ML20073G396

Testimony of GL Fitzpatrick on Commission Question 6 Re Energy,Environ & Economic Impact of Shutdown of Units 2 &/Or 3.Certificate of Svc Encl.Related Correspondence

ML20073G396
Person / Time
Site:	Indian Point
Issue date:	04/12/1983
From:	Fitzpatrick G CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
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ML20073G302	List: ML20073G301 ML20073G311 ML20073G341 ML20073G363 ML20073G375 ML20073G396
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ISSUANCES-SP, NUDOCS 8304180275
Download: ML20073G396 (49)

Text

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UNITED STATES OF AM tC933 A10:36 NUCLEAR REGULATORY CCM.25$10 ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P. Gleascn, Chairman Fredrick J. Shon Dr. Oscar H. Paris

)

In the Matter of )

)

CONSOLIDATED EDISON COMPANY OF )

NEW YORK, INC. ) Docket Nos.

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

) 50-286 SP

)

)

POWER AUTHORITY OF THE STATE OF )

NEW YORK ) April 12, 1983 (Indian Point, Unit No. 3) )

)

LICENSEES" TESTIMONY DE_DERBGE_L._ELIZEAIBIGK_,gN_GQMMI@@lgN_QUESI1QN_6 ATTORNEYS FILING THIS DOCUMENT:

Brent L. Brandenburg Charles M. Pratt CONSOLIDATED EDISON COMPANY POWER AUTHORITY OF THE STATE OF NEW YORK, INC. OF NEW YORK 4 Irving Place 10 Columbus Circle New York, New York 10003 New York, New York 10019 (212) 460-4600 (212) 397-6200 8304180275 830412 PDR ADOCK 05000247 T PDR

6 IABLE_OE_CONIEllIS PAGE INTRODUCTION 1

! PURPOSE OF TESTIMONY 4 CONSIDERATION OF CONSERVATION I BY NYPP - SECTION I 6 NY ENERGY PLANNING BOARDS CONSIDERATICN OF CONSERVATION

- SECTION II 11 DISCUSSION OF FREE MARKET VS. SUBSIDY-INDUCED CONSERVATION

- SECTION III I4 DISCUSSION OF NYPSC CASE 28223

- SECTICN IV 18 l

t CRITQUE OF ESRG'S DEMAND I

GROWTH PROJECTIONS

- SECTION V 28 APPENDIX A - RESUME OF GEORGE L. FITZPATRICK 37 APPENDIX B - FEA APPLIANCE EFFICIENCY TARGET COMPARISON 42 APPENDIX C - MAXIMUM POTENTIAL IMPACTS FOR SIX RESIDENTIAL l

MEASURES 43 I

T D D #

4 INIBooyCIICU My name is Gecrge L. Fitzpatrick. My businers address is 11 East 44th Street, New Ycrk, New York 10017.

I currently serve as President of Applied Energy Group, Inc., a management and technically-oriented consulting and software development firm offering services in the areas of Load Research, Load Management, Load and Energy Forecasting, and Economic Evaluations. -

Prior to this, I held the position of Vice President, Load l Research and Demand Planning for Stone and Webster Management Consultants, Inc. I was responsible for the coordination and I direction of consulting activities in the Load Research and Load I

Management areas within the Corporation. Additional responsibilities included analyses of data processing requirements and potential new markets for consulting activities.

My utility-based experience consists of nine years with Long i

Island Lighting Company where I held the position of Manager,

Load Research, Costing and Forecast Division. My prime responsibilities centered on electric peak and energy forecasts; electric and gas weather normalization; statistical sample design development; load research study implementation; load data

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1 management and analysis; annual population survey; all long-range demographic projections; the collection, processing, and overall <

supervision of billing of customers under commercial / industrial time-of-use rate; the electric class of customer annual system i load research study; and all statistically-based studies I

performe~d by the Economic Research Department. In 1978, my

, responsibilities were expanded to include fully allocated and marginal cost-of-service studies for electric and gas and total factor productivity studies.

I My academic background includes a Bachelor of Arts Degree in Economics with a concentration in Statistics as well as a Master of Business Administration Degree in Economic Theory, both frcm St. John's University. I have had additional erperience in the area of application of various statistical techniques for forecasting and descriptive analyses purposes. 'Through my l utility-based experience and continuing education, I have acquired additional expertise in the utilization and I

interpretaticn of stati sti cal techniques such as logistic function fitting, two and three stage multiple regression, Box-Jenkins stochastic and multi e transfer functions, and multiple regression techniques for time series, cross sectional, and pooled data bases.

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I have also had additional formal training in the areas of engineering economic analysos as well as data processing systems and applications.

I have testified as an expert witness on subjects such as electric and gas, peak and energy forecasts, load research studies for cost-of-service anal ysi s, load manageoent, conservation, cogeneration, and statistical studies for weather normalization of gas sendout and electric energy requirements data in the following New York State Public Service Commission proceedings: Case Numbers 26733, 26829, 26985, 27136, 27154, 80003, 27319, 27374, 27375, and 23223.

I have presented testimony on behalf of the Member Systems of the New York Power Pool on the subjects of load forecasting, energy conservation and economic analysi s in the New York State Energy Master Plan II Proceedings. I have also presented forecasts, conservation and economic analyses on behalf of the Power Authority of the State of New York (the Authority) in connection with the Arthur Kill Coal /RDF Facility Corps of Army Engineers Proceeding.

A more detailed presentation of my qualifications is presented in Appendix "A" to my testimony.

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O EUEEOSE_OE_IESIldCdy The purpose of my testimony is as follows:

I. To provide a discussion of the Member Systems of the New York Pool consideration of the future impacts of Conservation in the most recent State Energy Master Plan II proceeding.

II. To provide information on the New York State Energy Office's consideration of conservation in thei: formulation of the latest State Energy Master Plan.

III. To give an indication of the extent to which both price and non-price induced conservation has .already penetrated the marketplace via the free market forces, l utility programs and regulatory endeavors.

IV. To provide an update on the progress of the New York

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i Public Service Commission's latest investigation into the conservation issue as addressed in Case #25223 from a Con Edison perspective, and to provide preliminary information on the peak demand and annual energy impacts of the following residential conservation devices for the Con Edison service territory:

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a) Refrigerators (manual and auto defract) b) Residential room air conditioners c) Residential lighting d) Residential water heating measures (water heating blankets, lon flow showerheads, and heat pump water heaters).

Additionally, I will provide an extrapolation of those results to the Power Authority-served southeast New York residential households.

V. To demonstrate that the High Impact, Mid Range, and Low Impact economic scenarios presented by ESRG in a study entitled "An Analysis Of The Need For And Alternatives To The Proposed Coal Plant at Arthur Kill" (ESRG 81-21) are not the most reasonable for an objective assessment of the total j costs of the shutdown of the Indian Point plants since l

certain components of that ESRG study are either statistically suspect er have been selectively utilized to yield downward-biased cost projections. My analysis of the ESRG Report entitled "The Economics of Closing the Indian 1

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Point Nuclear Power Plants" will necessarily be abbreviated due to my clients' belated receipt of this document.

I. CONSIDERATICM OF CONSERVATICN 3Y THE MEMBER SYSTEMS OF THE NEW_yg85_8QhE8_89GL_ly_IHgl8_NEW_YQ88_SIGIE_gUg8Gy_USSIE8_E680_Il 59B015S1003 As part of my work for the New York Power Pool in the State Energy Master Plan II Hearings, I had the opportunity to review the major conservation f orecasts of the State's eight maj or electric utilities including Con Edison and the Power Authority.

This review encompassed both the investigation of the assumptions contained in the Report to the New York State Energy Office pursuant to Section 5-112 of the New York State Energy Law for each of these utilities as well as follow-up conversations with forecasting personnel at each company. As a result of my investigation, I concluded the following:

1) The Member Systems of the New York Power Pool had accounted for the DOE major appliance efficiency targets and corresponding per unit energy reductions in their "most likely" load and energy forecasts. Conversely, my analysis of ESRG's statewide forecast of conservation potential in that same proceeding showed that ESRG had improperly reflected the 1980 FEA Appliance Efficiency Targets in their

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4 projection. (See Exhibit GLF-6 of my SEMP II Rebuttal Testimony which is Appendin B to this testimony).

2) The Member Systems of the New York Pool had employed reasonable projections of f uture increases in the real price of electricity, thus insuring reasonable decreases to the "most likely" forecast for price related conservation responses. These real price projections accurately reflected the official SEMP II capacity expansion plans.

3) The Member Systems of the New York Power Pool have given sufficient, and perhaps optimistic consideration for the potential of conservation measures and strategies in their "most likely" peak load and energy forecasts. The following items, which have been included in the utilities' forecasts, are examples of this consideraticn.

A) Incorporation of the DOE 1980 Appliance Efficiency Targets -

Although these targets are no longer mandatory from either a state or federal perspective, the Member Systems have made the assumption that such targets will be achieved or exceeded in the future appliance stocks in their respective service territories. The appliances that are affected by these improved efficiency targets are:

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Original CCE Proposal For Per Appliance EOeC9Y_Bgdyctigg_*f Central Air Conditioning 17 Window Air Conditioner 22 Water Heater 15 Clothes Dryer 4 Clothes Washer 26 Range 3 Refrigerator (Frost Free) 29 Refrigerator (Manual) 33 Freezer 22 Dishwasher 20 Color TV 35 Black & White TV 65 l

Recognition of these or greater forecasted per unit l

l energy reductions for improved appliance efficiencies has served to greatly reduce the Member System's future 1

I load projections.

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s B) In the commercial sector, the Member Systems have reduced future forecasts for the impacts of conservation measures in this sector. As an example, Con Edison has forecast saturation of Load Limiting Devices of more than 70% in its service territory by the year 2000 and has lowered both its peak and energy forecasts accordingly. The percent reduction utilized by Con Edison in their f orecasts is based upon actual Con Edison experience, and from my review, appears quite reasonable.

Con Edison has also included other conservation related reductions in its "most likely" forecast:

1) Assumed increasing use of load management techni ques in response to rate structure changes (which affect energy as well as peaks).

2) Included a "non-cost-effective" conservation forecast reduction amounting to approximately 5% in 1995 and 7% in 2000. This reduction is separate from

" price related" conservation captured by Con Edison's econometric model and other cost effective measures such as the appliance efficiency improvement energy reduction.

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The following is a representative list of the additional measures included in various degrees by some or all of the Member Systems:

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a)- Time of use rate implementatien b) Movement towards marginal cost pricing policies

'c ) Continuation of programs to provide consumers with

information on types of conservation measures and their i

savings potential

d) Storage rates i

e) Interruptible rates I f) Energy audits g) Weakherization financing i

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I i Thus, in my opinion, Member Systems of the New York Power Pool have made a reasonable acccunting for conservation in i

their long range plans.

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lis__ tug _UgW YORK STATE ENERGY PLANNING BOARD'S CONSIDERATION CF L

GGUEEBMBIIOtl IN THg_ FINAL _SgMP_II REPORT For its part, the New York State Energy Planning Board has made conservation the corner, stone of its overall icng-term energy policy as em' bodied in the State Energy Master Plan II Final Report. On page 5 of the Executive Summary of SEMP II, there is a discussion of the role of conservation in the official state-load and energy forecasts.

"The forecasts reflect significant conservation resulting from rising energy prices, mandated efficiency standards and state conservation programs

now underway. They consider, in a systematic manner,

! the interrelationships of economic activity, fuel prices, national and state energy policies, fuel I

j substitution, conservation and renewables, as well as .

4 the availability of conventional fuels."

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. Thus, both the Member Systems of the State of New York Power Pool l

and the New York State Energy Planning Board have given major consideration to the future impact of conservation on energy demand in New York State.

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Two parties (Environmental Planning Lobby and the New York City Energy Office) sponsored forecasts of conservation potential prepared by Energy Systems Research Group (ESRG). The two studies are:

"An Analysis Of The Need For And Alternatives To The Proposed Coal Plant At Arthur Kill",'(ESRG 81-21), June 15, 1981.

and "The Conservation Investment Alternative For New York State" (ESRG 80-42) September, 1981.

These analyses presented scenarios for conservation both from a downstate (Con Edison - Power Authority (SENY)) and statewide perspective. These studies were, in ESRG's own words, "...not i

offered as a blueprint for immediate program action over the next 20 years" but, rather, "to show...one choice of plausible target l

conservation levels in order to test the proposition that conservation could feasibly play a maj or role in the State. . . "

(ESRG 80-42, page 4).

It is clear from the above, therefore, that ESRG never intended 1

their analyses to be utilized as an official planning document (as both the Member Systems and the SEO did intend theirs to be) and that it is inappropriate for ESRG to utili=e such methodologies and assumptiens in the presentation of High Impact, Mid Range and Low Impact Effects on Ratepayers for the early retirement of the Indian Point 2 & 3 plants.

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l IIIs__8_QIgGUggIQU_QE_IHg_QIEEEEgMCES BETWEEN FREE MARKET-INDUCED GONSEBYSI1ON_YS. -SUESIDY-1dDUGED_G9dEEBYBI198 i

Generally speaking, " price-induced censervation" would be the

! conservation of energy either by reduction in intensity of use of appliances or changes to more efficient appliance stocks that would be caused by increases in the real price of electricity l

either through the "real" or " perceived real" increases in the price of electricity. Non price-induced conservation can be thought of as conservation induced by subsidy programs based upon L the active intervention of utilities, regulatory authorities, or government. While price-induced conservation will usually affect the intensity of use for the short run and appliance decisions in the long run, non-price induced conservation would be directed at 1

altering appliance decisions only.

" Intensity of use" conservation can be thought of in terms of short-run price elasticity, that is, a consumer's short-run

! response to a "real" increase or a " perceived real" increase in the cost of energy. In this type of conservation response, a l

consumer alters his utilization of existing appliances or end uses such as reduction of lighting in the home, lowering of heating thermostats, or raising of air conditioning thermostats, l

lowering water heater temperature, etc.

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" Appliance decision" elasticity is more of a long-run response.

Literature indicates that such long-run elasticity may take between 5-7 years before it is fully effective, and such resulting energy reductions are usually of greater magnitude than short run impacts. Economic theory suggests that consumers will opt for more efficient and, thus, less energy consuming appliances and end uses in some direct relationship to the increase in the real price of electricity over time. The quantification of such a relationship is called the " price elasticity of demand" response.

Economic analysis performed by the utilities, the State Energy Office and others indicate that the potential for price induced conservation (f rom free market f orces) is quite significant.

Based upon AEG's anal ysi s of the six residential conservation measures for Con Edison as part of Case 29223 and further investigation of relevant portions of Con Edison's "most likely" long-range forecasts, " price-induced" impacts are expected to account for conservatively 67% of the total achievable impacts for the measures studied.

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1 During the Energy Crisis of 1973-74, consumers made dramatic efforts to save electric energy. Realistically, these shcrt-term savings came primarily from consumers' alteration of energy usage l

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appliances with a more efficient variety.

I Little is known abcut the potential for the_ " replacement"

. phenomenon that may occur if consumers substitute appliance

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decision conser,vation for' intensity of use conservation. That i s, it is conceivable that as consumers opt for more efficient appliances in the future, usage patterns that had been modified in the short run may revert to more traditional comfort and usage l

! levels as more efficient appliances come on line. Thus, caution must be exercised in assuming that short run intensity of use conservation is a lasting condition. Rather, it may be a temporary phenomenon until the longer run appliance decisicn

conservation takes effect.

1 Essentially, while some parties view conservaticn in a total impact sense, the utilities add the sophistication that there is a cost effective or free market-accessible portion of that I conservation, and consequently, there may be a subsidy induced portion for the more marginal conservation measures and markets.

It is extremely important to make the distinction between free market conservation and subsidy produced conservation, since such a distinction is critical to the overall evaluation of the economic feasibility of such measures. For example, if one were to postulate a $100 million program to assist New York State residents in replacing current refrigerators with 50% more

efficient refrigerators, the resultant cost benefit analysis wculd prcpose to view the $100 million as a cost and the total kWh savings of the 50% more efficient refrigerators as the benefit. However, the true perspective would be to discount the 50% benefit by that benefit that would have occurred in any case due to both:

1) Consumer's reaction to higher electricity prices.

2) The availability in the marketplace over time of a lower level efficiency refrigerator (that is currently estimated to be, on average, 33% more efficient).

Thus, a total percentage gain from the $100 million subsidy investment would be (50% - 33%) 17% not 50%. It is clear from the foregoing example that an accurate realistic view of the timing and the total impact of the " free market" forces is necessary if conservation subsidies are ultimately ordered by the PSC as a result of Case 28223.

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IVz__6.. DISCUSSION _CF THE FURTHER CCNSIDERATICN OF CONSERVATION IN 4 NEW YORK STATE PURSUANT TO NEW YORK STATE PUBLIC SERVICE i COMMISSION CASE NO. 28223 Overview In response to the Commission Order in Case 28223 dated May 7, 1982, Con Edison has thus far provided estimates of the maximum potential conservation impact for si:: residential measures.

Those measures are as follows:

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1) Refrigerators (manual and auto-defrost)

2) Residential room air conditioners

3) Residential lighting i 4,5,6) Residential water heating measures - (water heating blankets, low flow shower heads, and heat pump water i

heaters)

AEG was retained by Con Edison to provide the following data for each device for use in subsequent analysis: ,

1. Energy savings of a more efficient device relative to a less efficient device. These annual figures were further broken down into on and off peak costing periods for the

, summer and winter.

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2. Concomitant peak load impact of the more efficient device relative to the less ef ficient device.

3.. The additional cost of the more efficient device -

relative to the less ef ficient device.

AEG also developed the maximum system impacts for the above-mentioned conservation devices. Appendix C, Exhibit GLF-2 i'

entitled " Maximum Potential Conservation Impacts" contains this information. It is important to note that the analysis of conservation potential for these devices looked at the incremental conservation that could occur after the free market forces impacted these devices in the future. Thus, these impacts would be the incremental impacts that could be gained through subsidi=ation.

Con' Edison Study - Peak and Energy Impacts For the Con Edison system, the incremental maximum system peak i

i and annual energy impacts of these six conservation measures has been estimated to be 326 mW and 1296 gWh, respectively. These i impacts are over and above the free market force impacts for the affected appliances that are already included in the Con Edison official forecast. Those free market force impacts that have been accounted for in the Ccn Edison "most likely" forecast for these six measures have been estimated to be 660 mW and 2613 gWh,

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respectively. Thus, the Ccn Edison "most likely" forecast has accounted for a minimum of 67%'of the total conservation savings available from the six identified conservation measures.

Extrapolation of Con Edison Study Results to the Power Authority A similar fermal analysis has not been performed for the Power Authority with respect to these six measures. However, as a general statement, I would expect that the load and energy impacts in the case of each of the six measures would be significantly lower than that shown for Con Edison in Appendix C.

My reasons f or this expectation are as follows:

1. The Power Authority indirectly serves only a fraction of the number of residential households as does Con Edison. It is estimated that the Power Authority's Public Housing accounts serve approximately 250,000 households as compared to approximately 3 million households for Con Edison.

2. Virtually all of the households served by the Power Authority are master-metered. Master-metering diminishes, if not eliminates, incentives for households to conserve and usually removes the appliance purchase decision from the individual households.

For the purpose of discussion, however, I have performed a mathematical extrapolation of the incremental maximum conservaticn potential for the Power Authority utilizing tha results of AEG's analysis for Con Edison. The results of that extrapolation are as follows:

System Peak Annual Energy lenact_1dyt savings _1ggul Con Edison 326 1286 Power Authority 27 107 Incremental Conservation Measure Cost Effectiveness It is important to note that, as part of the study for Con Edison, an incremental cost / benefit analysis of the si:: measures was performed utili=ing a method that assessed the impacts en the l

utility's unit cost of electricity. That is, an investment by Con Edison in any measure at a level that would serve to increase the unit cost of electricity to consumers was not considered to be cost effective.

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Under the criteria for this i

investments in the case of more efficient room air conditioners were found to be cost effective. However, even in that case, the I

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were found to be cost effective. Hcwever, even in that case, the maximum rebate that would be allowed in crder to avoid higher unit costs would be $15.53 per device. This amount would be significantly below the total estimated incremental cost of the acre efficient device ($47.74).

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Conservation Analysis Limitations During the course of AEG's analysis for Con Edisca, we identified several impediments to both the accurate assessment and full i.npl ementa t i on of the subject conservation measures. From an assessment perspective r a number of data componeats lack the s

statistical rigor that wculd be required for an assessment with a high degree of confidence. For example:

1. The uncertainty surrounding the efficiency levels of the current appliance stock.

2. The uncertainty surrcunding future conservation program participation rates.

3. The lack of accurate information on the average annual i

kWh per appliance as well as their coincident peak demand i

levels.

4. The uncertainty concerning the amounts of conservation i

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that will occur without a subsidy program.

5. The magnitude of the potential offsets to certain conservation strategy implementation (e.g., more efficient

! refrigerators with added features, thermal savings of one i

appliance being made up by another).

b Thus, from a data constraint-perspective, the potential variance surrounding the base case usage values could conceivably be larger than the total percentage savings that is projected from

! the ascoci at ed - conservation measure. We have also identified a

[ number of institutional impediments to the full implementation of 1

the certain conservation measurcs analyzed. They are as follows:

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! 1. Significant Saturation of Master-Metered Residential ,

Buildings Approximately 20% of the residential dwelling units in the Con Edison service territory are master-metered apartments.

I Master-metering is a condition in which a building landlord i has a single meter for a multiple number of apartment units.

[ The landlord, in turn, assesses a fixed monthly electricity 4 charge based primarily upon the number of rooms. This i results in the removal of any economic incentive for i

! individual tenants to conserve electricity. Furthermore, when a landlord is faced with the replacement of a piece of i.

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equipment in a tenant's apartment, the landiced will most likely ept for the least expensive replacement (usually the least energy efficient). It should be recogni:ed that the following fcur measures under consideraticn would be affected by this impediment:

1. Lighting Improvements

2. Refrigeration

3. Air Conditioning

4. Water Heating

2. Incidence of Appliance Cunership in Residential Rentals In many apartments in New York City, major appliances are purchased by landlords rather than individual tenants. In most cases, such purchases are made in large quantities with price as the major consideration. Given Con Edison's customer min, which has a significant number of apartments (apartments comprise approximately 71% of the residential units in the Con Edison service territory), the evaluation of the incidence of appliance ownership will be a key determinant in a conservation program design for refrigeration, electric cooking, and air conditioning.

3. The Ramifications of a Relatively Large Residential Low Income Population in the Con Edison Service Territory

A 1977 survey perfcrmed for Con Edison by Audits and Surveys Inc. showed that over 30% of the residential customers in the Ccn Edison service territory can be classified as Icw income f amilies (under $10,000 annual income). This fact becomes e::tremely important when the time comes to design incentive programs for residential conservation measures.

This problem may be somewhat mitigated by the fact that tha majority of these Icw income customers live in master -cetered apartments. Thus, incentive programs for low inceme customers may better be aimed at landicrds than the low income families themselves. In any event, this is an issue worth studying to insure that ccnservaticn programs 7

reach the appropriate market segnent.

4. The Problem of Segregating the Incremental Costs of Higher Efficiency and Added Features There is another important variable associated with consumer purchases of more efficient air conditioners and i

l refrigerators. This unknown centers arcund the new energy consuming " features" that are being built into more energy efficiency appliances (e.g., ice makers in refrigerators, etc.). Thus, if one assumes that all future refrigeratcr purchases will be of the 33% more efficient variety and further postulate a $20 incentive program is required to 1

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i have consumers purchase a 50% more efficient unit, an average savings of 250 kWh's per year per unit wculd result.

However, it may well be that there would be no savings associated with the more e::p ensi ve model because of the offsets that may be included in such a model. Also higher efficiency models may contain additional features not found in the units they are replacing. This factor would serve to complicate any prospective incentive program.

Cggclysiggg From the results of AEG's analysis of the six conservation raeasures for Con Edison in PSC Case 28223 thus far, I offer the following cenclusions:

1. The incremental maximum impact of these six measures is relatively small in both an absolute sense and in comparison I

the amount of conservation reduction already includsd with these measures in the Con Edisen forecast.

2. By order of the PSC, the measures analyzed for Phase I of the Case were the measures that were conceived to have the greatest potential for cost effective incremental savings. Thus, other measures may have additional conservation potential over and above that included in the

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l Con Edison "most likely" ferecast, but I wculd expect that the incremental impact between Con Edison's "most likely" forecast and the maximum potential to be significantly smaller.

3. AEG's analysis for these sin measures showed that the Con Edison "most likely" forecast alroady contains specific reductions that accounted for the large majority of the maximum total impact for these measures. With the i

suspension of the 1980 DOE Appliance Efficiency targets by the federal government, the potential exists for an over-accounting for conservation in the Con Edison forecast.

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V. COMPARISCM CF ENERGY CEM9.ND GPCNTH RESULTS___GQUTSIU5D___IU ESE@ig__"EOQIUQIE__Z"_UlIU_EESULIg_yIILIIER_10_EGEUS31gS_EUELQYgp IU_"10DIGU_E010I_SIUQY" In their calculation of the " range" of revenue impacts, ESRG relies upon the forecasts contained in a prior EERG study entitled:

On_00alysi3_9f_Abe_Unnd_foc_and_Oltstantix2a___t9___tbe l EC9992Ed_C9Bl _E130t_'2 t _6c thut_ Kill ; A Report to the New York City Energy Office and the Corporation Counsel of New York, ESRS Study No. 81-21, June, 1981.

This report is referenced as Footnote 7 in ESRG's testimony in this prosecding entitled "The Economics of Closing the Indian i

Point Nuclear Power Plants".

The forecasts presented as part of this study were for the Con i

Edison service territory as well as the Power Authority's l

southeastern New York customers.

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Fcur scenarios were presented in this report *

1. High Case

2. Low Case

3. Base Case - Average of High Case and Low Case

4. Ccnservation Case In point of fact, however, the growth rates shown en Table 2 cannot be duplicated from the contents of ESRG's study referred to in Footnote 7, page 15, of the ESRS report which the following i table shows:

Indian Point Vs. Footnote 7 Growth Rates High Impact Mid Range Law Impact Indian Point Testimony .5% O .7%

Footnote 7 1.25% .5% .6%

. s It can be seen from this comparisen of " Demand Grcwth Scenarios" that ESRG has utilized variations of their pricr study that appeared to be skewed toward an overall lower range of energy demand growth rates which would have a result of biasing the entire analynis in the direction of lower overall cost estimates for the Early Retirement of the Indian Point plants.

CHANGES IN THE CHARACTERIZATION OF THE ESRG'S CCNSERVATICM SCENARIO In a review of Table 2, page 15 of the ESE3 Indi an Point Report, it can be seen that under the column " Load Growth" a range of growth rates of different energy demand scenarios is utilized in the determination of High Impact, Mid Range, and Low Impact Cost Scenarios for the Early Retirement of the Indian Point plants.

As noted earlier, these scenarios were purportedly obtained from ESRG's Footnote 7 which is a prior analysis done for determining the impact of censervation alternatives on the need for the Arthur Kill Coal /RDF Facility in New York City. While the similarities of these two pages are evident, the differences in the two reports are even more important for the purposes of viewing the ESRG's conservation " scenarios".

While the overall methodologies employee and much of the verbiage from the two studies are identical, the intent of the SEMP II

ESRG subaissicns appear to be quite different from the Arthur Kill Report. The text of the SSMP II Conservation Scenario presentation was significantly enpanded over and above that presented with the Arthur Kill Repert. The following citations from this expanded text should be noted:

"The object of this study is to analyze the potential for an intensive conservation program in tjew York State as a substi tute f or or ccmplement to additicnal pcwer plant construction. . .'cJhil e the conservatico scenario is n.gt_gtggggtpd_qg_g_blygp_rint fer inmediate action, it dces offer first approximation measure of the n.erits of such a program." (Emphasis added).

further:

"At the cutset, it is worth clarifying the character of the conservation scenario as designed and evaluated in the study. To begin with, thero are two types of functions it is not meant to serve. Eitat1_it_ig___ngt 9ff9Cgd__gg__g__bluggt i gt__fgt_igggdighg_gtgqtag_ggligg 92Et_thE_Oggt_tyggty_yggtps Rather it represents one choice of plausible target conservation levels in ceder to test the prcposition that conservatien could f easibly play a major role in the State...Whilg___it gebgdigg__thg__gaig__ggntggtg_gf_ggy_qgndidgig_gtggtag2

t thcre is no claim that the scenario is gcecisely_ seat

'dguld_eg gtg p_in_gn_gg tugl_gtg gtgOz " (Emphasis added) .

ESRG has erred in its ferecasts, technological evaluations, i timing- and extent of censervaticn iopacts, comparative economic analyses, and even in the most basic deductive reasoning looking at the relative pecbabilities of success of varicus competing alternatives.

The following sections will touch briefly some of the major methodolcgical flaws and errenecus assumptiens that are contained ,

in ESRG's Fcotnote 7.

4 WEAKNESSES OF THE ESR3 CONSERVATION SCENARIO In the case of the Conservation Scenario. ESRG has projected that almost 807. of the impact of conservation will be felt by the New York Power Pool System by the year 1990. Furthermore, the scenario shows full implementation of the total conservation potential in the first twenty years. This finding goes directly i

against statements made by ESRG in other proceedings and also an analysis performed by the National Academy of Sciences. The National Academy of Sciences in their analysis of the potential i for conservation implementation similar to that proposed by ESRG have estimated that the full impact from such a program will be

Felt between twenty to fifty years in the future in industrial

~32-

l .

I plants and over fifty years in the residential sector. This is totally at odds with the nine year 20% implementation that ESRG suggests.

Additicnally, there appears to b.e a methodological inconsistency in ESRG's implementation of their conservaticn scenario. ESRG's methodology relies, in large measure, on logistic curves that are fitted to historical data. Legistic curves have a flattened S-shape property. Therefore, if full implementaticn of a ,

technolngy requires twenty years. "the point of inflection" or that point at wnich half of the techno1cgy has been implemented shoule occur between years nine and eleven. However, ESRG purports to find an 80% penetraticn of their conservaticn scenario in the first nine years of the forecast period.

ESRG's use of an acc el erated conservation scenario is unrealistic. For example, cne has only to 1cok at the so-called 1980 FEA Appliance Efficiency Targets upon which ESRG bases a goed portion of its conservation reductions. These appliance

- efficiency targets originally scheduled for implementation in the 1980 appliance product line, have been suspended, and'the future i viability of those regulaticns is unccrtain as is the more optimistic 1986 increase in appliance efficiency targets referred to in the ESRG report.

. +

4 LACK OF CURRENCY OF ESRG FCRECAST AND METHODCLOGY The Footnote 7 Study was predicated on a data base that is now between three and six years old. The use of such an outdated study belies ESRG's statement, cade in response to a data request, that its " forecasting codel is subject to ccnstant change and improvement both in its data structure and in the analytical approach employed."

ESRG COST BENEFIT ANALYSIS METHODOLOGY FOR ASSESSING COST r

EFFECTIVE CC:5ERVA1IDh i:E 45URES Page 19 of ESRG's Indian Point Repcet in e discuscion of the j Conservation Scenario con ained in Footnote 7 states:-

i "Our June, 1981 study also developed a conservation scenario consisting of ccnservation measures and levels that were technically feasible and cost effective compared to energy supply" Thus, according to ESRG's acceptance criteria for conservation measures, all measures included in their conservation scenario must be cost effective.

I ilowever, an analysis of ESRG's censervation measures and their associated cost effectiveness points to f our major conceptual l

_34_

- - - - - _ - , , . - . - n. _ , . , , _ . - _ . - . , . . , - , _ _ . . . - , , , , . _ _ . _ _ . , _ . , ._ ,-_,n..-.,, _ _ , . . . _ . . , - , _ - . , , . _ . , - . . _ . -

9 2 .

errors in Secticns III, IV, and V of the 1981 ESRG Arthur Kill Report. They include the following:

1. ESRG's failure to perform a valid incremental cost / benefit analysis f or each conservation measure.

2. ESRG's inccrrect inclusion of benefits attributable to free market forces in its cost / benefit analysis.

3. The improper treatment of the i mpacts of more efficient appliances in the ccnsarve.tien scenario. The cost / benefit of measures that uere double counted in the Conservation Scenario.

4. ESRG's failure to reccgnize that fer certain end uses, the energy ccnserved in the conservation scenario is larger than the energy left to be conserved after the implementation of their base scenario.

OTHER ESRG ERRCRS AND INCONSISTENCIES The preceeding situations have served to provide information on some sample of ESRG's errors and inconsistencies. The following is a brief summary of some additional errors that have been uncovered during the course of my investigations of these ESRG studies:

i

4

1. ESRG's staff's alteration of feracast input data.

2. Utilization of incorrect and inconsistent FEA Appliance Efficiency Improvement targets.

3. Improper development of confidence bands around ESR3'S "most likely" forecast.

4. Lack of econometric justification for forecast ascucotiens employed.

5. Inability to quantify the impacts of important e::cgeneous variables.

6. Incorrect computer algorithms for computing conservation scenario dollar savings.

7. Overstatement of conservation scenario savings. (ESRG admitted $3 billion overstatement. Subsequent computation of ESRG's savings indicated overstatement of $6 billion).

I i

i

4 g 4

- Appendix A REEUME C.:

GECROE L. FITZPATRICK

SUMMARY

OF O.UALIFICATICNS E:: tensive background in load research, load forecasting and Icad management with a graduate degree in economic thecry and a ccncentraticn in statistics. E:: p eri enc e includes the development and defense of short and 1cng run econcmetric-based electric and gas forecasts, and overall management of load research prcgrams-with specific c::p erti s e in sample design and weather rormalization methodologies. Has testified an an e::p er t witness in the creas of Icad forecasting, load research, and load canagement.

CO2RErlT PCEITICN Mr. Fitzpatrick is the President of A,cp;iad Energy Grcupe I n ': .

(AEG), a management ccnsulting firm that serves the needs of the energy industry pria.arily in the areas of load research, Iced forecasting, load managcmcnt, and strategic energy planning studiec.

FRCFESSIC.*mL BACKGROUMD Stone & Webster Management Censultants, Inc. 1979 - 1981 Mr. Fitzpatrick held the position of Vice President-Load Research and Demand Planning. He was responsible for the coordination and direction of consulting activities in the Load Research and Load Management areas within the Corporation. Additional responsibilities included analyses of data processing requirements and potential new markets for consulting activities.

Long Island Lighting Company 1971 - 1979 Manager, Load Research and Fcrecast Division As a Manager of the Load Research and Ferecast Division, his prime responsibilities centered on electric peak and energy fcrecasts; electric and gas weather normalization; statistical sample design development, load research study implementation; load data management and analysis; Long Island Lighting Company's annual population survey; all long-range demographic projections; the collection, processing, and overall supervi si cn of billing of customers under Long Island Lighting Company's commercial-industrial time-of-use rate, the electric class of customer annual system load research study; and all stati st i c al l y-b as ed studies performed by Lcng Island Lighting Company's Economic Research Department.

37

i 4

]

Manager, Lead Research, Casting and Ferecast Division His responsibilities were enpanded in 1979 when the Load Research, Costing and Forecast Division was formed. As

.r.2 n a g e r , his resocnsibilities were enpanded tr include fully allocated and marginal cost-of-service studies fcr electric and gas and tctal factcr productivity studies.

t 1

SELECTIVE CC

13CLTING PROJECTS Locd Research Power Authority of the State of New York Supervised the review of the enisting load research prcgrso and fo mulated a management plan to speci f y f ature neads in the areas of sample design, harduare, software, and staffing.

Ccasclidated Edison Comprny of New Ycrk. Inc.

l Supervised the technical and data processing revi ew and assistcd in the develcpment of recommendaticns fcr a five year managec.ent plan for the 1 cad research prograo, Pacific Gas & Electric Ccmpany Performed a ccmprehensive audit of the PGaE Load Research Data Management and Analysis system. Also, assessed the .

value of load research to all relevant departments in the Company including recommendaticos for more cost effective uses of load research data for both current and future applications.

Electric Power Research Institute Advisor to EPRI's Demand Program. Author of RP 1585-3 " Load Data Management and Analysis"; co-author of EPRI Rate Design Study Tcpic Paper 3: " Issues in Load Research."

Tennessee Valley Authority Conducted review of TVA's Sampling Plan strategies and methcdolcgies.

Tacama City Light 1

Supervised the development of PURPA sampling and specification of organizational structure for a new Load Research Group.

38

+.

• 4 L cr.g Island Lighting Ccapany Designed and implemsnted stratified sampling software that scployed Dalenius-Hodges and Meyman Allccation techniques with stratum opticizatica and validaticn. Also directed LILCO's Lcad R: search Program.

Conservaticn Ccnsolidated Edison Company of Nsw York, !nc.

i j

Project Manager fcr a Conservation Assessment study which included designing a methcdo2cgy and perfcraing enalysis-to impact conservation measures in the residential and 4 commercial sectcr to meet requirements imposed by Naw York PEC in Case 28223.

i Nea Yorl: Power :' col

, F.nal yc ad the cancerva ti cr, allcut-.nces ccntained within the Memher System's i ndivi dual Icng range terecasts anJ critiqued intrvencrs' c en s arv at i cr. for'acssts and analyses.

Power Authcrity of the State of New York ,

Analysis on bahal f of Fr.3:lY of CSC.E Canservation Assessment Repcrt submittad in FERC Case 2729: Prattsville.

Load Managemant Power Authority of the State of New Ycrk

Supervised the development of an evaluation of potential Load i

Management strategies for the New York State Power Authcrity, including a cost / benefit anal ysi s and specific Load

Management t.est programs.

Long Island Lighting Company

Assi sted in the preparation of a June, 1978 Load Management study. Specific responsibilities included estimating Load Management reducticns included in LILCO's load forecasts by maj or component.

Load Forecasting Long Island Lighting

. Directed the preparation of LILCO's annual long range peak and energy forecasts during the years i?74 -

1979.

, Constructed the first engineering end use and econometric end use models for electric forecasting in New York State; utiliced Bo::-J en k i n s stochastic and transfer functions for t

39 --_ -

short run electric forecasts: emploved two and three stage regression tachnicues in S I C-b c. sed cccmercial-industrial forecasting.

Power Authority of the State of New Ycrk Supervi=cd the preparation of forecasts of impacte 3cr cost effective applicable Load Man ag e.nen t strategies for the Upstate Municipal Eystems served by the Authcrity.

Carolina Pcwer & Light Supervised the preparatico of energy and peak demand forecasts of ma::i mum icad and energy impacts for electric hect pump water heaters uithin the Carolina Power & Light service terri'" >

ctudy ccnmissioned by U.S. Power Management Corp.

NCR Carccraticn Perfcemed engineering 2conomic ctst benefis a. t al ynes and multi-scenario  :.ar k e t crojscti:ns for potential ICR '

energy-related product entries.

E:: pert Testiccn'

Has testified as an e'

p er t witness in the follcaing New York i State Public Service Co.mmi ssi on proceedings: Case Numbers >

26733, 26829, 26955, 27136, 27154, S0003, 27319, 27374, 27375, 23223 on subjects such as electric and gas peak and energy forecasts, Icad research studies for ccst-of-service analysis, Icad management. cogeneration. conservatico and s tati s ti cal studies for weather normalization of gas sendcut and electric energy requirements data.

Presented e:: pert testimony on behalf of the Member Systems of the New York Power Pool on the subjects of Load Fcrecasting, Energy Conservation and Economic Analysis in the New York State Energy Master Plan II Proceedings.

Presented rebuttal forecast, conservation and economic analyses cn behalf of the Power Authcrity of the State of New

! York in ccnnection with the Arthur Kill Coal /RDF Facility Corps of Army Engineers Proceeding.

1 EDUCATION St. John's University. MBA Economic Theory, 1972 St. John's Uni ver si ty. EA Economics. 1969 C. M. Post College, MS Candidate, Management Engineering Ccntinuing education cources in Engineering Econcmics. Lead Research, Demand Forecasting in Electric Pcwer Systems.

Bo::-Jenkins Forecasting Techni ques. FORTRAN, COBOL, and 40

BASIC. Ccncentration in logistic curve analysas two and three stage multiple regressicn technicues; Box-Jenkins stochastic and multiple transfer functions; and utilication and interpretatico of mul tiple regression model s and acsociated analytical techniques.

AFFILIATIC!!S American Statistical Association Mathematical Association of Americs Omicron Del ta Epsilon PUSLICATICNS "Hou Electric Util: tics Forecast", EPRI Peak load Fcrecasting Methodol ogi es, EP3I Synacsium Froceedings, tiew Orleans, 1979.

" Report of the Macca- Electric Systems of the New Y;rk Fower Poc1 and the Empira State Electric Energy Reuearch Corporati on pursuant to Article 3, Oe:ticn 5, 112 of ths Energy Law of New '/cr k State, E::hi b i t 7", LILCO Load Fcrecast Methodclog /, 1979.

" Report of the Mc-aber Electric S/ stems of the Ned York Pcwee Pool and the Empire State Electric Energy Rasearch

Ccrperatica pursuant to Article 8, Eectico 149-b of the

! Public Service Law, E::hi bi t 7", LILCO Load Forecast.

Methodology, 1974-1973.

" Issues in Load Research". Topic Paper 3, EPRI Rate Design

( Study (co-auther) 1981.

Speaker, " Issues in Load Research", EPRI Rate Design Study Executive Transfer Conferences, San Francisco, Kansas City and Washington D.C., 1990.

Speaker, " Load Forecasting Working Group Chairman Reports" (3), Utility Mcdelling Forum (EPRI sponsored) San Francisco, i

1979.

Instructor, " Load Research and Load Management Seminar" Stone and Webster Utility Management Development Course, New York j (2 courses) 1990.

j Speaker, " Allocating Revenues Between Service i

Classifications: Necessary Load Research", flational Regulatory Research Institute, Ohio State Unversity, 1900.

"The Load Research Process Above and Beyond PURPA" Public Utilities Fortnightly, March 18, 1?S2.

," Load Data Management and Analysis" EPRI RP15EO-3 December, 1991. .

41

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.# Appendb C Case 28223 EXHIBIT (GLF-2)

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.

MAXIMUM POTENTIAL CONSERVATION IMPACTS Maximum Annual System Energy Peak Load Savings Reduction Residential Device (GWH) (MW) a) Room Air Conditioners 219 209 b) Lighting (1) 252 19 c) Refrigerators Manual Defrost 29 4 Automatic Defrost 411 54 d) Water Heaters Heat Pump 175 18 Low Flow Showerheads (1) 111 15 Insulation Blankets (1) 53 7 (1) For these measures, conservation savings ara banee on relative efficiency improvements. Therefore, increasing base case efficiency will result in decreasiag satings over time. Maximum conservation potential wi'.1 tnus occur in an intermediate year.

43

. = - - - - .

(

UNITED STATED OF AMERICA

, NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P. Gleason, Chairman Dr. Oscar H. Paris 4

Frederick J. Shon

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

1 POWER AUTHORITY OF THE STATE OF  :

4 NEW YORK, (Indian Point,  : April 12, 1983 Unit No. 3)  :

! _________________________________x i

4

^

CERTIFICATE OF SERVICE I certify that I have served copies of Licensees' Testimony of George L. Fitzpatrick, Eugene T. Meehan, William J. Wagers, George C. S. Wang, Allan M. Stewart and Con Edison's

, Testimony of Dr. Peter C. Freudenthal on all parties by United i States mail, first class, postage prepaid this twelfth day of April, 1983.

Docketing and Service Branch Mr. Frederick J. Shon Of fice of the Secretary Administrative Judge U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission James P. Gleason, Esq., Chairman Washington, D.C. 20555 i Administrative Judge '

513 Gilmoure Drive

, Silver Springs, Maryland 20901 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing i Board

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

l 2

f l

Joan Miles Alan Latman, Esq.

Indian Point Coordinator 44 Sunset Drive l 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 208 West 13th Street i c/o Dean R. Corren, Director New York, New York 10011

New York University l 26 Stuyvesant Street Zipporah S. Fleisher

! New York, New York 10003 West Branch Conservation 443 Buena Vista Road i Atomic Safety and Licensing New York, New York 10956 j Board Panel j U.S. Nuclear Regulatory Mayor F. Webster Pierce j Commission Village of Buchanan

Washington, D.C. 20555 236 Tate Avenue

~

Buchanan, New York 10511 Atomic Safety and Licensing Judith Kessler, Coordinator l'

Appeal Board Panel Rockland Citizens for Safe

U.S. Nuclear Regulatory Energy 1

Commission 300 New Heropstead Road 10956

! Washington, D.C. 20555 New City, New York Richard L. Brodsky David H. Pikus, Esq.

Member of the County Legislature Richard F. Caaja, Esq.

Westchester County 330 Madison Avenue

< County Office Building New York, New York 10017

! White Plains, New York 10601 i

Phyllis Rodriguer, Spckesperson An&r.da Potterfjeld, Esq.

Parents Concerned About New York Public Interest Indian Point Research Group, Inc. _

P.O. Box 125 9 Murray Street, 3rd Floor Croton-on-Hudson, New York 10520 New York, New York 10007 Charles A. Scheiner Janice Moore, Esq.

Co-Chairperson Office of the Execitive Westchester People's Action Legal Director  !

i Coalition, Inc. U.S. Nuclear Regulatory i P.O. Box 488 Commission White Plains, New York 10602 Washington, D.C. 20555 l

! Stewart M. Glass

! Regional Counsel, Room 1347

Federal Emergency Management i

Agency 26 Federal Plaza

]j New York, New York 10278 i,

a 1

1

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_. - -___-- _ .._. _ . _ . . , _ ~ , _ _ . _ _ , . _ . . . _ , , , _ _ . _ _ . _ _ _ . . - , _ . - _ _ _ . _ . . . _ -

Z

• Paul F. Colarulli, Esq. Charles J. Maikish, Esq.

Joseph J. Levin, Jr., Esq. Litigation Division Pamela S. Horowitz, Esq. The Port Authority of' Charles Morgan, Jr., Esq. New York and New Jersey Morgan Associates, Chartered One World Trade Center 1899 L Street, N.W. New York, New York 10048 Washington, D.C. 20036 Ezra I. Bialik, Esq.

Charles M. Pratt, Esq. Steve Leipsiz, Esq.

Stephen L. Baum New York State Attorney Power Authority of the State General's Office of New York Two World Trade Center 10 Columbus Circle New York, New York 10047 New York, New York 10019 Andrew P. O' Rourke l Ellyn R. Weiss, Esq. Westenester County Executive l William S. Jordan, III, Esq. 148 Martine Avenue i Harmon & Weiss White Plains, New York 10601 1725 I Street, N.W., Suite 506 Washington, D.C. 20006 Renee Schusrtz, Esq.

Paul Chessin, Esq.

Joan Holt, Project Director Laurens R. Schwartz, Esq. .

Indian Point Project Botein, Hays, Sklar & Herzoerg  ;

New York Public Interest 200 Park Avenue Research Group New York, New York 10160 9 Murray Street New York, New York 10007 Stanley 3. Klimberg Nev York State Energy Melvin Goldberg 2 Rockefeller State Plaza Staff Attorney Albany, New Ycrk 12223 -

New York Public Interest Research Group Ruth Messinger -

9 Murray Street Member of the Council of the -

New York, New York 10007 City of New York District #4 Jeffrey M. Blum City Hall New York University Law School New York, New York 10007 i 423 Vanderbilt Hall

! Washington Square South Marc L. Parris, Esq.

l New York, New York 10012 County Attorney i County of Rockland Donald Davidoff, Director 11 New Hempstead Road Radiological Preparedness New City, New York 10010 Group Empire State Plaza Craig Kaplan, Esq.

l Tower Building - Room 1750 National Emergency Civil Albany, New York 12237 Liberties Committee

~

175 Fifth Avenue - Suite 712 New York, New York 10010 1

9 6.. .

Jonathan D. Feinberg New York State Public Service Commission David B. Duboff Three Empire State Plaza Westchester People's Albany, New York 12223 Action Coalition 255 Grove Street Steven C. Sholly White Plains, New York 10601 Union of Concerned Scientists Spence W. Perry 1346 Connecticut Avenue, N.W. '

Office of General Counsel Suite 1101 Federal Emergency Washington, D.C. 20036 Management Agency 500 C Street Southwest j David Lewis, Esq. Washington, D.C. 20472 i Atomic Safety and Licensing l Board Panel Andrew S. Roffe, Esq.

U.S. Nuclear Regulatory New York State Assembly Commission Albany, New York 12248 Washington, D.C. 20555 Dated: April 12, 1983 New York, New York

/

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