in each of the first five years of the . '.t 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 [- f unit-days of outages at Indian Point 2 and/or Indian Point 3 o between May 10 and August 10 in addition to the other outages at ..sl these units, increasing the 10-year total outages at these units '* ,;

p, from 420 unit-days to 434 unit-days. i It is expected that ir the Bowline Point July penalty outage j will be in addition to the regular maintenance for these plants, thus reducing Bowline Point 's overall availabilitp by 31 days per l year.

L 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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TABLE I SETTLEMENT AGREEMENT IMPACT OF INDIAN POINT OUTAGES

SUMMARY

TABLE -

Method 1 Method 2 Method 3 Method Refueling Outage Model Generic Probabilistic Standard Modified

' '\q Modifie Determinis tic

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Deterministic De terminis tic "N

Forced Dutage Model Generic Generic Generic Histori h

Weeks of Outage During Spawning Period IP2 IP3 IP2 IP3 IP3 IP2 IP2 IP3 Refueling Outages 13.3-16.7 13.3-16.7 16.0 12.0 24.0 12.0 24.0 12.@

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.@

Total for IP2 & IP3 52.2 -

58.4 53.5 60.7 63.8 Additional Outage 7.8 -

1.6 6.5 0 0 h

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j INTERROGATORY 3 l Provide a copy of your latest submittal to Northeast Power Coordinating Council response to ERA order 411.

RESPONSE

A copy of the requested submittal will be available for i

review at the Power Authority offices, 10 Columbus Circle, New i

j York, New York.

INTERROGATORY 4 -

Provide latest copy of " Report of Member Electric Systems of the New York Power Pool and the Empire State Electric Energy Research Corporation."

RESPONSE

A copy of the requested report will'be available for review at the Power', Authority offices, 10 Columbus Circle, New York, New York. ,

INTERROGATORY 5 Provide all documents which relate to estimates of the decommissioning cost for Indian Point Unit No. 3 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 Interrogatory identify all of the data and assumptions used in developing such cost estimates.

RESPONSE

(a) The Power Authority has, in the absence of a site-specific study, used a study performed for Atomic Industrial Forum, Inc. by Stone & Webster Engineering Corporation entitled " Analysis of Nuclear Power Reactor Decommissioning Costs," dated May 1981 as the basis for its rate treatment of decommissioning expense at the end of the plant's useful life. This study estimated a decommissioning cost for prompt removal and dismantling of $38.64 million ,(in 1980 dollars) for a single model 1160 MWe pressurized water reactor.

This estimate did not include consideration of site-specific or plant-specific characteristics, regional (New York area) labor l costs or contingencies.

l The Power Authority is reviewing the site-specific study performed for Con Edison by Nuclear Endrgy ' Services, Incorporated, particularly as it pertains to Indian Point No.

2, and may update the estimated cost of decommissioning Indian Point No. 3 if appropriate.

l Each of these reports will be available for review at the Power Authority offices, 10 Columbus Circle, New York, New York.

(b) The Power Authority has not performed a specific

( study for premature decommissioning of Indian Point No. 3.

I INTERROGATORY 6 Have any provisions or proposals, such as change in the rate base, been made by the Licensee, its agents or consultants l

l to recover expected decommissioning costs? If so, identify such provisions or proposals and all documents relating to such provisions and proposals.

RESPONSE

The Power Authority has made provision in the Required Reserves component of its Astoria/ Indian Point Project Revenue Requirement to recover the expected decommissioning costs of Indian Point No. 3. The amount included for calendar year 1982 is $2.373 million.- '

Documents relating to the expected decommissioning costs of Indian Point No. 3 are attached. Material irrelevant to Indian Point No. 3 has been deleted.

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l' 1 September 16, 1981 MEMORANDUM TO P. J. PELLEGRINO FROM A. M. LJLLIS

SUBJECT:

Nuclear Decommissioning Revised Cost Estimates:  ;

IP3 M Since 1980, the Authority has made provision in the revenue requirements associated with its two nuclear plants for the collection of future decommissioning costs of those plants. The initial estimations of decommissioning costs were based on a ,

National Environmental Studies Project report sponsored by Atonic Industrial Forum, Inc. (AIF) which was published in 1976. The purpose of this memorandum is to report the results of an analysis based on an updated (1981) AIF study which we have recently received.

The attached schedules show the development of the required annual decommissioning accrual for each plant. Assuming the ,

immediate dismantling alternative, the AIF estimate for decommis-cioning, expressed in 1980 dollars, was escalated at eight percent per year to the anticipated retirement date of the plant to obtair. i estimated costs at retirement. The estimated decommissioning ccsts l are approximately $420 million M for IP3 M ,

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, , The amounts fncluded in the,1980 and 1981 revenue requirements l for the plants were then escalated at ten' percent per year to the retirement date and subtracted from the decommissioning cost estimates. The resultant figure must be collected over the estimated remaining service life of the plant. For purposes of this calcu-lation, an interest rate of ten percent was assumed.

The required annual decommissioning accruals are approximately

$2.373 million for IP3 .

Notwithstanding the uncertainties associated with estimates of decommissioning costs, based primarily on the lack of actual data, ,

these figures tend to support the Budget Department's proposed provision for decommissioning in the 1982 revenue requirements for

  • IP3JEEEEEEF of $2.42 million for each plant. However, in anticipation ,

of customer inquiries for supporting data, it is suggested that the figures documented herein be used for purposes of establishing the j respective revenue requirement for each nuclear plant. >

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cc: Messrs. Hiney, Sinclair, Litchfield, Becker, Clabby, DeGraffenried & Parekh Ms. Caligiuri

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V Estimated Decommissioning Costs : IP3 Immediate dismantling alternative, PWR, NESP estimate per 1981 AIF study:

Estimated 1980 cost:

S 38,640,000 Assume 35 year service life, exclude contingencies.

First year of commercial operation: 1976 Year of anticipated retirement: 2011 Estimated decommissioning cost in 2011 assuming escalation at 8% annually = $419,926,747 S1,500,000 in 1980 A/IP revenue requirement at 10% to 2011 =

28,791,514

$2,201,000 in 1981 A/IP revenue requirement at 10% to 2011 =

, 38,406,134 Net decommissioning. cost in 2011 =

S352,729,099 Estimated remaining service life of plant, 1982 - 2011 = .

29 years Required annual decommissioning accruals i = 10%

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INTERROGATORY 7 If Indian Point Unit No. 2 or No. 3, or both, were permanently shut down in 1983, would replacement 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 necessary to take the place of the Indian Point Unit ('s) . Provide for each identified source of  !

such generation all documents that describe the surrounding environment. Particularly provide those documents which note the description of aquatic and terrestrial biota that might be affected by operation or construction of such replacement f sources.  !

RESPONSE l The Power Authority and Con Edison have retained Energy Management Associates of Atlanta, Georgia to conduct production cost analyses which will estimate the incremental cost penalty associated with a shutdown of Indian Point Units No. 2 and 3.

! Such analyses will also determine the sources which would replace Indian Point generation. The results will be made available upon completion of the analyses.

INTERROGATORY 8

(a) For the year 1980 and, if available, the year 1981 l

i provide the annual fixed charges on the capital investment I

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attributed to Indian Point 3 and any other fixed costs of the utility which are allocable to Indian Point 3 (giving the bases  !

I for their computation), including but not necessarily limited to  !

the following:  !

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1) bond retirement
2) bond interest j
3) payments to state and local jurisdictions (in lieu I of property taxes)
4) state.and local taxes
5) interim replacement allowance
6) property insurr. ice premium
7) nuclear liability insurance premium
8) non-nuclear liability insurance premium t i
9) general administrative costs (excluding fixed l

operation and maintenance costi) l l

10) other fixed costs (specify)

(b) Identify the original book co'st and the pre:ent ,

book cost of Indian Point 3.

(c) In your response to 8.A.4) identify the kinds of state and local taxes paid by PASNY.

(d) In your response to 8.A.9) explain how general administrative expense was determined.

(e) State whether PASNY conducts any nuclear relat'ed planning or research activity not specifically tied with Indian )

Point 3, the cost of such activity, whether that cost was included in general administrative expense, and to what extent the shutdown of Indian Point 3 could be expected to affect that cost. -

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RESPONSE

(a) The Power Authority's responses to this subsection are set forth below.

(1) Dond retirement and (2) Bond interest Payments for bond retirement and bond interest are reported as Total Fixed Costs in Schedule I which is attached.

These payments includes (i) Bond Service, defined under the General Purpose Resolution as, "with respect to Bonds of any series, the sum of interest accruing thereon and,that portion of each principal installment for such series" and (ii) Bond Reserve, defined as "an amount equal to 15% of the amounts allocated to Bond Service."

Such payments are required by t~e n Rate Covenant included in the General Purpose Bond Resolution as follows:

"The Authority shall at all times maintain rates, fees or charges which will produce Revenues in each year s~u_fficient, together with other moneys available therefore, (i) to pay the costs of operation and maintenance of all projects of the

, Authority, (ii) to pay the Bond Service in each year on all Bonds Outstanding as the same

! respectively become due and payable and (iii) to meet the requirements for reserves established by i the Resolution, but in no event shall Revenues l available for Bond Service for a calendar year be less than 1.15 times Aggregate Bond Service for such calendar year."

l L "In addition, the Authority shall annually determine, and shall certify to the Trustee, that it anticipates that it can meet the foregoing covenant. If the Authority is unable to so certify it shall promptly adjust its rates, fees or charges, and take such other necessary action which will be sufficient to comply with the covenant." (Bond Res. , Sec. 609; Seventh Supp.

Res., Sec. 308) l i

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The Rate Covenant also requires the Power Authority to pass all operating and financing costs to rate payers.

Schedule I also reflects the series, issue date, average interest rate and earliest redemption date of l t

$796,281,000 of General Purpose Bonds issued with respect to to  !

l IP-3. l I

1980 and 1981 Fixed Costs for bond retirement and interest were $74,840,000 and $77,700,000 respectively (See Schedule I). -

Schedule I only takes into account bond proceeds used to pay for IP-3 Construction and Improvement costs as of December 31, 1981.

(3) Payments to state and local jurisdictions (in lieu of  ;

i property taxes)- i Properties and income of the Power duthority are exempt from taxation. 1, ,

i However, the Power Authority, did not make any payments, in lieu of property taxes to state or local jurisdictions during the years 1980 and 1981 in behalf of Indian Point 3. There is a state fund which substitutes for Power Authority payments in lieu of property taxes. See Response to Interrogatory Number 12.

i' The Power Authority has made a donation of $150,000 to  ;

I the village of Buchanan for the construction of recreational' facilities and $75,000 to the Verplanck Fire Department to assist in the enlargement of its fire hall.

(4) State and local taxes - The Power Authority's property and income are exempt from taxation. See Item (3) above.

(5) Interim replacement allowance - The cost of Facility ordinary replacements is included in operating expenses and for IP-3 amounted to $23,097 in 1980 and $365,742 in 1981.

(6) Property insurance premium - See Schedule II attached.

, i; (7) Nuclear liability insurance premium - See Schedule'II

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attached.

ll (8) Non-nuclear liability insurance - See Schedule II attached (9) General administrative costs (excluding fixed operation and I

maintenance cost) are as follows: '

, 1 1981 $12,224,000 1980 7,379,000 (10) Other fixed costs - Provision For Reserves From Operating Revenues - i Commencing in 1980, the Power Authority allocated from 0

operating revenues, certain reserves (nonfunded reserve acounts) l for its operating plants. Reserves allocable to IP-3 for:

spent nuclear fuel disposal, plant decommis'sioning and contingent operating and improvement costs for 1980 and 1981 are IL as follows:

1980 1981

,1 Reserve for Spent Nuclear Fuel Disposal $6,634,000 $5,998,000 ll d

Reserve for Decommissioning 2,000,000 2,201,000 i Reserve for Contingent Operating and Improvement costs 3,700,000 10,000,000 Totals $12,334,000 $18,199,00u !

(b) Cost of Indian Point 3 Original book cost - $380,078,000 Present book cost at 12/31/81 - $588,253,000

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The present book cost stated here represents direct construction I costs excluding: interest expense during construction, financing costs and income on investments. The cost includes, i however, expenditures of $17,853,000 relating to the IP-3 Improvement Fund No. 1. 1 I

(c) State and local taxes paid by the Authority. The ,

i Authority's income and its properties are exempt from taxation  !

(d) Determination of general administrative expense -  ;

General administrative expenses represent actual expenses for the general operation and management of Indian Point 3. Such amount includes certain administrative and managerial salaries,  !

l employee fringe benefits for all plant employees, insurance and .

an allocated portion (based on plant generating capacity) of the [

total Headquarters Office expenses (a support f acility to field operations.)

l' NucleEr related planning or research activity not (e) , '

specifically tied to Indian Point 3 .

l Research activities are conducted by the Headquarters  !

Office. Actual expenses paid by the Headquarters Office for I

these activities are charged to the field-Facilities through the l l Headquarters Allocation (referred to in Part D above) and accordingly included in the administrative and general expenses l of the filed Facilities.

l A shutdown of Indian Point 3 is not expected to materially affect the cost of such activity.

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INTERROGATORY 9 Indicate which, if any, of the costs in the Interrogatory 8 will vary from year to year and the amount of decrease or increase, assuming Indian Point 3 continues to operate.

RESPONSE i l

1) Bond retirement - Fixed costs for bond retirement and (2) bond interest for 1980 and 1981 are $74,840,000 and $77,700,000 respectively. These costs increase to a peak of,3114,314,000 in l>

1986 when principal repayments on presently issued the bonds

,- commence. (See Schedule I attached.) * ['

3) Payments to state and local jurisdictions (in lieu of f property taxes) - N/A
4) State and local taxes - N/A

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5) Interim replacements would continue.
6) Property insurance can be expected to increase substantially consistent with prior years experience, as 'the cost of additions and improvements to electric plant increase. (See Schedule II).
7) Nuclear liability insurance can be expected to increase substantially as consistent with prior years experience. (See l Schedule II).

I 8) Non-nuclear liability insurance can be expected to increase i

substantially as consistent with prior years experience. (See l

Schedule II).

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9) General administrative expenses can be expected to increase annually, based on allowances for inflation.

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10) Other fixed costs, including the Provision For Reserves From Operating Revenues can be expected to increase annually, as consistent with prior years experience.

INTERROGATORY 10 Indicate which, if any, of the costs in Interrogatory 8 would cease in the event of a shutdown of Indian Point Unit No.

3 and which, if any, of the costs in Interrogatory 8 would decline, and by what amount if Indian Point Unit No. 3 ceased operation.

RESPONSE

(1) Bond retirement and (2) Bond interest - There would be no reduction in the annual fixed charges for Bond Service and Bond Reserve. These costs would be the same whether the plant continues to operate or not.

3) Payments to state,and local jurisdiction (in lieu of property taxes) - N/A ,
4) State and local taxes - N/A-
5) Ordinary replacement expenses would decline.

6-8) Property and Jiability insurance coverage would have to be maintained although nuclear liability insurance would decrease on a pro rata basis depending upon the term of the shutdown period.

9) General administration costs would decline but the amount of decrease is difficult to assess. After initial shutdown significant costs to maintain shutdown condition (caretaker status) would be incurred.
10) Other fixed costs - Provision For Reserves From Operating Revenues -

If Indian Point 3 is shutdown the reserve for spent nuclear fuel disposal will decline directly in proportion to the shutdown period (as such reserves are a direct fianction' of fuel consumed) whereas reserves for plant decommissioning, and contingent operating and improvement costs would continue at a significantly reduced level.

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INDl AN PolNT - 3 SCHEDUL E I ANNUAL FlXED CHARGES FOR BOND SERVICE (INTEREST AND PRINCIPAL REPAYMENT) AND BOND RESERVE General Purpose Bond proceeds used to pap a portion of Indien Point 3

. Construction & Improvement costs as of December 31, 1981:

EARLIEST AMOUNT AVERAGE REDEMPT10N ISSUED INTEREST DATE PRIOR 57'. S DATE (In Thousands) RATE TO MATURITY

. C 01/20/76 $465,000 9.50% 01/01/86 E 09/21/76 55,000 7.20% 10/01/86

  • F 01/25/77 21,030 6.50% 02/01/87 G 04/27/78 90,000 6.55% 01/01/88 H 10/30/79 51,970 7.895 01/01/89
  • M 11/25/81 113,281

$796,288_

11.455 9.10%

01/01/92 (Weighted Avge. Int. Cost)

I ANNUAL BOND SERVICE AND BOND RESERVE REQUIREMENT (in thousands) 15% TOTAL YEAR BOND SERVICE BOND RESERVE FlXED COST 1980 $65,078 $9,762 $74,840 1981 67,565 10,135 77,700 1982 71,459 10,719 -

82,178 1983 71,459 10,719 82,178 1984 71,459 10,719 82,178 1985 71,d59 IQ,719 82,178 1986 99,404 14,910 114,314 l 1987 '

96,963 14,544 111,507 -

1988 94,797 , 14,220 109,017 1989 93,221 13,983 107,204 1990 91,21l 88,195 13,682 13,229 104,893 [

1991 101,424 1992 86,866 13,030 99,896 1993 85,527 I2,829 98,356 l 1994 55,603 8,340 63,943 1995 26,489 3,973 30,462 1996 26,020 3,903 29,923 1997 25,364 3,805 29,169 1998 24,660 3,699 28,359 - '

1999 24,423 3,663 28,086 j

2000 25,669 3,850 29,519 -

2001 25,549 3,832 29,381 t 2002 24,982 3,747 28,729 2003 24,242 3,636 27,878 2004 23,774 3,566 27,340 -

2005 23,092 3,464 26,556

  • 2006 12,930 1,940 14,870 -

2007 7,802 1,170 8,972 2009 3,223 483 3,1706 n

INDIAN PolNT - 3 SCHEDULE l1 ANNUAL CHARGES FOR INSURANCE 1980 1981 Nucelar Property insurance $2,372,775 $2,814,475 Nuclear Liability insurance 3E9,334 453,144 (Less) Shutdown credits (16,625) *

  • Exclusive of any credit which may 372,709 453,144 be issued by the Nuclear Liability Pools for shutdown in 1981 as such credits are undetermined at this time. '

i

, Non-Nuclear L iabili ty

! Automobile liability 2,514 3,100

, General liability 15,770 26,019

$ 18.384 $ 29.I19 l

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INTERROGATORY 11 Indicate for Indian Point Unit No. 3 the 1980 real property tax payments to the State and the 1980 real property i tax (or in lieu) payments to the following jurisdictions:

Westchester County, Town of Cortlandt, Village of Buchanan, Hendrick 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 Power Authority made no real property tax payments to the State and no real property tax (or in lieu) payments to any of the jurisdictions listed in the question.

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INTERROGATORY 12 Indicate for,the Indian Point Unit No. 3 all payments to the State and to local jurisdictions, other than real ,

property tax and in-lieu payments. In your response to this Interrogatory specifically identify the amount of each payment.

RESPONSE

Under Section 545 of the Real Property Tax Law for the Indian Point No. 3 plant the New York State Board of Equalization and Assessment estimates that State aid will be paid to the Village of Buchanan, Town of Cortlandt, County of Westchester and the Hendrick-Hudson School District. State aid would continue for at least 11 years for the village, 8 years for the Town and County and 10 years for the School District.

Payments began in 1975.

The payments made by New York State during the year 1980 are as follows:

Village of Buchanan - $153,400 Town of Cortlandt - $43,060 County of Westchester - $385,600 Hendrick-Hudson School District - $1,178,875 In addition the Power Authority made a donation of

$150,000 to the Village of Buchanan for the construction of recreational facilities and $75,000 to the Verplanck Fire Department to assist in the enlargement of its fire hall.

INTERROGATORY 13 Indicate for Indian Point Unit No. 3 the number of employees at the site and the number of contractor personnel (security, maintenance) who are regularly stationed at the site. For the former_ group, also indicate the job categories of employees, the residential location of each individual and the 1981 dollar value of each contract. (County level addresses will satisfy the residential location information request.)

RESPONSE

1 The attached table lists the various locations of the Power Authority workers who are assigned to the Indian Point 3 site. Power Authority management personnel are responsible for plant management, administration, technical, professional and secretarial duties required in the operation of Indian Point 3.

Power Authority union personnel duties include plant operation, instrumentation, mechanical and electrical technology operations as well as health physics.

Since 80% of the Crouse (contractor) payroll is paid to the Westchester Building Trades Council and because workers for Crouse are not assigned permanently to the IP-3 site, it was not practical to assign locations to individuals. However, in order to respond as completely as.possible, Crouse has provided an estimate as to the geographical location in which salaries were paid.

Indian Point Unit No. 3 IP-3 Site Contractor Number of Employees Power Authority (Crouse)

Total 362 150 Mgmt 105 Union 182 Security 75 Annual Salary (1980) .

Total $10,147,861 Mgmt/ Security $ 5,259,672 Union (, $ 4,888,789 Contract $4,576,000 .

Residence New York State Dutchess 138 New York City 9 Orange 25

, Putnam 44 l Rockland 7 Sullivan 1 Ulster 1

! Westchester 132 Other 2 Connecticut 0 New Jersey 3 Total 362 150

INTERROGATORY 14 Indicate with respect to operation of Indian Point Unit No. 3 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 purchased in Westchester County, Rockland County and New York City (including New York, Kings, Queens, Bronx and Richmond Counties) are listed below for Indian Point 3. Included are expenditures for equipment, professional and general services, repair, and maintenance, construction, automotive, office supplies, mechanical and electrical material, spare parts, EDP equipment, etc. Not included are expenditures for fuel, legal services, financial services and personal purchases by Power Authority employees, i.e. lunches, gas.

WestchesteR County $2.9 million Rockland County $174 thousand New York City $11.4 million INTERROGATORY 15 (a) Is it physically possible to construct at the Indian Point site one or more coal-fueled facilities generating a total of 1800 Md.

(b) If it would not be possible to locate such coal-fired generating capacity at Indian Point, state whether they 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

(a) Based on a qualitative assessment of the Indian Point site area constraints, it appears that it would not be physically possible to construct one or more coal-fueled facilities generating a total of 1800 MW. Additional engineering and environmental studies would be required to more accurately respond to this interrogatory.

(b) There are no new sites, available that could be used for construction of coal-fueled facilities generating a total of 1800 MW within the 10-mile radius of Indian Point.

Sites for such construction must only have physical attributes required by such generating facilities, but also offer reasonable likelihood of being licensable by the appropriate local, state and federal authorities.

INTERROGATORY 16 3 Using the most recent " capability period," provide the ,

current operating reserve requirement for the NYPP, and indicate the magnitude of each member's share of this requirement.

RESPONSE

Attached is a copy of the New York Power Pool operating reserve schedules for the summer, 1982 capability period.

, ._ -s . . ' o

. .c .

' Issued 4/12/82 Effective 4/25/82 I

, _ NEW ' YORK P

'~

ow ER

. SUMMER 1982 P'OOL - OPERATING RESERVE TABLE OP-2-A C AP ABIL ITY - PERIO D ,

31 R ST '

'ON TI NG ENCY LILCO CO N ED ORU CHGL E NM P NYSEG RGCE NYPP TOT 1000 MIN SYNCH . . -99 237 21 24

  • MAX NON SYNCH 98 199 85' ~ 38 -703

.236. > 20 24 198 64 10 MINUTE RES 197 473 41 48 397 37. - _ 697 30-MINUTE-RES 9e '237 169  :'.75 1400 21 25- 1-90 ' 04 TOT OPER RES~ 295 710 62 73 595 37 70C 253 112 2100

! 1300 MIN SYNCH 92 220 20 " 23 l MAX-NO N-SYNC M 01 210 .10

, .164 79 35 653 l

to MINUTE RES 22 184 70 24 183; 439 -

39 45 368 647 l 30' MINUTE RES 98 237- .157 -

69- 1300.

TOT OPER RES, 20 24 199 64 38 l 281 676 59- 69 567 700 241 107 '2000 1200 M1 N SY NCH 85 203 18 21 1 70 1

' MA X NO N SYNCH 84 202 73 32 602 18 20. 170 72 t o MINUTE RE 5 169 405

  • 36 41 32 598 04 340 145 64 1200 30 TOT -MINUTE-REQ OPER RES 2C3 kt 21 k-7C 7; O2 253 608 .54 62 5 10 217

.,0 C

, 96 1800.

.100 MIN SYNCH . 77 .186 1-7 19 156 MA X-NO N-S YNG;i 77 180 17.,

6 6~ 30 551 10 MINUTE RES, FO 150 00 20 154 .372 33 3a G4S 1 30 MINUTE RE 5, 85 3 12 132 59 1100 202 17 21 1 70 73 TOi OP ER RES 239 574 50 32 600 59 4 82 205 *91 1700 go MIN SYNCH "

70 169' ' 15' 18 '

MAX NON SYNC . 70 169.

142. 61' '27 '5 0 2 15: 17 141- . 60 10 MINUTE RE . '140- 338 30 -

35 .283 26 498 ,

30--M-INUTC RCs 71 160 14 1 2 1- $3 1000 -

TO T OP ER RES e 211 1-7 F42 6C 27 ", 0C 507 - 44 52 425 181 p0 1500 900 MIN SYNCH 63 ~152 14 '

16 ' 128 M.', X-NON-SY NC ; ^ "'

55 24 452 to MINUTE red 126 ~304 * ,27 F27 4 24 440 30 MINUTE RES -71 31 2 66 - 109 r 48 .. 900

.169 - 14 '

17, 142 60 ,:

TO T OP ER .R ES ' 197 473 -41 48 , 397 27 500-169 ~ -

75 1400.

8 00 M I N SY NCH 56 135 12 14 MAX NON SYNCH 1 14 48 22 401 56 135 12 14 1 13 48 10 MINUTE RES 112 270 24 -

28 227 96 21 399

'30-MNOTE RC O 57 F35 43 800 12 13 k-13 49 21

. TO T OP ER RES 169- .405  :; 3 6 ; :- 41 340 400

- 145.- , c ,

1200 700 MIN SYNCH 49 119. '~ 11 C 12' 99 MA X-NON-5YNC;; 40 1-10 tC

.42 .9- 351 -

10 M IN UTE RE S 12 OO 42 {O 040 98 237 21 24 198 30 MINUTE RES 56 135 12 14 84 38 700 TOT OPER RES 114 48 21 400 154 372 33 38 312 132 59 1100 600 MIN SYNCH . . A,, 142 102 a ; .'9 ; 11* B5 :3 6' -

MAX NON SYNCH 2 .

42 ' 101. . .9 2 10 ulb 301 10 MIN UTE ' RE S - 85 36- : 16 299

'84 203' 18- 21 1 70 30-MINUTE-RES' 42 10i  ? 10 85 72'~ * '32 37 000 .

TOT OP ER RES 126 304 10 3OC 27 31 255 109 48 900 ,

500 MIN SY NCH-

. 35 85 8 9 71 30 14

"?.X-NON-SYNCH 35 Ot 7 0 71 00 13 252-10 . MINUTE RES 70 169 , - 15 17 142 60 - 27 0 4,;

30 MINUTE RES . 42 - 101 9. 11 85- -36 500 .

TO T OP ER . RES , 2 '- ~ 112 . 270-L24 16 , 300' 28 227,-

967 -43 800 ,

INTERROGATORY 17 Provide all documents which relate to the NYPP policy regarding distribution of operating reserve.

RESPONSE

Attached is the latest version of the New York Power ,

Pool operating reserve policy, dated December 22, 1981.

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, OP2-13 7 Page 1 of 6 NEW YORK POWER POOL OPERATING POLICY #2-13

SUBJECT:

Operating Reserve Policy APPROVED BY; the Operating Committee on December 17, 1981 to become effective December 22, 1981 SUPERSEDES: Operating Policy #2-12

REFERENCES:

NERC-0C Operating Manual l

MINIMUM OPERATING RESERVE REQUIREMENT The Minimum Operating Reserve Requirement of the New York Power Pool shall be the, sum of:

1. Sufficient Ten-Minute Reserve to replace the operating capability loss caused by the most severe single contingency wjthin the Pool. A single contingency is considered to be a f 9rced outage of generation due to the loss of a generator, ,

bus section, transmission line or transformer.  !

2. Sufficient Thirty-Minute Reserve equal to one-half of the b Ten-Minute Reserve. -

AVAILABILITY AND CATEGORY l .

! 1. The Ten-Minute Reserve portion of the Pool's Ainimum Operating Reserve Requirement shall be fully available within ten minutes and shall be .

in theifollowing categories- t 1 t 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 l

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 composed of non-synchronized capability such as hydro, pumped storage hydro and l

quick start combustion generation which can be syn-chronized and loaded to claimed capability in ten -

minutes or less.

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OP 2-13

  • Page 2 of 6 . l
2. The Thirty-flinute Reserve portion of the Pool's Operating Reserve Requirement is that portion of unused generating capability which can and will be made fully available as promptly as possible, but in 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. i ADVANCED PLANNING, 3CHEDULING 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.

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 detarmined from table OP 2-A, of the Pool Minimum Operating Reserve Requirement.
4. Each member shall schedule the operation of surplus capability, which is available but not scheduled to run, when called upon to do so by i the Pool in order to meet Pool tiinimum Operating Capability Require- '

ments.

5. The Pool shall be responsible for scheduling or. purchasing sufficient operating capability from neighboring Pools to meet the Pool load and g

minimum Operating Reserve Requirements.

6.

L Generating capability which is not available in the prescribed time limits for Ten-Minute and Thirty-Minute Reserve because of response -

" tes 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-flinute Reserve on units within the Pool must be such that it can be delivered within the guide-lines specified in the NYPP Design Standards for Long Range Planning ,

and Studies of Short Range Operating 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.

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l. OPERATIONS 1

i t

1. The Pool shall monitor the Operating Reserve to assure that i.t meets

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i or exceeds the minimJm 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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- OP 2-13 Page 3 of 6 7

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2. When the Pool Operating Reserve is equal to or exceeds the Pool

, Minimum Operating Reserve Requirement, and when a member or i; members are deficient, the deficiency will be supplied from Pool excess capability.

3. When the Pool becomes deficient in meeting the TEN-?11NUTE 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 reestablish 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 i

. utilizing only that capability which can be converted within t 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 OPERATINp CAPABILITY is less than required to re-establish the minimum OPERATING RESERVE, or (iii) the remaining OPERATING CAPABILITY is energy limited and should be with-  !

held if p' ossible, the SPD shall immediately attempt to

.- purchase the required OPERATING RESERVE.

v

6. During tie shortages of OPERATING RESERVE, the Se'nior Pool Dis-patcher las the authority to depart from economic dispatch, to utilize reserve pickup, full unit OPERATIt!G CAPABILITY or member directed dispatch, as required. -

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7. Emergency Transfer Limit criteria may be invoked to provide trans-i mission papability 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 ipcluding load shedding to return facilities to appropriate ratings yithin 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 compapies has been utilized, load 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 OperatingiPglicy No. 3 - yoltage Reduction Policy. ..

l ACTIVATION OF RESERVE lv 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 ca ry so that as the pickup proceeds, the Pool

')P 2-13

. age 4 of 6 .

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-flinute Reserve will be fully re-established not later than thirty g

minutes after the initial incident.

When the loss of generation causes the NYPP control error to exceed 3L

  • d 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 metnods will be used:
1. WITH NYPP COMPUTER DIRECTED DISPATCH 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 been 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 expediticusly as possible.

2. WITHOUT NYPP COMPUTER DIRECTED DISPATCH The Senior Pool Dispatcher shall direct each member to pick up his portion of the generation deficiency in accordance with Reserve Pickup Table 2-B.

L.

It is the responsibility of the individual members to initiate action to 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 Operating Reserve are maintained.

Upon the pickup of reserve, the Senior Pool Dispatcher will monitor the l 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 di. rect the G

As defined in NERC-0C (NAPSIC) Control Performance Criteria

Sheet 5 of 6 following typ::s of Reserve demonstrations:

1. Selected Unit Response - A Ten-Minute Reserve pickup, a demonstration of C claimed Operating Capability, or both, may be directed on an; unit syn-chronized or non-synchronized claimed for Daily Operating Capability.

Should the selected unit be unable to demonstrate the amount of capability claimed, the Senior Pool Dispatcher shall direct the owning member to derate the unit as required.

2. Synchronized Reserve Response - A member may be directed to demonstrate its Synchronized Reserve.

If a member fails to demonst' rate the ability to pickup his porticn of Synchronizeq Reserve, the Senior Pool Dispatcher will do one of the following:

a) Iqstruct the member to transfer capability from the Non-Synchronized or Thirty-Minute category to the Synchronized cqtegory. A member transferring capability from one category to another is still obligated to maintain his portion of the Pool Minimum Operating Reserve Requirement.

b) If a member fails to demonstrate his Synchronized Reserve aqd is deficient, and capability is available from other squrces, arrangements will be made to purchase capability to cover the deficiency. The deficient member will be ob-ligated to take the assigned purchase.

3. Actual Response - For purposes of measuring NYPP performance and the L response of individual members to a required reserve pickup, selected audits of actual response to a unit loss will be conducted.

1 RESERVE REQUIREMENTS WHEN COMMISSIONING NEW GENERATING UNITS Pool Ten-Minute Reserve may be used to cover the loss of test generatio'n on a non-cognercial unit, making it unnecessary for the Installing Company (ies)~

to carry additional Ten-Minute Reserve above their normal Pool Requirement.

The Operating Capability of a unit on test shall not be included jp the.0p-erating(Reserve Company ies) willof bethe Installing required Company to carry (ies)Thirty-Minute additional and, therefore, the. Installing Reserve-equal to the generation of the unit undergoing test.

When size and output of a non-commercial unit on test increases the Pool's Ten-Minute or Thirty-Minute Reserve Requirement, the Installing Coinpany(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.

~- __

4-13

. .ineet 6 of 6 -

NYPP RESERVE OBLIGATION TO NEIGHBORING P0OLS

1. NYPP will transfer capability from its Thirty-Minute Reserve to the Ten-Minute Reserve category in order to re-establish the reserve of g' another NPCC Area in a similar category to the NYPP Ten-Minute. Such Operating Reserve, once established in the Ten-Minute Reserve category, w be made n1 Pab'e :r::n ecuest i n ter minutes.

4

1. NYPF will provioe Emergency Energy from its Operating Reserve to other NPCC Area to avoid interruption of service in the deficient areas.
3. When an NPCC Area experiences contingencies in excess of its initial Reserve response, the Operating Reserve of NYPP may be used to return the loading of the NPCC ties to adjacent Pools to normal within a ten-minute period.
4. Wnen a shortage of Operating Reserve exists throughout NPCC, available energy may be transferred between areas to provide for a proper dis-tribution of the remaining Operating Reserve.
5. The NYPP Control Center has administrative responsibility for the NPCC Operating Reserve Policy.

A_UTHORITY The New York Power Pool Control Center has the responsibility for acministering this Operating Reserve Poli.cy and the Senior Pool Dispatcher has the authority to direct the actions required as set forth above. g L. - .

OPERATING POLICY #2-13 -

Approved by: ,-

. m

) .g Central Hudson 0 kr . 1

.. Niagara Mohawk M 'j/t./ . j Con' Edison . 0&R I .(, - .

j ) - -

LILC0_ u e d N PASNY Not Required ,

NYSE&G 2 -

Rochester d d.

NYPP Operat anager / h .d$.. j h U'. >

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INTERROGATORY 18 Provide all documents which relate to the PASNY policy regarding distribution of operating reserve.

RESPONSE

With the exception of Astoria #6, all Power Au'thority units are hydro or nuclear which are either operated to maximize use of available water, or are base loaded at full output to minimize fuel costs, and therefore are not normally utilized for operating reserve purposes. Astoria #6, as normally dispatched, usually runs at less than full load for economic reasons. Con Edison can utilize the available output from Astoria #6 to meet its operating reserve obligations. Because the Power Authority coordinates the operation of its system with the other member utilities of NYPP, the Power Authority will operate the Blenheim-Gilboa pumped storage units to help meet rapid statewide load changes and to help; mcompensate for the loss of generation and/or transmission facilities within NYPP. Theh'werAuthoritywill o

j also deviate from optimum operation at its Niagara, St.

Lawrence, and Blenheim-Gilboa projects in order to assist operation of the NYPP statewide system during system emergency

( conditions.

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POWER AUTHORITY OF THE STATE OF NEW YORK .

10 CoLuusus CincLE New YORK. N. Y.10019 (2126 397 62oo e vnustase GE0",CE,[g

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, ces, sOww s.OvsON cosa se mass "" ' "

E hCu t V CE rue 80Cscuote CEORM L. MW r vice cualema88 J,,,,g ,,,ggggggg, m6 CHARD M. PLYNN a n scutavt vice moegny g MILLONIl i

kmate LcROY W. SINCLA

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March 26, 1982 ,,0,,o. ,ecv

""':*l.i;"'.'s*l"'

Mr. Lester Stuzin Executive Deputy to the Chairman New York State.Public

~

. Service Commission 3 Rockefeller State Plaza Albany, New York 12223

Dear I.es:

Last summer Chairman Gioia sent Chairman Dyson a memorandum prepared by his staff summarizing the results of a Reliability Study performed by a consultant to the Department of Public Service, Power Technologies, Inc. ,

t (PTI). Our staff has carefully reviewed the PTl report '

and participated in the preparation of the comments which were sent to you last fall by the New York Power Pool  ;

. (NYPP) member codipanies.  !

With respect to the Power Authority, PTl mentions.

~

In its report the fact that the Power Authority is not a full participant in all of the transactions which occur under the NYPP agreement, noting in particular the operating reserve p'olicy. PTI addresses the issues of policies, procedures, and practices which the Authority will follow in implementation of the planning and operating criteria set forth by the NYPP member systems in compilance with the directives of the PSC.

The Power Authority buys and sells power under ,

separate contracts with its utility customers and through these contracts we are able to provide available capacity for use both in normal operations and in response to requests for operating reserve. For example, through the use of an alarm device in the control room in our Astoria No.6 unit, we are able to increase 9eneration at the request of Con Ed8 s power dispatcher in the same manner as Con Ed does at its own generating plants.

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.l Mr. Lester Sturin

Executive Deputy to the Cha i rman .

New York State Public d

Service Commission 2-4 We recognize the adequate operating reserve,impor tan,ce of mawith particularly inta the ining planned increase in Imports of energy f rom Hydro Quebec over our 765 KV Interconnection. As you know, '

the Power Authority has been seeking a license from the Federal Energy Regulatory Commission to construct -

a pumped storage hydroelectric plant at Prattsville, which among to'her things would enhance our a'bflity to absorb and provide large quantitles of energy f rom flydro Quebec increased operating flexibility,

' i Wethat to ensure willour continue plants to work.wlth continue to bethe other utlittles opeaated in a manner which maximizes the reliability of the power supply and makes the best use of these valuable resources.

tracts The subject of is a complex the one andPower Authority's power non- '

a meeting with you or other appropriateI would be happy to set up I

Individuals at the PSC to discuss this setter in detall.

1~

, S i n ce're.l y , '

l Robert A. H!ney l' Senior Vice President RAH:Jb Planning & Harketing

'l bec: Messrs. KIcInski, English, Haase I

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INTERROGATORY 19 PASNY indicates no installed reserve criterion for its hydro units and indicates special reserve policies associated with thermal facilities (see footnote to Exhibit 3, page 36, Volume 2 of the NYPP Report of Member Electric System, 1981).

In the absence of a specific overall reserve policy:

(a) How does PASNY characterize its level of reliability?

(b) How does PASNY plan for the installation of additional facilities?

(c) How does the lack of a firm policy impact PASNY's relationship with other members of NYPP?

RESPONSE

(a) Installed reserve requirements of the member utilities in NYPP are determined on a Pool b5 sis'by reliability  ;

studies which includ,e-. the Authority's generating units and load. Because of its large amount of hydro' capacity, the Power ,

Authority's generation capability is generally more reliable than that of other member systems within NYPP, and provides the l

effect of reducing the reserve requirements of the other member i

utility systems in NYPP from what they will be in the absence of l

the Power Authority's hydro capacity. Therefore the Power Authority characterizes its level of reliability as at least' equal to that of the member systems of NYPP.

(b) As stated in the referenced NYPP 5-112 report, the Authority will provide installed reserves of approximately 18%

for each new thermal unit by restricting firm contract sales l

from the unit to about 85% of its net installed capability. In this manner, the Power Authority is planning to provide for the  :

1 installation of adequate installed reserves in conjunction with l the installation of additional generating capacity. l (c) The New York Power Pool Agreement clearly defines i

how the member company purchases firm capability from the l Authority and how the member will treat such capability for the purpose of implementing the installed reserve policy defined in the agreement. The structure of its contracts provide the l

Authority with a firm policy on installed reserves which is consistent with that of other member systems.

INTERROGATORY 20 i Provide copies of all agreements between PASNY and Con Ed related to providing backup support in the event that either I utility cannot meet':its customer's requirements.

RESPONSE

i l The following voluminous documents will be available t

I for review at the New York Offfice of the Power Authority, 10 Columbus Circle, New York, New York: The " Contract for the Sale of Power and Energy to Consolidated Edison Company of New York, ,

Inc. from Astoria 6 Unit and Indian Point 3 Unit," dated 1

December 30, 1975. Article III of this document addresses the backup support Con Edison is required to provide to serve Authority customers when either or both of these units are out of service. f l

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3 Contract UD-2 "For the Sale, Transmission and, ,

Distribution of Power to Consolidated Fdison Company'of New s , ,

\

York, Inc.". This contract which provides for I "'

the sale of power to con Edison from the Authority's J.A.

FitzPatrick Nuclear Power Plant, includes an agreement. which s

provides for backup support to the Authority during outages of this plant. ,

" Contract For the Sale of Imported Power and Energy to i

consolidated Edison Company of New York, Inc.". This contract s

which provides for the sale to con Edison of power pt5N.hased by the Authority from Hydro Quebec includes arrangements'for

[g

emergency assistance of either party (Special Provision A) .

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i Respectfully sub'mit ed;

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WN . Wutt .

CHARLES.M. PRATT" -

Assistant General Counsel, 3 3

POWER A0TRORITY OF THE i STATE 6FsNEW i'OPK ,

10 Columbus Circle .

New York, ! Jew York 10019i'

.i (212) 397-6200 -

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UNITED STATES OF AMERICA  :

NUCLEAR REGULATORY COMMISSION 4

., +

A

, TOMIC SAFETY AND LICENSI.MG BOARD ,

n Before Administrative Judges:

Louis J. Carter, Chairman (b d Dr. Oscar H. Paris -

Frederick J. Shbn .

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__ __ __--- -x CONSOLIDATED EDISON COMPANY OF  : Docket Nos. 50-247-SP NEW YORK, INC. (Indian Point, 50-286-SP Unit No. 2)  : ,

i POWER AUTHORITY OF THE STATE OF  : ,,

liEW YORK, (Indian Point,  ! j Unit No. 3)  : -

_________________________________x ,

CERTIFICATE OF SERVICE' .

I certify that I have served copies of the " Power (

Authority's Responses to Interrogatories and Document Requests

- Propounded by the NRC Staff"on the following parties by deposit ,

in the United States mail, postage prepaid, this 17th day of ,

June, 1982.

l.

Docketing and Service Branch Dr. Oscar H. Paris Office of the Secre'tary Administrative Judge .  :

U.S. Nuclear Regulatory Atomic Safety and Licensing .'

Commission Board

Washington, D. C. 20555 U.S. Nuclear Regulatory Commission l Louis J. Carter, Esq., Chairman Washington, D. C. 20555 Administrative Judge Atomic Safety and Licensing Mr. Frederick J. Shon  ;

Administrative Judge f Board 7300 City Line Avenue - Suite 120

~

Atomic Safety and Licensing ~

Philadelphia, Pennsylvania 19151 Board .

U.S. Nuclear Regulatory Commission Washington,.D. C. 20555

i ,

Janice Moore, Esq. Charles J. Maikish, Esq.

Office of the Executive Litigation Division  :

Legal Director. Thf 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, E5q.

r Joseph J. Levin, Jr., Esq. Steve Leipsiz, Esq. , I Pamela S. Borowitz, Esq. New York State Attorney l Charles Morgan, Jr., Esq. General's Office i Morgan Associates, Chartered Two World Trade Center i 1899 L Street, N.W. New York, New York 10047

{

Washington, D. C. 20036 i

Alfred B. Del Bello i

' 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 ~~

l 10 Columbus Circle Andrew S. Roffe, Esq.

l New York, New York 10019 New York State Assembly  !

l Albany, New York 12248 l ,

Ellyn R. Weiss, Esq. )

William S. Jordan, III, Esq. Renee Schwartz, Esq.

Harmon & Weiss , Paul Chessin, Esq. i 1725 I Street, N.W., Suite 506 Laurens R. Schwartz, Esq. q Washington, D. C.. 20006 Botein, Hays, Sklar & Herzberg  ;

200 Park Avenue j 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 l Albany, New York 12223 ll n

John Gilroy, Westchester Ruth Messinger d

Coordinator Member of the Council of the f Indian Point Project City of New York 0 New York Public Interest District #4 f Research Group City Hall .

p 240 Central Avenue - New York, New York 10007 -

~

White Plains, New York 10606 - l l- 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 l o

~

l I .

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 1828 New York, New York 10010 Richard M. Hartzman, Esq.

Lorna Salzman -

Greater New York Council on Friends of the Earth, Inc.

Energy i >'< -

.208 West 13th Street c/o Dean R. Corren, Director New York, New York *10011 New York University 26 Stuyvesant Street 2ipporah 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 Pat Posner, Spokesman -

Parents Concerned About ,

Amanda Potterfie'ld, Esq.

Indian Point Box 384 P.O. Box 125 Village Station Croton-on-Hudson,'New York ,10520 New York, New York 10038 ,

T Charles A. Scheiner, Co-Chairperson Ruthanne G. Miller, Esq. I Westchester People's Action Atomic Safety and Licensing l Coalition, Inc. -

Board Panel  !

P.O. Box 488 U.S. Nuclear Regulatory ",

White Plains, New York 10602 Commission i Washington, D. C. 20555 Dated: June 17, 1982 New York, N.Y.

u W niMa / 7j

' JENNIFER G.MOLSON

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