ML20215L150

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Affidavit of SS Bernow Responding to Certain Statements Made by Util Re Two Documents Filed W/Nrc Concerning Request for Authorization to Increase Power to 25% & Motion for Expedited Consideration.Certificate of Svc Encl
ML20215L150
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 05/05/1987
From: Bernow S
ENERGY SYSTEMS RESEARCH GROUP, INC.
To:
Shared Package
ML20215L077 List:
References
OL, OL-3, NUDOCS 8705120116
Download: ML20215L150 (49)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station )

Unit 1) )

)

AFFIDAVIT OF STEPHEN S. BERNOW Stephen S. Bernow, Ph.D. , being duly sworn, does say under oath as follows:

1. My name is Stephen S. Bernow. I am employed by Energy Systems Research Group ( 'ESRG") . ESRG has frequently reviewed Long Island energy needs over the last ten years, and presently is preparing both short-term and long-term analyses of such matters. A description of my experience, of ESRG's work related to Long Island's energy needs, and a copy of any resume are provided as Attachment 1 to this affidavit.
2. The purpose of this affidavit it to respond to certain statements which were made by the Long Island Lighting Company ("LILCO") in two documents filed recently with the Nuclear Regulatory Commission ("NRC"). The two documents were a " Request for Authorization to Increase 8705120116 870506 PDR O ADOCK 05000322 PDR

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.'.4' Power ~to'23%" and a " Motion for Expedited Commission

, consideration." Specifically,'in support of the Motion for ,

, Expedited Commission Consideration, LILCO has stated'as follows:

4-Long Island, however, has an'immediate i- need for Shoreham's power. Power alerts are already occurring and capacity shortfalls are forecast. LILCO's aging foreign oil-fired base generating capacity-is insufficient to meet Long Island's current demand. LILCO must rely on off-Island purchases through its three interconnections. But these limited interconnections are already being used to capacity, and new trans-mission lines and interconnections are years away. An immediate remedy is

needed.

LILCO then continues in the Request (at pages 104-116) to purport'to demonstrate that there is a pressing need for the i CommisJion this summer to grant LILCO authority to' operate

[ Shoreham at 25% power and thus purportedly to augment LILCO's capacity by approximately 170 megawatts.

3. In the short time since receipt of LILCO's filings, ESRG has performed review to determine whether, in fact, LILCO's statements of an immediate need for Shoreham's
power are correct. For reasons set forth below, we conclude that they are not correct.

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4. The following conclusions have been reached:

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a. LILCO'S system reliability in the summer of 1987 is not " critical" as LILCO's statement
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asserts, but, according to the New York Power Pool'(NYPP) and New York Department of Public Service (NYDPS) studies mentioned by LILCO,

" marginal", i.e. in the neighborhood of its reliability criterion.

b. The NYPP reliability study of Long Island, referred to in LILCO's statement, indicates that LILCO's system will approximately meet its reliability criterion in the summer of 1987.
c. The Shoreham plant, operating at 25% power, is not "the best and most reliable means" of helping meet Long Island's electric supply needs for reliable service in the 1987-89 period. Nor is it the only means. In fact, it is likely to be a very unreliable source of power, given industry experience with such nuclear plants. More specifically, given the typical startup problems of nuclear plants, 4 Shoreham is likely to be especially unreliable in the summer of 1987.
d. The condition of LILCO's system expected in the summer of 1987 is similar to that over 3

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the past two to three summers. With varying degrees of outside support during the past three years, which'can be expected this summer as well, LILCO was able to reliably meet its customers' loads on Long Island.

e. The NYPP and DPS studies referred to in LILCO's statement point to a number of actions open to LILCO for the 1987-1991 period to overcome potential reliability problems in the absence of Shoreham.
f. The LILCO statement makes reference to possible " blackouts" arising if Shoreham does not operate, but it provides no analysis of its own or of NYPP of the likelihood of such customer disconnects, compared with the NYPP criterion of one " disconnect" in ten years,
g. Further, LILCO's use of the term " blackouts" is itself misleading. In fact, in the unlikely circumstance that LILCO were to suffer generation insufficiency in spite of its emergency operating procedures, this would result in selected and limited load 4

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sheddina, not system or area-wide

" blackouts."

h. Nor does the LILCO statement even indicate that between the potential " brownouts" (i.e.

voltage reductions) and " blackouts" it mentions, LILCO has a number of standard emergency operating procedures to significantly reduce the likelihood of

" blackouts" (i.e. selected customer disconnects for short periods).

i. There are a number of assertions in the LILCO statement, beyond those alluded to above, which may misleadingly exaggerate the potential reliability problems on Long Island this summer.
j. All statements regarding the reliability of an electric utility system (including LILCO's) nust be understood to be probabilistic, not precise predictions. No one can predict in advance whether voltage reductions or disconnects will occur or not.

At best, one can compute their probability or average under a set of conditions.

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k. It appears, from the DPS and NYPP studies, and from independent evaluation by ESRG, that LILCO is likely to be able to effectively manage the reliability of its system in the summer of 1987 without Shoreham. Beyond 1987, additional measures can be used by LILCO to further improve its reliability, as is also discussed in these studies and in the attached preliminary ESRG study.
1. LILCO has already undertaken some key measures since the summer of 1985 to enhance the reliability of its system. These include bringing back its 112 MW Far Rockaway unit, enhancing its maintenance activities, upgrading the Y-50 transmission tie line to NYPP by 50 MW, and, introducing some new conservation and load management measures.

In addition, LILCO has 20 MW of back-up diesel generators at Shoreham some of which could potentially be used to help meet load in 1987 if Shoreham does not operate. Thus, in some respects reliability conditions may have improved over the past two years (all else equal).

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m. An independent assessment of reliability on Long Island.needs to be done. Preliminary results of an ESRG study (Attachment 2 to this affidavit) indicate that the reliability of LILCO's Long Island system is better than found in the NYPP study cited by LILCO.
5. Since LILCO has asserted that it has an immediate need for power and for Shoreham in particular, it is important to first focus on the summer of 1987. Other options could be invoked in later years-if and as need is demonstrated.

LILCO has referred to the reliability of its system on Long Island as " critical." But for the present it is

" marginal" according to reports of NYDPS and NYPP.

The DPS report states:

"The reliability of power supply on Long Island is marginal and will remain so in coming years." (p.2.; emphasis added)

The NYPP report statcs:

" ... reliability of the LILCO system is presently marginal and is expected to deteriorate rapidly..." (p.8.; emphasis added).

The key here is the assessment of " marginal" not " critical."

l Moreover, while NYPP study (to which the DPS report itself refers) expects the reliability "to deteriorate rapidly," it 7

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is important to note that such " deterioration" assumes that no measures are taken in the coming years to improve the system's reliability. This is unrealistic since some reliability enhancement measures are already underway, including the 50 MW upgrade of the tie line to NYPP (slated for completion by the summer of 1987), LILCO's enhanced

- plant maintenance program, LILCO's expanded conservation and load management programs,-the potental availability of existing back-up diesel generation at Shoreham, steps LILCO has taken to bring a combustion turbine into service if necessary, a further 50 MW upgrade of the tie line to NYPP (possibly by 1989), and the second 345 KV tie line to NYPP expected by 1992. Thus, we disagree with any assertion that the reliability situation on Long Island will deteriorate.

' The data are to the contrary.

6. The NYPP reliability study of LILCO's system finds that the expected number of voltage reductions in 1987 would be about 4 assuming 700 MW of interconnection to Long Island, and about 8 assuming 600 MW of interconnection to Long Island. It is important to note, as the NYPP report i

does, that by " expected" it is meant not that such will occur, but that on a probabilistic basis this is the average expected annual amount.1 1

I For example, even if all the assumptions made in the analysis are precisely correct, this could be consistent with none in 1987.

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The LILCO load forecast for 1987 which was assumed in the NYPP study was 3430 MW, whereas LILCO's net load according to its statement will be 3479 MW (3570 MW minus 91 MW conservation and demand control). Thus the 1987 peak load is expected by LILCO to be only 49 MW or 1.4 percent more than in the NYPP study. LILCO's Long Island resources assumed in the NYPP study for 1987 amounted to 3766 MW2, LILCO currently assumes that it has 3743 MW of its own capacity and 10 MW small power which along with 30 MW for the munis would give 3783 MW available to meet its loads in the sunmer of 1987.3 Thus, overall the loads and resources situation will be about the same this summer as was assumed in the NYPP study.

The NYPP study result, 4 to 8 expected voltage reductions in (all of) 1987, is close to NYPP's criterion of 4 per year, and LILCO's specific criterion of 3 per year.

The NYPP study results indicate, therefore, that to bring the voltage reductions down to 3 per year at its 700 MW intertie assumption, about 40 to 60 MW of capacity support and/or load reduction would be needed.

2 NYPP assumed 3714 MW installed, 30 MW small power, and 32 MW from munis.

3 Winter and spring capacity ratings are a few nundred t!W higher.

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LILCO plans to upgrade its Y-50 line by 50 MW for this summer. Moreover, LILCO has estimated that about 36 to 38 MW of interruptible load could be achieved in 1987 under its new Restricted Demand Service and Energy coalition programs

_(and a total of about 50 MW from all of its conservation and load management (C&LM) programs). The Commission has already approved LILCO's current C&LM plans. If needed, at the appropriate rates approved by the Commission, even more savings might be achieved quickly. Thus, reliability this summer will be, in a probabilistic sense, at about the levels required by LILCO's own criterion.

Finally, the NYPP study pointed out that even more than 700 MW intertie support is available to Long Island sometimes. This would, to the extent available, provide additional support capacity, and thus better reliability than found in its study.

7. LILCO asserts 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 requi.rements . " (p. 104) Twenty-five percent of Shoreham's power is about 200 MW. Yet this is not likely to be a reliable source of 200 MW of capacity for the 1987-89 period, given the experience with such nuclear plants as will be discussed below. In fact it is likely to be very 10

unreliable and especially so in the near term given the 4

, experience with such nuclear plants as d.iscussed below.

t-f Nuclear power plants in general, and Boiling Water reactor plants (BWRs) such as Shoreham in particular, have _

historically had poor reliability. The average capacity factor'(fraction of the time that power is available on average) of all BWRs has been 56.6% through 1985, and for all large (800 MW+) BWRs it has been 52.9%. This poor

] performance has not improved recently, indeed it may have deteriorated. Since 1980 the averages.have been about 55%

for all BWRs and about 52% for all large BWRs. This implies i

L that for such plants the power would be available only about one half of the time, with about a 50 percent chance of not having it.

, The reliability of such nuclear units has, in fact, been worse still in their early years of operation--the well

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known phenomenon in the industry of " immature" performance.

, Moreover, the likelihood of even higher outages in its first l~ year, and therefore this summer, is supported by past l' experience at nuclear power plants. If Shoreham were to

! ' start up by this summer, it would likely have a capacity i

factor of only about 44 percent over its first six months of operation, based upon first year experience at nuclear plants of this type, size, etc.

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8. A comparison of LILCO's 1987 situation with that of the period 1984 to 1986 indicates that this summer will

- have comparable conditions.

1984 1985 1986 1987 LILCO Summer Peak 3096 3380 3441 3479 Installed Capacity 3609 3609 37434 3743 Munis 36 36 33 32 Small Power -- -- 8 . 10 Total Capacity on Island 3645 3645 3784 3785 Surplus Over Peak 5 549 265 343 306 ,

LILCO suffered only one voltage reduction (and no customer disconnects) in the past three summers. There is no more reason this summer to expect it will be much different (again in a probabilistic sense). In fact, LILCO's planned completion of a 50 MW upgrade on its Y-50 transmission tie to the NYPP through Westchester, and its recent attempts to schedule maintenance to minimize risk and to improve (i.e. reduce) its plant forced outage rates (see the NYDPS study and LILCO's statement concerning its

" Generation Availability Program"), could create even more 4 Far Rockaway added (112 MW), June 1986.

5 Does not include the approximately 700 MW of power that LILCO could obtain through its available interties.

See Attachment 2.

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favorable reliability conditions in 1987, making it comparable to 1985 and much better than in 1986.

9. A number of LILCO's statements misleadingly suggest worse reliability than is actually the case on Long Island in 1987.

Aae and Reliability of units LILCO suggests that its major oil-fired generating.

units have poor availability because of their ago, noting that the average age of its large units is 27.2 years with only 3 less th.n 20 years old. This is misleading. LILCO's major generating stations are not very old:

Equivalent Aces Maior Steam Units Canacity Forced Outaae 10 to 20 yrs 4 Northport Units 1507 MW 8.8 to 16.3 percent 20 to 30 yrs 2 Port Jefferson Units and Barrett Unit 2 575 MW 3.8 to 5.9 percent 30 to 40 yrs Barrett Unit 1, Port Jefferson 1 & 2, Far Rockaway 612 MW 6.2 to 20.4 percent 4,'and Glenwood Units 4&5 Thus LILCO's units are not very aged. More than half its oil-steam capacity is less than 20 years old and almost 80% is less than 30 years, and the principal equivalent forced outage rates are reasonably low. Moreover LILCO has more than 1000 MW of combustion turbine capacity which is 13

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especially desirable for quick response reliable peaking use.

April 3. 1987 Alert As one of its examples provided to demonstrate that:

"Long Island's energy crisis... is here now (p. 104)," and i

that " Dramatic proof is furnished by recent events (p.

104)," LILCO discusses its April 3, 1987 " power alert."

While such a condition may be cause for concern, it also illuminates LILCO's ability to manage the reliability of its system, even under such potentially extreme and unusual circumstances.

The conditions facing LILCO on that date were unusually extreme. According to LILCO, almost half of its oil-steam generating capacity was out of service at the time. This included three of its four largest units, (Northport 1,3 and 4 at about 375 MW each), the loss of 2/3 power from its next largest units (two Port Jefferson units at 190 MW each), and its Glenwood units (two units at about 110 MW each).

LILCO also noted that it purchased an additional 300 MW from Con Ed and 200 MW from Northeast Utilities, but such support is precisely what its interconnections are designed to achieve. Thus, even under these extreme conditions, 14 i

4 LILCO did not need to invoke any voltage reductions (brownouts).

Emeroency Operatina Procedures LILCO's statement refers several times to potential

" brownouts" or " blackouts." Yet it is important to note that: (a) these are potential, (b) a brownout is a voltage reduction of about 5 percent with service continued, and (c)

" blackouts" ought not be construed in the first instance as area-wide, but the shedding of small blocks of load for short time periods. More importantly, by juxtaposing these two potential conditions, LILCO misleadingly suggests that if voltage reductions occur, they are immediately followed by customer disconnects. This, however, is not the case.

Between the occurance of a voltage reduction and customer disconnect, the LILCO system has a margin of several hundred megawatts with which to operate: this includes the 5 percent voltage reduction itself (about 135 MW for LILCO) , use of emergency generator ratings (about 130 MW for LILCO), the use of ten-minute spinning reserves (about 160 MW for LILCO), plus additional voltage reduction and appeals to customers to reduce demand. Thus, LILCO's juxtaposition of " brownouts" and " blackouts" is misleading.

There are several hundred megawatts of emergency generating l procedures between when a brownout (i.e. voltage reduction) l l

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is first needed and when the first potential disconnect would occur if at all. These operating procedures, then, provide LILCO with the ability to significantly further reduce the possibility of any customer disconnects.

Combustion Turbines LILCO's statement asserts that: " Additional generating capacity for new gas turbines or new coal-fired power stations could not realistically be brought on line in time to meet the energy shortfalls of the next several years."

(p. 116).

This statement is misleading. Both the DPS and NYPP studies identify new combustion turbines as a viable option during this period. In its February, 1986 report, NYPP concluded that: "If Shoreham is not operated, gas turbines could possibly be installed by 1989, assuming the necessary regulatory approvals are received on a timely basis." In its May, 1986 report, the DPS drew similar conclusions. In the mean time, LILCO has proceeded to pursue this option; it has completed a siting study, sent out specifications for bid, and has been preparing licensing documents for a nominal 200 MW combustion turbine facility on Long Island.

Moreover, LILCO is also pursuing discussions with Con Edison for an additional 50 MW upgrade of its Y-50 16 l

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l transmission tie line to NYPP which could be-implemented by 1989, beyond that planned for this summer. Thus, contrary to LILCO's statement'(p. 116) there is evidence that LILCO is already in the process of adding 50 MW by the summer of ,

1987, and at least 250 MW by 1989.

Authoritative Reliability Study

LILCO quotes the North American Reliability Council, 1986 Summer Assessment of Overall Reliability of Bulk Power Sucolv as an " authoritative reliability study."

Yet.such NERC annual reports do not perform an independent detailed reliability assessment of each NERC region or of the component sub-regions, or of individual utilities. Rather, they summarize the situation, based upon information provided by the NERC members. NERC did not perform a separate reliability analysis of Long Island.

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Subscribed to before me this 5th day of May, 1987.

Steph n S. BeTnow, Ph.D.

My commission expires: - /4, /YN (date) b .

(Notary Public) l 1

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ATTACH:iENT 1 SCHEDULE A DESCRIPTION OF ESRG AND DR. STEPHEN BERNOW My name is Stephen S. Bernow. My business address is Energy Systems Research Group, Inc., 120 Milk Street, Boston, MA 02109.

I am senior research scientist and Vice-President at Energy Systems Research Group (ESRG). ESRG is a non-profit organization specializing in research on energy-related issues, including demand forecasting, conservation program analysis, electric utility dispatch and reliability modelling, generation planning, avoided cost analysis, financial analysis, rate design, cost of capital analysis, power plant cost and performance analysis, and related matters. ESRG also does research on energy and economic planning for developing countries.

My work at ESRG has included demand forecast modelling, generation planning and supply analysis, district heating analysis, emissions / air quality analysis, and developing country energy planning.

I have testified before the Wisconsin Public Service Commission (Docket CA 5447, January, 1979) and the

p9 Pennsylvania Public Utility Commission-(Case R-77110521, April, 1978) on demand forecasting; before the Michigan Public Service Commission (Docket U-6006, April, 1979) and the U.S. Federal Energy Regulatory Commission (Project 2729 in 1980) on supply planning; and before the Illinois Commerce Commission (Docket No.82-092, May, 1983) on excess capacity. .

In 1983 I presented testimony before the New 2

York State Energy Planning Board on the economics of a proposed pumped storage hydro-electric facility, and before the New York State Department of Public Service on the economics of proposed 345 KV transmission facilities (Case 70126).

In 1984, I presented direct testimony (in case U-76670 before the Michigan Public Service Commission) on

! excess capacity in the Detroit Edison system. I also i presented direct testimony, in Docket No. 82-0855 before the Illinois Commerce Commission, October 1904, on an economic evaluation of completion of Commonwealth Edison Company's Braidwood nuclear facility.

In 1984 and 1985 I presented direct testimony on behalf of the Consumer Representative Staff of the Wyoming Public Service Commission, regarding excess capacity and the economics of capacity additions for the Utah Power and Light System (Docket No. 9441, Sub. 20) and the Pacific Power and Light System (Docket No. 9454, Sub. 25).

4 In 1985 I presented testimony in Michigan on Detroit Edison . Company 's plans to construct the Saragtoga-Jewell transmission line. I testified for the Public Service Commission in Arkansas (Docket No. 84-249-4) on the reliability and the economics of generation planning in the Middle South Utilities system and, in particular, the economics of the Grand Gulf nuclear generating station.

I have also recently completed a study of the economics of completing the two unit vogtle nuclear station from the standpoint of Georgia Power Company alone as well as Finally, in 1985 I all participants in the project.

completed a study of power plant performance standards for Public Service Company of New Mexico and the Attorney General of New Mexico.

In 1986 I developed analyses and provided testimony on excess capacity and economic cost-benefit, involving the Millstone 3 nuclear plant, in Decket No. 85-10-22 before the Connecticut Department of Public Utility Control (DPUC) and in Docket No.85-212 before the Maine Public Utilities Commission. I also provided testimony on these issues involving the Palo Verde nuclear plants in Docket No. U-1345-85-156 before the Arizona Public Service Commission in February 1986. I testified before the Michigan Public Service Commission in Case No. U-8376 on establishing performance standards for Detro'.t Edison

Belle River coal-fired power plants, and before the South Carolina Commission regarding the economic cost-benefit and appropriate ratemaking treatment for Duke Power Company 's Catawba 2 nuclear plant. In late 1986 I testified before the Illinois Commerce Commission on the economics of completion versus cancellation of Common-wealth Edison Company 's Braidwood 2 nuclear facility, and I provided testimony before the Michigan Public Service Commission on the economics of and ratemaking for Detroit Edison's Fermi 2 nuclear plant.

I have done research on electric utility supply planning involving utilities in New York, New England, Illinois, Michigan, Pennsylvania, the American Electric Power Co. (AEP) system, the Southern Company system, the MOKAN system, the Middle South Utilities system, and systems in the Pacific Northwest and Southwestern U.S.

The primary focus of this work has been on the reliabi-lity and economi.cs of generation planning, and on power plant cost and performance.

I directed ESRG research for Brookhaven and Argonne National Laboratories on district hea ting feasibility.

The District Heating Strategy Model, which I developed for Argonne National Laboratory, was used by the Department of Energy and the Department of Housing and Urban Development in a 28-city district heating feasibility study. Work for the national laboratories and for the Boston Redevelopment Authority has included emissions and air quality analysis of district heating, cogeneration and solar energy strategies for electric utility-service territories.

My work on international energy planning has included energy supply / demand and policy analysis in Kenya and in the southern African region. A major feature of this work has been the development and application of appropriate computer model capabilities.

Among the sponsors of my international work have been the United Nations, the Swedish International Development Agency, the U.S. Agency for International Development, and the Beijer Institute of the Royal Swedish Academy of Sciences.

I received a Bachelor of Science degree from Columbia University School of Engineering and Applied Science in 1963, and a Ph.D. in physics from Columbia University in 1970.

Before joining ESRG, I taught at the university level. I have been with ESRG since it was established in 1976.

ATTACHMENT 1 SCHEDULE B SELECTED PRIOR ESRG STUDIES AND TESTIMONY RELATED TO LILCO Year Tonic (snonsor) 1986 Evaluation of Long Island Power Authority option as part of Smith Barney consulting team with focus on electric rates impacts and financial projections (Suffolk County).

1985 Testimony in LILCO rate case evaluating the economics of Shoreham and phase-in approaches to protect ratepayers from rate shock (CPB and Suffolk County) 1984 Prudency evaluation of LILCO's request for recoupment of investment in cancelled Jamesport project (Suffolk County) 1984 Review of public power option for Long Island (New York Assembly) 1983 "Long Island Without the Shoreham Power Plant:

Electricity Cost and System Planning Consequences" (4 volumes), presented before Governor's Marburger commission on Shoreham (Suffolk County) 1983 Critique of LILCO defense of Shoreham economics (Suffolk County) 1982 Inquiry into the benefits to ratepayers and utilities from implementation of conservation programs (sponsorship by multiple New York state citizens groups) 1981 Prudency evaluation of LILCO's request for recoupment of investment in cancelled New Haven nuclear project (Suffolk County and Nassau County) 1980 "The Conservation Alternative to the Power Plant at Shoreham, Long Island" (Shoreham Opponents coalition) 1978-79 Independent forecast of LILCO service area and critique of Company forecast (Department of Environmental Conservation) 1977-78 Review of LILCO power planning and proposed Jamesport investment (L.I. Farm Bureau and several L.I. towns) 1977 Independent load forecast and critique of LILCO's continuation of Shoreham investment (Consumer Protection Board)

, ATTACHMENT 1 STEPH ] S. BERNOW SCHEDULE C

  • Research Scientist Vice-President of the Corporation Energy Systems Research Group Education Ph.D.: Experimental Physics, Columbia University, 1970 M.A.: Physics, Columbia University, 1965 B.S.: School of Engineering and Applied Science, Columbia University, 1953 Experience 1976 -

Present: Energy Systems Research Group, Inc., -

Vice President since 1976.

Responsibility for a range of energy technology assessments and modelling studies in the areas of district heating, cogeneration, the economics of generation alternatives, and electric load forecasting, and reliability analysis.

Analysis of the physical, economic, and environmental implications of alternative energy and resource planning strategies.

1974 - 1976: Assistant Professor, Allen Center, State University of New York at Albany. Taught courses in social science / economics and science / society.

1972 - 1974: Assistant Professor of Physics, Richmond College, City University of New York.

1969 - 1972: Assistant Professor of Physics, Rutgers University at Newark.

Testimony Case or Agency Docket No. Date Topic Arizona Corporation U-1345-85-367 February, Concerning Excess Capacity Commission 1987 and Cost Benefit Analysis of Palo Verde Generating Station Arizona Corporation U-1345-85-367 February, Concerning Performance Commission 1987 Standards for Arizona Public Service Company t.

1 Michigan Public U-7660 December, Cancerning tho Fcrmi II Servico Commiscien 1986 Nucicar FOcility e

Further*and Additional Evidence Michigan Public U-8469 December, Concerning Performance i Service Commission 1986 Standards for the

. Fermi II Nuclear Facility Illinois Commerce 86-0249 October, Concerning Cancellation Commission 1986 of Braidwood 2 4

South Carolina Public 86-188-E July, Catawba 2 Economic Service Commission 1986 Analysis and Rate-making Treatment Michigan Public U-8376 May, Performance Standards Service Commission 1986 for the Belle River Plant Maine Public Utili- 85-212 April, Excess Capacity ties Commisson 1986 Determination and Economic Cost-Benefit Analysis Maine Public Utili- 85-212 June, (Surrebuttal Testi-

ties Commission 1986 mony)

Georgia Public 3553-3 April, Economics of Completing Service Commission 1986 versus Cancelling the Vogtle Nuclear Facilities Arizona Corporation U-1345 February, Excess Capacity and Commission 156 1986 Economic Cost Benefit Analysis of Nuclear j Plant Connecticut Depart- 85-10-22 February, Excess Capacity and r ment of Utility 85-09-12 1986 Economic Cost Benefit

] Control Analysis of Nuclear Plant Arkansas Public 84-249-U June, 1985 Request for a Retail Service Commission Rate Increase Arkansas Public 84-249-U July, 1985 (Surrebuttal Testi-Service Commission mony)

Aug., 1985 (supplemental Testi-money)

Sept., 1985 (Surrebuttal Supple-montal Testimony)

Illinois Commerce 82-0855 June, 1985 (Robuttal Testimony)

Commission

Wyoming Public 9454 Jen. 1985 Ex22inOtiCn of ExcOca Utilitica Sub 25 C:p city cn tho Pacific

, Commissien Powcr cnd Light Company System: Reliability and Reserves, and the Econo-mics of the Colstrip 3 Plant Wyoming Public 9441 Dec. 1984 Examination of Excess Utilities Sub 20 Capacity on the Utah Commission Power and Light Company System: Reliability and Reserves, and the Econo-mics of the Hunter 3 Plant Illinois Commerce 83-0855 Oct. 1984 Cost-Benefit Analysis Commission of the Cancellation of Commonwealth Edison's Braidwood Nuclear Generating Station (Direct Testimony)

June, 1985 (Rebuttal Testimony)

Michigan Public U-7660 Jan. 1984 Application of Detroit Service Commission Edison Company for Authority to Amend its Rate Schedule Covering the Supply of Electric Energy and to Amend Other Miscellaneous Rates (Direct Testimony)

Aug., 1985 (Sur-Rebuttal Testimony)

Catskill Center for 1983 State Sept. 1983 Economics of Pumped Conservation and Energy Master Storage in NYPP Development, Inc. Planning and et al Long-Range Elec-tric and Gas System Plan-ning Proceeding N.Y. Public Service 70126 Aug. 1983 Evaluation of NY Power Commission Authority's Economic Justification for its Proposed Marcy-South 345 KV Transmission Facilities Illinois Commerce 82-092 May 1983 Economics of Capacity Commission Reserves Federal Energy Regu- 2729 Jan. 1981 Economics of Pumped latory Commission Storage in NYPP N.Y. Public S;rvico 80003 Aug. 1979 Nuciccr eccnomico Commisolcn Connecticut Division 781206 and May 1979 Economic implications of Public Utilities 718207 of alternative Control generation capacity construction scenarios Michigan Public U-6006 Apr. 1979 Reliability and Service Commission reserve margins  :

N.Y. Public Service Case No. Mar. 1979 Nuclear economics commission and 80006  !

U.S. Nuclear Regu- Docket No.

latory Commission 50-549

. Wisconsin Public CA 5447 Jan. 1979 Forecast critique and Servi,ce Commission independent long-range forecast of electric energy and demand Pennsylvania Public R-77110521 Apr. 1978 Long-range forecast Utility Commission of electric demand Selected Reports and Publications May, 1986 Management Audit of Baltimore Gas and Electric Company's Fuel Procurement and Purchasing Practices. ESRG Study No.

85-65/B. '

April, 1986 The Economics of Completing and Operating the Vogtle Nuclear Generating Facility.

ESRG Report No. 85-98. Co-author. I February, 1986 Approaches to the Development of Generating Plant Performance Standards for Palo Verde. Volume Is Main Report. ESRG Study No. 85-22/1. Co-author.

l Volume II: Technical Report. ESRG Study No. 85-22/2. Co-author.

4 October, 1984: Cost-Benefit Analysis of the

Cancellstion of Commonwealth Edison's Braidwdod Nuclear Generating Station.

ESRG Study No. 83-87. Co-author.

June, 1984: An Assessment of the Proposed Ellenville Wind Energy Project, ESRG Study No.

j 84-25. Principal investigator.

i 1

! i

  • I i

+ . -- _ _ - . - , _ - _ , - , . , - - - - - - . , - - - - - . . - , --,--_-,-,_,-,-._-_,.~..,-,-,n--.,._,-..-

M;y, 1984: Electric Ratn C n" qu'nc^, rf C^nc'llntien of th7 Midlond Nucirne Power Plant, ESRG Study No. 83-81/1.

Co-author.

May, 1984: Power Planning in Kentucky: Assessing Issues and Choices, Project Summary Report to the Public Service Commission. ESRG Study No. 83-51. Co-author.

January, 1984: Electric Rate Consequences of Retiring the Robinson 2 Nuclear Power Plant. ESRG Study No 83-10. Co-author.

December, 1983: Power Planning in Kentucky Assessing Issues and Choices, Technical Report I Long Range Forecasts of Electricity Requirements for Kentucky and its Six Major Utilities. ESRG Study No.

83-51/TRI.

1982/83: LEAP-LDC-Energy Alternatives Planning -

System, 3 volum3s. Co-author.

August, 1983: Preliminary Evaluation of the OKA Audit of Marble Hill Nuclear Project Costs, ESRG Study No. 83-48. Principal investigator.

August, 1983: An Evaluation of the New York Power Authority's Economic Justification for its Proposed Marcy-South 345 KV Transmission Facilities. ESRG Study No. 83-45.

Principal investigator.

J uly , 198 3 : Long Island Without the Shoreham Power Plants Electricity Cost and System Planning Consequences. ESRG Study No.

83-14. Co-author.

May, 1983: Report to the Counties of Orange, Dutchess, Sullivan, and Otsego, Re Is the Proposed Marcy-South Project Justified? An Assessment of PASNY's Case for Construction. ESRG Study No. 83-08.

Principal investigator.

March, 1983: A Report to the Washington, D.C. Public Service Commission on the Research Programs of PEPCO and WG&L, ESRG Study No. 83-11.

January, 1983/

April, 1983 Technical Assistance to Hayes / Hill, Inc.

in Evaluating and Projecting Nuclear Power Plant O&M Costs and Not Capital Additions, ESRG Study No. 83-7.

5-

I November , 1982 : Irqu^1 in SADCC En'rgy Plenning: Usaqq P7tt^rn9, R^"nurc7 Pnt"ntini end R gienni e

Possibilities, A Report for a seminar convened by Angola and hosted by Zimbabwe with cooperation from the Swedish International Development Agency.

Co-author.

August, 1982/

October, 1982 Technical Assistance to the Boston Redevelopment Authority on Fuel Use, Emissions, and Air Quality Impacts of Alternative Energy Strategies for Boston Electric Company and the Central Business District, ESRG Study No. 82-04.

October, 1982: The Economics of Closing the Indian Point Nuclear Power Plant, ESRG Study No. 82-40.

Co-author.

August, 1982: L*AP, LDC Energy Alternatives Planning System, volume 1 - overview, A Report to the Beijer Institute of the Royal Swedish Academy of Sciences. Co-author.

August, 1982: The Impacts of Early Retirement of Nuclear Power Plants: The Case of Maine Yankee, ESRG Study No. 82-91.1 Co-author.

August, 1982: Nuclear Capacity Factors: The Effects of Aging and Saltwater Cooling, ESRG Study No. 82-81. Co-author.

April, 1982: A Power Sup>ly and Financial Analysis of the Seabroot Nuclear Station As a Generation Option for the Maine Public Service Company. Co-author.

February, 1982: Energy Conservation and Employment in Ohio. A Report to the Office of the Consumers' Counsel, State of Ohio, ESRG Study No. 80-27. Co-author.

February, 1982: Energy Planning for Small Developing Islands. Report to United Nations Ocean Economics and Technology Branch, D.I.E.S.A., United Nations. ESRG Study No. 81-28. Principal investigator.

O

s Janu ry, 1982: Energy Dev91opm nt in K^ny9: Preblem7 end Opp ^rtunitirn. A rcport to tho K;nya Ministry cf En0rgy. ESRG Study No. 80-24.

Co-author.

January, 1982: Long Range Capacity Analysis for Alabama Power Company and the Southern Company System, A Report to Alabama Public Service Commission. ESRG Study No. 82-017CE.

Co-author.

October, 1981: LEAP, LDC Alternatives Planning Model, A Description. ESRG Study No. 81-24.

Co-author.

October, 1981: A Conservation Investment Scenario for The Northeast Utilities Connecticut Service Area, ESRG Study No. 81-12/1. Co-author.

July, 1981: Long-Range Capacity Expansion Analysis for Alabama Power Company and the Southern Company System. ESRG Study No. 80-63.

Co-author.

June, 1981: An Analysis of the Need for and Alternatives to the Proposed Coal Plant at Arthur Kill - A Report to: Robert M.

Herzog, Director, New York City Energy Office and Allen G. Schwartz, Corporation Counsel for the City of New York. ESRG Study No. 81-21. Co-author.

May, 1981: The Economics of Solar Hot Water Heaters as a Supply Alternative for Maui Electric: A Preliminary Appraisal.

Co-author.

February, 1981: District Heating Strategy Model Users Guide developed for the Department of Energy under contract with Argonne National Laboratory, ESRG Study No. 80-57.

Principal investigator.

January, 1981: The Conservation Investment Alternative for New York State, ESRG Study No. 80-42.

Co-author.

November, 1980: Economic and Need Analysis of the Proposed pumped Storage Facility at Brumley Gap, ESRG Report 80-08/R. Co-author.

0 9

a Oct bar, 1980: Th9 ESRG Electric 91 System 9 G narntien Mod 71, ESRG R: port 80-12 Ca-cuthar.

September, 1980: Emissions Impacts of Diesel Cogeneration in New York City, ESRG Report 79-30/8. 4 Co-author.

September, 1980 : Pollution Impacts of Solar Heat and Hot Water Systems, ESRG Report 79-30/A.

Co-author.

September 1980: Reducing New Enqland's Oil Dependence Through Conservation anc. Alternative Energy:

1978-2000, ESRG Report 79-29. Co-author.

June 1980: The Alternative Supply Scenario, ESRG Study No.

79-29/4, a technical report in the ESRG Study for the U.S. General Accounting Office, Reducing New England's Oil Dependence Through Conservation and Alternative Energy. Co-author.

February 1980: Long Range Forecast of Eastern Wisconsin i utilities' and Western Wisconsin Utilities' Electric Energy Requirements and Peak Demands,  !

ESRG Study 79-28. Principal investigator.

October 1979: The Annual Emissions and Air Quality Impacts of an Urban Area District Heating Systems Boston case Study, ESRG Study No. 79-19. Principal investigator.

4 July 1979: State Conservation Policy Case Forecast, Vol. -

II of ESRG Study No. 79-12, Electricity Requirements in New York State. Co-author.

4 September 1978: Update and Reconciliation of District Heating Studies of Argonne National Laboratory and Brookhaven National Laboratory. ESRG Study No.

78-08. Principal investigator. ,

January 1978: Industrial Cogeneration in New York State:

Identifying and overcoming Barriers, ESRG Study '

No. 78-01, A Report to the New York State Energy Office. Co-principal investigator. ,

November 1977: Profile of Targets for the Energy Advisory Service to Industry, ESRG Study No. 77-09. A l Report to the State Energy Office.  ;

  • T 8- 1 1

I

6 Octcber 1977: An A"rcar~^nt of th7 Pntentini fer Dintrict Hr7 ting in Frur M7 der Citirn, ESRG Study No.

i 77-08, A Report to Argonne and Brookhaven National Laboratories. Principal investigator.

i Other Professional Activities September , 1986 Incentives vs. Audits: The Regulation of Fuel Costs, presented to the Fifth Biennial Regulatory Information Conference sponsored by the National Regulatory Research Institute in Columbus, Ohio.

February, 1979: Analysis of Costs and Scarce Fuel Savings Associated with Nine Eastern and North Central Center City Conversions to a District Heating

, System. Co-author with D.J. Santini, A.A. Davis, and S.M. Marder. Argonne National Laboratory Report ANL/CNSV-TM-12.

August, 1978: An Assessment of the Potential for District j Heating in Four Major Eastern Cities. Co-author with R.A. Rosen. Argonne National Laboratory Report ANL/ ICES-TM-ll.

May, 1979: " Feasibility of District Heating and Cooling of Core Areas of Major Northeastern U.S. Cities By Cogeneration from Central Station Power Plants," presented at the Northeast Regional Science Association meetings ( Amherst, Mass. ).

Co-Author with D.J. Santini.

Consulting

] 1977 - 1978: Consultant to Brookhaven National Laboratory's Less Developed Countries Energy Project Awards and Honors

, 1964 - 1965: New York State Fellowship for graduate study l in physics.

3 1963: Eta Kappa Nu, electrical engineering honor society.

j Professional Societies International District Heating Association '

i I

4/87 t

! L i

_ _m.__ _ - _ _ _ _ _ _ _ _ _ _ _

4 ATTACHMENT 2 RELIABLE P00fER OIf IDIIG ISIAND FOR TIII NEAR TERIII (1987-1992)

PRELIMINARY Energy Systems Research Group, Inc.

120 Milk Street Boston, MA 02109 May 5, 1987

s o

RELTABLE POWER FOR THE NEAR TERM f1987-1992)

The next five years present special planning problems for Long Island. The problems are traced to the concentration of planning on the 809-MW Shoreham nuclear unit. With Shoreham, the LILCO system would have a capacity reserve margin of about 35 percent, 560 MW more than the 18 percent reserve target. This excess would increase to over 700 MW in 1988 and gradually decline thereafter as load grows.

However, the absence of Shoreham places Long Island in a potentially problematical near-term situation, although one which can be addressed successfully as discussed below. The issues concern the resources needed to satisfy the 18 percent NYPP reserve margin obligation, the provision of reliable service, and the supply of electricity at the lowest achievable cost. of course, had other options been pursued in Shoreham's stead, these problems would not have emerged. '

Two basic questions arise. First, does LILCO have sufficient resources to meet its NYPP taraat reserve reauirement and, if not, what steps can it take to meet it? Second, and more importantly, 1

can LILCO orovide reliable service on Long Island and, if not, what steps can it take to achieve acceptable levels of reliability? As we shall see, these two sets of questions must be distinguished from one another since, because of LILCO's unique i situation within NYPP, it is possible that the NYPP requirement could be satisfied without satisfying Long Island's reliability needs, and vice-versa.

The "near term" refers here to the period until 1992, the year when the planned second 345 KV underwater transmission line connecting LILCO to the rest of NYPP through Westchester is scheduled for completion. The addition of that capability, allowing for 560 MW additional off-Island purchases, provides a natural demarcation between near- and long-term planning considerations.

LDAda_. pad Resourcest NYPP and LILCO 1

The New York Power Pool (NYPP) currently plans on the basis of a 22 percent reserve margin. That is, firm resources --

installed capacity plus net firm purchases -- are targeted to be at least 22 percent above firm coincident peak demand. This minimum reserve margin is intended to ensure that the system will exporlence no more than one loss-of-load event in ten years on an average or probabilistic basis. That reliability target is typical of the industry.

owing to the " diversity" of loads amongst the electric utilities in New York State -- i.e., each utility's peak load in at a dif ferent time -- a 22 percent reserve margin for NYPP's 1

i coincident peak will be met if each utility has 18 percent reserves with respect to its own peak. Thus LILCO must maintain an 18 percent reserve margin to satisfy its NYPP responsibility.

The consequence of not meeting this level is that LILCO would have to make modest deficiency payments to NYPP. It does not follow, as we shall see, that system reliability would necessarily be threatened.

Examination of Table 1, showing LILCo's loads and resources projected for the near term, illuminates the apparent problem (NYPP, 1986b; NYDPS, 1986). The table excludes the Shoreham facility and assumes that the Nine Mile Point 2 plant does not enter service until 1988. The table demonstrates that LILCO's installed capacity will fall short of its NYPP requirement by about 248 MW in the summer of 1987 and by about 103 MW to 231 MW from 1988 to 1991. However, as indicated in Table 1 and discussed below, LILCO has ample opportunity to purchase capacity from surpluses in NYPP or New England to meet these needs. Indeed, it made not firm purchases of 454 MW in 1986 and had net imports on i peak of 607 MW in 1985. Thus, it must be emphasized that under any credible analysis, LILCO can satisfy the 18 percent reserve l capacity criterion.

TABLE 1 LILCO LOADS AND RESOURCES l 1987 - 1991 l Availablo for Peak Installed Total Capacity Firm Purchason Load capacity Without Needed for and/or i IMH1 (MW) Firm Purchacon* 18% Tarcet+ Other Supnnrt j 1987 3430 3743 3799 248 700 1988 3485 3937 4009 103 700 1969 3535 3937 4045 126 700 1990 3590 3937 4052 184 700 1991 3640 3937 4064 l 231 700

  • Includes 10 MW small power in 1987, increasing by 20 MW por yeart Fitzpatrick purchanon of 14, 12, 30, 20 and 14 (1987-91) and Municipal purchanes of 32, 30, 28, 25 and 23 MW (1987-91) .

& Could be achieved by purchanon, load management, conservation, or now capacity.

j LILCo's capacity situation by no means implies that there in insufficient capacity in NYPP to ensure reliability of electric service on Long Inland. Table 2 demonstrates that in the aboonco l

of Shoreham, NYPP has far more resourcon than it needs to natinfy 2

its minimum reserve requirements of 22 percent in order to meet its reliability criterion. Indeed, the capacity surpluses within NYPP shown here, provide the clue to the solution of LILCO's near-term capacity problems.

TABLE 2 NYPP IAADS AND RESOURCES 19s7 - 1991 Peak Load Capacity

  • Reserve Surplus +

DgQ, fMW) Marain fMW) 1987 23,450 31,543 34.5% 2934 1988 23,840 32,752 37.4% 3667 1989 24,150 32,811 35.9% 3348 1990 24,420 33,084 35.5% 3292 1991 24,730 33,150 34.0% 2979

  • Installed capacity plus firm purchases, minus firm sales (NYPP, 1986b).

+ Above the 22 percent NYPP reserve margin target.

Each of the recent studies of LILCo's near-term reliability situation and capacity requirements (NYSEO, 1985; NYPP, 1986a; and NYDPS, 1986) recognizes that LILCO could readily purchase additional power from sources outside Long Island in order to satisfy its reserve margin obligation to NYPP through 1991. This is apparent from the table above. (For example, the DPS study cited above identifies Con Edison as the primary source of such purchases, while the SEO study identifies Northeast Utilities and NYPP support.) But while such firm purchases would satisfy LILCO's contractual obligation, they would not essentially alter the technical situation.

At this time, LILCo capacity purchases from NYPP (and/or New England) to meet its NYPP reserve margin requirement, would not appreciably improve the reliability on Long Island, nor would it appreciably affect the reliability within NYPP as a whole. This is because LILCO can obtain power anyway through its existing transmission interlinks to provide emergency support. If LILCO enters additional firm power purchase agreements, such power would, in the main, simply substitute for power it would receive in any case in an emergency. In other words, the Long Island system has essentially the same level of reliability with or without additional firm purchases.

The real issue, then, is not LILCO's reserve margin in itself (by increasing tirm purchases, LILCO could readily increase its reserve margin to over 18 percent), but the reliability of service 3

to Long Island customers. Indeed, the reliability situation is complicated by the fact that LILCO's Nine Mile Point 2 capacity is on the other side of its transmission links to NYPP. LILCO has an interconnect capability of at least 20 percent, but its Lona Island system will provide reserves of only 10 percent in 1987 decreasing to about 6 percent over the next five years. Seen in this way, it is understandable why the near-term reliability of electricity supply on Long Island has received attention in the past few years.

However, the situation is not as urgent as it appears, for several reasons. First, the Long Island system has particular technical features that enhance its reliability. Second, a number of planning options have been proposed to solve the potential problem. These include load manaaement. conservation, new interruntible customers, imorovina the transmission system. and installina new canacity (e.g., combustion turbines). Third, LILCO has a number of emergency operating procedures to manage the reliable matching of resources to load. These factors will be discussed below.

Reliability and Reservest NYPP and Lona Island -

Before analyzing LILCO's system, a few observations regarding LILCO's purported reliability problems are useful. There are a number of factors that govern the reliability of an electric utility system and, thereby, the relationship between a reliability criterion and the capacity reserves required to satisfy it.

First is the reliability of the system's generating units themselves. Lower forced outage rates for generating units will result in greater system reliability. Generally, larger base-load units (nuclear plants in particular) have higher forced outage rates. Second is load shape - the pattern of demand as it changes from hour to hour. All things being equal, a lower system " load factor" will tend to improve reliability. Load factor is a measure of the average demand to peak demand. A low load factor will generally permit more opportunities for plant maintenance during seasonal low load periods, without jeopardizing reliability. This permits more resources to be available for improving reliability during high peak periods. Third is the degree of interconnection and available support from neighboring systems. The greater such interconnection, the higher is the reliability of the system. For each of these factors, greater reliability translates into lower reserve requirements to meet a given reliability criterion.

Finally, utility systems can invoke a number of operating options when peak load is expected to exceed available generating resources. These can include roscheduling of maintenance, and such " emergency operating procedures" (EOP's) as voltage 4

reductions (brownouts), customer appeals, use of emergency generator ratings, use of spinning reserve capacity and, if further imports are possible, utilizing the emergency ratings of selected transmission lines. Moreover, in the very unlikely event that these measures are not sufficient, a utility can still avoid area-wide customer disconnection by selective and limited load shedding for short periods of time.

How then does LILCO's system compare with NYPP's in these regards? NYPP concludes that its one-event-in-ten-years customer disconnect criterion is achieved with a 22 percent reserve margin, assuming zero effect of customer appeals. An illustrative comparison can be made as follows:

Plant Forced Outace Rates: LILCO's Long Island system generally has lower forced outage rates than the NYPP as a whole.

Its plants are smaller oil-fired facilities, and it has a higher percentage of peaking capacity than NYPP. By contrast, NYPP will have more than thirty percent nuclear and coal capacity.

Load Factor: LILCO's load factor is expected to range between 53 and 54 percent during the 1987 to 1991 period, while NYPP as a whole is expected to have a much higher load factor, more than 63 percent, over the same period. (It should be noted that although such a high load factor tends to necessitate a larger reserve margin, it can improve the economics of a utility system.)

Dearee of Interconnection:

In NYPP's analysis of its reliability and reserves, the degree of interconnection support assumed between NYPP and neighboring systems (Ontario Hydro, NEPOOL, and PJM) was taken at about 17 percent of its then-projected peaks (NYPP, 1981). Over the 1987-1991 period, LILCO will have about 1,000 MW of interconnection. Of that, approximately 100 MW is dedicated to wheeling to the Long Island customers of the New York Power Authority, and perhaps 200 MW may not always be available due to various operating constraints.

Thus, approximately 700 MW will be available, which translates into 20 percent of LILCO's average peak load during that period.

Thus, relative to the NYPP assumptions LILCO's interconnect situation appoars relatively strong.1 ,

Emeraency Ooeratina Procedures Two of LILCO's emergency operating procedures deserve attention here. First, LILCO has a five percent voltage reduction capability of about 4.1 percent of its peak load, whereas the NYPP-wide capability assumed in NYPP's study of its overall requirements was 3.2 percent. Moreover, all of LILCO's capability is automatic (remote control), whereas for 1 However, the precise status of these interconnects must bo considered in a full reliability modelling analysis.

5

NYPP, only 2.4 percent is automatic with the remainder achieved manually, thereby taking more time to implement.

In addition, in the NYPP study, customer appeals were assumed to occur after voltage reduction and were assumed to have no effect in the satisfaction of NYPP's reliability criterion. For LILCO, by contrast, customer appeals are made prior to voltage reduction (i.e., in the morning of a day in which problems are emerging), and are thus more likely to be effective.

By virtue of the foregoing considerations, it appears that while the electricity system on Long Island may have crima facie reliability problems, it may also have a number of offsetting advantages. Thus, while NYPP may require a 22 percent reserve margin, LILCO's Long Island system may require a significantly lower reserve margin to achieve the same level of reliability.

Indeed, as we shall see below, NYPP's own study of the LILCO system suggests that this is the case.

Assessina Reliability Each of the three aforementioned studies -- NYSEO (1985),

NYPP (1986b), and NYDPS (1986) -- indicates that, in the absence of actions, the reliability of LILCO's electricity supply system on Long Island will be problematical over the next several years.

However, the studies also discuss various solutions to this problem, and indicate that by 1992, with the new 350 KV underwater cable from Westchester to Long Island completed, the problem would be largely overcome, albeit temporarily if load growth continues.

This, then, would set the stage for a more orderly development of demand- and supply-side planning and operating measures in the subsequent years. In the meantime, over the 1987 to 1991 period, measures can be and are being taken to address potential reliability problems.

The reliability criteria on Long Island are based upon the overall reliability criterion of NYPP. The intention of these criteria is to limit the number of voltage reductions (brownouts),

customer appeals, and customer disconnections that could occur.2 The NYPP criterion is that NYPP's generating capacity shall be planned in such a manner that, after duo allowance for scheduled 2 Customer disconnections, if they ever occurred, would likely be in the form of rotating blackouts (short-term load shedding from blocks of customers) as opposed to area-wide blackout.

6

e a

maintenance, forced and partial outages, interconnections with neighboring systems and available operating procedures, the probability of disconnecting firm load due to generation insufficiency will be, on the average, no more than one day'in ten years. (NYPP, 1986)

Moreover, NYPP also expects that under normal weather conditions the number of voltage reductions should be limited to an average of four per year. Both of these criteria assume no load relief from customer appeals. They give rise to the Pool's 22 percent reserve requirement, with 18 percent for member systems.

The freauency of voltaae reductions is determined assuming thatgeneratorsareattheirnormaloperatinggimits(notmaximum capability), that capacity on spinning reserve is not available to meet load, and that all available interconnect support has been used. The freauency of disconnects is determined assuming that all available resources and emergency operating procedures (including voltage reductions, emergency generator ratings, and spinning reserve, but not appeals), are deployed to meet load.

As discussed earlier, LILCO's interconnections to neighboring utilities could provide 600 to 700 MW support to Long Island if needed. These transmission links include the 345 kV Y-50 underwater tie to con Edison in Westchester (Dunwoodle-Shore Road), two 138 kV ties to con Edison at Jamaica, Queens, and one 138 kV tie to Northeast Utilities (Norwalk-Northport) from LILCO's Northport plant.

The NYPP (1986) study's results on voltage reductions without Shoreham, and without any measures to improve supply and reliability, for the critical 1987 to 1991 period are contained in Table 3.

3 Spinning reserve is capacity kept in operation but not connected to load so that quick response resources are available to the Pool. In fact, to the extent that capability for automatic remote control voltage reduction is available, spinning reserve capacity can be used to meet load before actual voltage reduction is needed. Thus, LILCO can count about 140 MW of its spinning reserve for this purpose.

7

o

  • i TABLE 3, NYPP'S PROJECTIONS OF ANNUAL NUMBER OF LILCO VOLTAGE REDUCTIONS (Assumina LILCO Forecast)

Assuming Assuming 600 MW 700 MW Transfer Transfer Canacity Canacity 1987 8 4 1991 18 11 NYPP also performed analyses assuming the SEO's load forecast, and obtained voltage reductions approximately one-third i

lower, 12 voltage reductions per year at 600 MW transfer capacity and 7 voltage reductions at 700 MW transfer capacity in 1991, the i most critical year.

The NYPP study did not provide results on the frequency of disconnects, su) that only its voltage reduction results can be i compared with the NYPP criterion. If this is done, it can be seen that under the study assumptions, in 1987 the number of voltage i reductions would satisfy the NYPP criterion of 4 per year if.700 MW of transfer capacity were available (which is very likely to be the case), but would be higher than the criterion at 600 MW j transfer capacity. The voltage reductions are found to increase

! as load grows, so that by 1991 the number of voltage reductions

! reach 7 to 11 per year at 700 MW transfer capacity and 12 to 18 l

per year at 600 MW transfer capacity.

These results suggest that to bring the frequency of voltage

reductions down to the NYPP criterion of 4 per year (or to LILCO's l criterion of 3 per year), about 100 MW to 300 MW of resources I

and/or demand management would need to be in place by 1991. They also indicate that by 1992, with the second 345 kV underwater line in service, LILCO's near-term problems would be solved.

The NYPP report notes that its results are probable outcomes, not actual outcomes. The reliability could be lower, for example, if firm load grew more rapidly, if weather conditions were more severe (e.g. very hot summer), or if plant availabilities were less than assumed in the study. On the other hand, the reliability would be better if load growth were lowered, if weather were mild, or if plant performance were better than assumed.

This suggests actions to mitigate potential reliability problems. Conservation and load management could reduce the impact of possible high load growth and severe weather conditions, 8

a Q - +a - 1 _-

  • i l

and could improve reliability under anticipated conditions (perhaps providing a substantial portion of the needed 100 to 300 MW). Moreover, improvements of existing plant availabilities could also help meet reliability goals over the critical 1987 to 1991 period. Further discussion of measures to improve Long Island's electric supply reliability situation will be provided in the next section.

Finally, as the NYPP report noted, power imports above the 700 MW level it assumed as the maximum in its study may be transmitted to Long Island on occasion if it were capacity deficient. Indeed, perhaps as much as about 900 MW could be transmitted. While the NYPP report states that it "is unlikely this can be done consistently," nonetheless the existence of such support, even on an occasional basis, would reduce the frequency of voltage reduction below that determined by the NYPP study.

Moreover, the long-term emergency (LTE) ratings of LILCO's tie lines can permit a few hundred megawatts of additional support for up to four hours,4 if (as is expected) the resources are available from neighboring systems.

Thus, while the NYPP reliability analysis indicates some cause for concern and action, there are substantial reasons to believe that (a) as discussed above, the situation may be less problematical than NYPP finds and, (b) the situation is within a domain where meliorative action can be taken. A full and independent reliability assessment is needed.5 Measures Available to Imorove Reliability A range of actions are available to improve the reliability

, of electricity supply on Long Island in the near-term. These fall l into the following categories:

! 1. Increase available generating capacity on Long Island.

l 2. Increase transmission tie line capacity to Long Island.

I 3. Implement measures to reduce peak loads.

Potential measures exist for each of these categories, albeit with

! different lead times. Indeed LILCO has already begun to implement some of them.

4 Typically, daily peak loads in the LILCO system persist for

several hours. However, use of the LTE ratings of the tie lines i for four hours, could provide sufficient support to help carry the l system through until load declines somewhat (e.g., by about 50 to 200 MW).

l i

5 Preliminary results of an ESRG study of reliability on Long Island indicate better reliability than is reported in the NYPP study.

l 9

's 1 Increase Available Generatina Canacity on Lona Island

a. New Combustion Turbines: New gas turbine capacity could 4

be in place by about 1989 or 1990, assuming that site licensing, the most time-consuming part of the process, is already underway. LILCO began pursuing this option in early 1986 and has completed a siting study, has sent out specifications for bid, and is in the process of preparing licensing documents for a nominal 200 MW combustion turbine plant. Such capacity could provide sufficient resources, either by itself or, preferably, along with other measures, to bring LILCO system reliability-in line with the NYPP standard.

4

b. Imoroved Availabilities of Existina dnits: By stepping up its maintenance activities and by purchasing critical spare part components for its generators, LILCO can improve its system reliability in the coming years.

Indeed, the DPS report has noted that LILCO's active maintenance program has already produced salutary results - lower forced outage rates during critical i recent summer months. Moreover, the DPS notes that LILCO has been considering the purchase of spare parts for its generators which "would improve generation availability and... avoid prolonged outages."

c. Lease Canacity: Con Edison has several hundred MW of combustion turbine capacity on barges in the East River, including four 135 MW combustion turbines at its Gowanus station. The use of these power plants would need to be j negotiated with Con Ed. Furthermore, some substation work would be necessary to connect them to LILCO's system and siting approval would need to be obtained.

These are substantial barriers, though the relevant New York State agencies (DPS, DEC, SEO) could expedite this process to quickly bolster the reliability of Long Island's system.

d. Shoreham Back-un Diesels: There are about 20 MW of diesel generating units at the Shoreham station, which were originally intended as emergency back-up for the facility. With Shoreham abandoned, this capacity could l

become available to help meet Long Island electricity loads.

l Increase Transmission Line Canacity to Lona Island

a. Uoarade the Y-50 Line: LILCO expects to complete an upgrade of its Y-50 345 kV underwater transmission line to Westchester by the summer of this year. This project

[ will provide 50 MW of additional capacity to LILCO in ,

i' the summer of 1987.

10

. . .m . - . _ _ _ _ . . _ .. ._ . _ _ . ,. . _ _ _ _ _ .

b l- b. Further Unorade of the Y-50 Line: LILCO is now considering an additional upgrade of theLY-50 line to obtain an additional 50 MW of transfer capacity. It is anticipated that this project could be completed by-1989.

c. Comoletion of the New NYPA Tie Line: A second 345 kV submarine cable between Westchester and Long Island (Yonkers - Oyster Bay) is currently expected to be completed by 1992. This line will provide an additional 560 MW of transfer. capacity to.LILCO, and is the principal basis for eliminating LILCO's potent'al near-term reliability problems. <

Reduce Peak Loads

a. Interruotible Customers: As of May, 1986, LILCO had 12 customers on its restricted demand service rate (for a lower rate these customers would reduce their load on 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />' notice), which provides 8 MW of interruptible load'(NYDPS, 1986). With PSC approval, a more attractive rate was designed which LILCO expected would increase the amount to 10 MW.

l However, LILCO has since moved more aggressively to pursue this option. _Its two new programs (currently awaiting Commission approval) are its new Restricted Demand Service. Rate and its Energy Coalitions concept

-(LILCO, 1986). The first establishes a rate for new interruptible customers who could sign up individually.

The second permits groups of customers to sign up together, thus providing LILCO substantial' peak load l interruption capability,- while permitting the group of customers to share the burden of load reduction.

[ LILCO currently expects a total of about 37 MW of interruptible load under its interruptible programs in 1987 and 51 MW in 1988. The Commission has approved these and other programs, for a total of about 50 MW in l 1987 and 75 MW in 1988.

b. Direct Load Control: It is possible to reduce the contribution to peak loads of certain weather-sensitive and other devices that can be controlled at and around the time of peak on an automatic basis, without affecting the overall service delivered. For LILCO, controlled water heaters and controlled air conditioning may provide such opportunities,
c. Conservation: LILCO can also contribute to its system's reliability, and reduce overall electricity costs, by 11 l

-,_..-m. ., _.._ _. _. _ - .. . - . . . _ . _ . . - - , - _ . - - , . _ , _ . - - - - - . . . . _ .

a promoting conservation. The DPS has urged LILCO to move

" aggressively to take full advantage of end-use efficiency programs," and to increase its expenditures to pursue these goals (NYDPS, 1986).

Table 4 below su;4marizes the possible measures, gives indicative estimates of possible impacts, and places them in their approximate completioni sequence.

TABLE 4 INDICATIVE NEAR-TERM MEASURES FOR IMPROVING RELIABILITY (Mecawatts)

New Y-50 New 345 Load Total Cumulative CIg Uoorades KV Line C&LM Control Added in Place 1987 50* 50* 100 100 1988 25* 26 126 1989 50+ 50 176 1990 200+ 30 230 406 1991 30 30 436 1992 560* 996

  • underway

+ planned l The table is conservative. It does not include utilizing l Shoreham back-up diesels, new conservation programs, and the possible further impacts of LILCO's interruptibles programs, or the potential for adding further peaking capacity (such as leasing the barged units from Con Edison). It nonetheless shows that there are means to make the necessary adjustments for the system l

to operate reliably through the critical 1987 to 1991 period without Shoreham.

12

4 4:

DOCbETED USNRC-

^

May 6. 1987 1R SY -6 P4 :27 UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION jIlk OC Before the Commission f

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket Nos. 50-322-OL 7

). 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

CERTIFICATE OF SERVICE 1

1 I hereby certify that copies of SUFFOLK COUNTY, STATE OF NEW YORK AND TOWN OF SOUTHAMPTON SUBMISSION OF ADDITIONAL AFFIDAVIT IN OPPOSITION TO LILCO MOTION FOR EXPEDITED CONSIDERATION OF 25%

POWER REQUEST have been served ~on the following this 6th day of May 1987 by U.S. mail, first class, except as otherwise noted.

Lando W. Zech, Jr., Chairman Comm. James K. Asselstine U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Room 1113 Room 1136 1717 H Street, N.W. 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555 William C. Parler, Esq. Comm. Frederick M. Bernthal U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 10th Floor Room 1156 1717 H Street, N.W. 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555 t

e i

I f

i I

o 7 i Comm. Thomas M. Roberts * .

Alan S. Rosenthal, Chairman

U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Room 1103 Appeal Board 1717 H Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Howard A.-Wilber Gary J. Edles, Esq.

Atomic. Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. -20555 Morton B._ Margulies, Esq. Comm. Kenneth M. Carr*

Atomic Safety and Licensing Board U.S.. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20555 Dr. Jerry R. Kline William R. Cumming, Esq. .

Atomic Safety and Licensing Board Spence W. Perry, Esq.

U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C. 20472 Mr. Frederick J. Shon Anthony P. Earley, Jr., Esq.

Atomic Safety and Licensing Board General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C. 20555 175 East Old Country Road Hicksville, New York 11801 Ms. Elisabeth Taibbi, Clerk W. Taylor ~Reveley, III, Esq.**

Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Mr. L. F. Britt Stephen B. Latham, Esq.

Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River,-New York 11792 Ms. Nora Bredes

. Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm-195 East Main Street 1717 H Street, N.W.

Smithtown, New York 11787 Washington, D.C. 20555

. i Mary M. Gundrum, Esq. Hon. Michael A. LoGrande -

New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H. Lee Dennison Building Room 3-116 Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O. Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq. Fabian G. Palomino, Esq. **

Suffolk County Attorney Special Counsel to the Governor Bldg. 158 North County Complex Executive Chamber, Rm. 229 Veterans Memorial Highway State Capitol Hauppauge, New York 11788 Albany, New York 12224 Richard G. Bachmann, Esq.

  • David A. Brownlee, Esq.

Oreste Russ Pirfo, Esq. Kirkpatrick & Lockhart George E. Johnson, Esq. 1500 Oliver Building U.S. Nuclear Regulatory Commission Pittsburgh, Pennsylvania 15222 Office of General Counsel Washington, D.C. 20555 Mr. Jay Dunkleburger Mr. Stuart Diamond New York State Energy Office Business / Financial Agency Building 2 NEW YORK TIMES Empire State Plaza 229 W. 43rd Street Albany, New York 12223 New York, New York 10036 Joel Blau, Esq. Mr. Philip McIntire Director, Utility Intervention Federal Emergency Management N.Y. Consumer Protection Board Agency Suite 1020 26 Federal Plaza Albany, New York 12210 New York, New York 10278 Douglas J. Hynes, Councilman '

Town Board of Oyster Bay )

Town Hall .

Oyster Bay, New York 11771  ;

0V46W

. Lawrence Coe Lampher KIRKPATRICK & LOCKHART

. 1800 M Street, N.W.

, South Lobby - 9th Floor Washington, D.C. 20036-5891 t

  • By Hand
    • By Federal Express

__