ML20209G643
| ML20209G643 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/24/1987 |
| From: | Davis W NEW YORK, STATE OF |
| To: | |
| Shared Package | |
| ML20209G621 | List: |
| References | |
| OL, OL-3, NUDOCS 8705010030 | |
| Download: ML20209G643 (9) | |
Text
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Docket No. 50-322-OL i
Unit 1) 50-322-OL-3 AFFIDAVIT OF WILLIAM E. DAVIS, EXECUTIVE DEPUTY COMMISSIONER, NEW YORK STATE ENERGY OFFICE WILLIAM E. DAVIS, being duly sworn, deposes and says:
1.
I am William E. Davis.
I have prepared this affidavit for use in Case Dockets #50-322-OL and #50-322-0L-3 which are presently pending before the Nuclear Regulatory Commission.
2.
I am presently employed by the New York State Energy Office as Executive Deputy Commissioner, a position I have held since August 23, 1984.
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3.
As part of my official duties at the Energy Office, I oversee the agency's studies and analyses related to electricity forecasting and supply planning.
4.
The State Energy Office has been and continues to be the lead agency in New York State government for energy policy, forecasting and planning analysis.
5.
I am responding to the material presented on pages 104 through 116 in the Request For Authorization to Increase Power To 25% And Motion For Expedited Commission Consideration submitted by the Long Island Lighting Company on April 14, 1987 in Case Docket No. 50-322-OL before the Nuclear Regulatory Comission.
In this material, LILC0 argues that there is a pressing need for power on Long Island, that the need is immediate, and that Shoreham's operation at 25 percent power is the only near term answer to this pressing need.
Due to the brief time which has been available to review the Request and Motion, I set forth the State Energy Office's views in sumary form only.
6.
It is my professional opinion, based on analyses performed by the Division of Policy Analysis and Planning of the State Energy Office, that operation of Shoreham at 25 percent power is not essential either in the near term or in the longer term to assure a reliable supply of power to Long Island l
since:
Without operation of Shoreham, reliability of electricity o
j service on Long Island should not be significantly different over the next two years than it has been for the past two years;
o Over the past two years, LILC0 has implemented only one voltage reduction, a
load control action largely unnoticed by consumers; and even this action did not occur during the summer peak period ;and o
After the next two years, the reliability of electricity service on Long Island without operation of Shoreham is projected to improve substantially.
7.
My conclusions are supported by on-going analyses of electricity reliability on Long Island performed by the Energy Office over the past two years.
In our December 1985 report: Meeting the Challenge: An Analysis of 1
Electricity Supply Options for New York State, we analyzed reliability on Long Island in the event that Shoreham were not to operate and concluded:
"Our analysis presented in Chapter 3 indicates that options are available to insure that LILC0 maintains adequate, electricity reserve margins from 1986-1991.
To maintain an 18% reserve margin (the minimum required by the New York Power Pool), LILC0 could increase its capacity by:
purchasing capacity from New England, other New York State electric utilities, Long Island municipal electric cooperatives and owners of small power production facilities; instituting new conservation demand programs to reduce peak demand; implementing automated transmission and distribution system controls; implementing a conservation voltage reduction program; encouraging voluntary load management by institutional, commercial and industrial customers; increasing the availability of time-of-day rate schedules; and increasing the number of interruptible customers.
The supply option estimates presented in Chapter 3 are shown through 1991 because the New York Power Authority's proposed new transmission line from Westchester County to long Island is expected to be in operation in 1992. Operation of the NYPA transmission line will significantly increase LILC0's ability to maintain adequate reserve margins."
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8.
We have continued to analyze LILC0's reliability status since issuance of the 1985 report; and continue to support the report's general conclusions, notwithstanding that our current forecast of load growth for Long Island is higher than our 1985 forecast.
9.
Our current analyses indicate that, even with a higher peak loao forecast (1.9 percent per year through the year 2000 versus the 1.3 percent per year forecast in 1985), there are actions which can be, and indeed are, being taken to maintain supply reliability on Lcng Island in the absence of Shoreham.
10.
In the near term (prior to completion of a second 345KV, 600MW transmission interconnection under Long Island Scund from Westchester County to Nassau County by the State Power Authority in late 1991), several steps can be taken to increase available resources.
These available steps include:
o increasing the capacity of the existing 345KV Long Island Sound Cable by 50MW by this sumner and by another 50MW by 1989; o
increasing by approximately 149Mk the ability to import power from Connecticut over the existing Norwalk Harbor to Northport cable by upgrading the capacity of the Northport to Pilgrim transmission line; o
if Shoreham is abandoned, fully utilizing the existing Shoreham diesels to provide an additional 28MW of peaking ccpacity to the LTLC0 system; promoting development of approximately 300 MW by 1991 of small o
pcwer facilities on Long Island by third party developers; o
enhancing conservation and load management programs capable of saving approximately 210 MW of load by 1991 through voluntary load control
- programs, in:plementation of new appliance efficiency standards, aggressive marketing of voluntary interruptible rates for large consumers, providing energy audits and financial incentives for all commercial and industrial custcmers to improve their er.ergy efficiency, and promoting energy management and thermal storage systems; and if necessary, o
adding 200MW of new gas turbine capacity.
11.
In the longer term, the following actions will ensure continued supply reliability of the LILC0 system:
o Construction of the new 345KV cable, scheduled for completion in late 1991, which will add 600 MW of additional import capability, backed up by the new Marcy South transmission line, scheduled for completion by 1988, and which will allow LILC0 access to lower cost resources in upstate New York and Canada; o
Enhanced development by third party producers, which could add a cumulative total of over 480 MW by the year 2000; o
Continued aggressive pursuit of conservation and load management which can reduce loads by a cumulative total of almost 540MW by the year 2000; and o
Construction of additional capacity as needed in the late 1990's in the form of smaller, modular facilities using technologies such as natural gas combined cycle, coal fluidized bed, or coal gasification combined cycle.
12.
In analyzing supply reliability on Long Island, it is necessary to consider total Long Island peak load (whether served by LILC0 or not) and total supply resources available to Long Island (whether installed on Long
- Island, obtained through conservation, or imported over transmission interconnections to other systems).
A measure of supply reliability which accounts for these factors is the resource or supply ratio, which is calculated by dividing the total Long Island capacity and transmission resources by the projected, weather-normalized, Long Island peak load, adjusted for conservation.
- 13. The experienced value of this weather-normalized ratio in 1985 was 1.24 and in 1986 was 1.25, indicating that total supply, including that available through transmission interconnection, exceeded
- actual, J
weather-normalized peak load by 24-25 percent over the past two summers.
I During these past two summers, there were no voltage reductions implemented by LILCO.
In fact, LILC0's last voltage reduction occurred not in the summer period, but on December 23, 1985, when a large amount of capacity was out of service for planned maintenance, and it lasted only four minutes.
- 14. Our analysis of future supply ratios for Long Island, with implementation of the measures summarized previously and with our updated, higher forecast of peak load, projects the following values:
Year Supply Ratio 1987 1.24 1988 1.26 1989 1.28 1990 1.36 1991 1.42 1992 1.58 1993 1.58 1994 1.57 1995 1.57 1996 1.56 1997 1.60 1998 1.57 1999 1.54 2000 1.52
- 15. The weather-normalized ratio projected for this summer is the same as that experienced in 1985, when no voltage reductions occurred.
16.
The ratio projected for 1988 is higher than the experienced ratio for the past two sunners. Future ratios are projected to increase dramatically indicating that not all of the measures analyzed are necessary to maintain supply reliability.
- 17. LILCO's Need For Power analyses and conclusions, as presented on pages 104-116 of their Request, are heavily based on two important premises j
which are not supported by recent experience.
18.
First, LILC0 indicates it was only fortuitous that they did not experience much greater problems in 1986, since they didn't experience their
" normal 700MW unavailability." Request p.110 l
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- 19. LILCO's experienced levels of unplanned unavailable capacity at the time of occurance of their system peak over the past four years have been:
Year Capacity (MW) 1983 330 1984 645 1985 522 1986 375 l
- 20. The average level of experienced, unplanned, unavailable capacity over the 1983-1986 period was 468 MW. This is also consistent with the 460MW level of projected unavailable capacity utilized by the State Public Service Comission staff in their 1986 analysis of LILC0's summer operating reserves.
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- 21. The difference between the experienced level of unavailable capacity over the past four years (468MW) and the level LILC0 argues should t'e considered normal in their reliability analysis (700MW) is 232 MW, or 62MW more than would result from operating Shoreham at 25 percent puwer.
- 22. The second premisc which heavily affects LILCO's analysis,and
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cccclusions on Need For Pcwer is that the LILCO system must have 30 ' percent reserve capacity. Request, p.109.
This level LILC0 argues, is i.ecessary to limit the projected number of voltage reductions to three per year in order to satisf,y a New York Power Pool standard which requires that "the prcbability of disconnecting firm load due to generation deficiency will be, on average, no more than one day in ten years." Request, p. 109.
i
. 23.
First, LILCO's contractual obligations to the New York Power Poci are to maintain an 18 percent reserve margin and to maintain their share of the Power Poul's operating reserves.
LILC0 has not indicated they will be unable to maintain these obligations.
- 24. Second, the Power Pool one day in ten years standard applies to the entire Pool, not individual utilities, and does not specify a maximum level of three voltage reductions for LILCO.
- 25. Third, LILC0's calculation of a 30 percent reserve required to limit voltage reductions to three per year is, at best, suspect.
As described above, the experience of the past two years, when reserves were in the 24-25 percent range and no voltage reductions occurred, has not borne out the predictions of LILC0's reliability model.
26.
LILCO's "Need For Power" analysis also states that "Shoreham's operation at 25% power is the best and most reliable means of helping meet Long Island's 1987-89 shortfalls in electric supply requirements." Request, p.
104. LILC0 argues that, "Without operation of Shoreham, LILC0 cannot assure its customers that this total 1987 demand can be met with currently available and anticipated resources,"
(Request, p.109) and that there are, "No Alternative Solutions for the Imediate Need". Request, p.ll3.
27.
Even if LILC0 were to obtain permission to operate Shoreham at 25 percent power prior to the occurrence of this summer's peak, there is little assurance that the plant would be actually operating when most needed.
Information available en the last six boiling water reactors to commence comercial operation in the United States indicates that during the first three merths of operation, the percentage of time the generators were actually on line varied from a low of approximately 12 percent to a high of approximately 66 percent, and averaged approximately 37 percent.
I 28.
In summary, near term (thru 1991) load growth on Long Island is projected to average approximately 65MW per year; there are a series of supply, transmission, ceriservation and load management actions which are capable of adding an average of aln'ost 150 VW per year of effective resources over the same period; and irrplementation of these actions, in the absence of any capacity from Shoreham, is projected to signficantly improve supply reliability on Long Island from the levels which have been experienced over the past two summers, when no voltage reductions occurred.
29.
Finally, ir adoition to the above described actions which can be and to a large extent are being taken to improve supply reliability on Long Islard, there is at least one other option which could be pursued should the State conclude that circumstances so warrant.
The Consolidated Edison Cerrpany, the electric utility which borders LILC0 to the west, owns a substantial quantity of barge mounted gas turbine capacity and also currently enjoys a significart excess of installed capacity compared to peck load.
If New York State were to conclude, for example, that moving cr.e of the 136 MW Gowanus Unit barge mounted gas turbines was both in the finar.cial interest of Consolidated Edison and necessery for the provision of safe and adequate electricity service on Long Island, this option could be pursued.
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/ h d & 2, W " b t' M William E. Davis Sworn to before me this
?4tb day of April,1987.
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