ML20235M178
| ML20235M178 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/14/1987 |
| From: | Irwin D HUNTON & WILLIAMS, LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20235M163 | List: |
| References | |
| CLI-87-04, CLI-87-4, OL-3, NUDOCS 8707170095 | |
| Download: ML20235M178 (20) | |
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LILCO, July 14,1907 4
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
_Before the Atomic Safety and Licensing Board
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In the Matter of
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LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3
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(Emergency Planning)
(Shoreham Nuclear Power Station,
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(25% Power Operation)
Unit 1)
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1 MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%
L Preliminary Statement In accordance with CLI-87-04 (June 11,1987), Long Island Lighting Company (LILCO) hereby refiles its Request for Authorization to Increase Power to 25% (25%
Power Request or Request) at Shoreham and thus moves this Board, pursuant to 10 CFR S 50.57(c), for authorization to operate Shoreham at 25% of rated power.
Because of the power thcrtage on Long Island - four forced power alerts have already been declared this year - LILCO requests that all necessary proceedings on this
. Motion be conducted in an expedited fashion. However, in light of uncertainty about this Board's jurisdiction and the potential limitations on its availability be:ause of nrior commitments, LILCO has simultaneously asked the Commission 1/ o appoint a succes-t sor Licensing Board to take jurisdiction of this Motion, and to set a schedule for any necessary proceedings.
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Motion for Designation of Licensing Board and Setting Expedited Schedule to Rule on LILCO's 25% Power Request, July 14.1987, filed herewith, i
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' 3 Pending Commission action on this request, LILCO is not requesting this Board to take any specific steps to activate this proceeding.2/
II. Background 1
'LILCO has held a license to operate the Shoreham Nuclear Power Station, cur-rently limited to 5% of rated power, for over two years now.EI The Company has suc-cessfully operated the plant at that level, even generating commercial electricity tem-l porarily to its power grid. Meanwhile, proceedings on the one remaining aspect of 1'
LILCO's app!! cation to permit modification of that license so as to permit ope ation at 100% of rated power - ofisite emergency planning - have been underway continuotoly 1
for over four years by now, since the spring of 1983. While many matters have been re-solved, there is no certainty as to when those proceedings will be sufficiently complet-ed to result in issuanch of a 100% license.
At the same time, electric demand on Long Island has continued inexorably to grow. The insistent nature of that ir2 crease, combined with the uncertainties about completion of the 100% emergency planning proceedings, have 1mpelled LILCO to re-1 quest interim operation of Shoreham at 25% of rated power.
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in this Motion, the materials LILCO is relying on are the April 14 Ilequest for i
Authorization to increase Power to 25% and attached affidavits; the subsequent errata filed May 20, 1987; the May 11 affidavit of Adam Madsen; and the July 14 affidavit of Adam Madsen. Each of these documents except the July 14 affidavit, which is attached hereto, has been previously filed with the Commission and all Boards and served on all parties. Mr. Madsen's July 14,1987 Affidavit, served unexecuted in the interest of ex-pedition, will be re-served as soon as it has been signed and notarized.
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Facility Operating License, NPF-36 was issued on July 3,1985.
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tt LILCO accordingly filed its Request for Authorization to increase Power to 25%, along with a Motion for Expedited Coinmission Consideration, with the Commis-sion on April 14,1987. Those papers, citing Long Island's immediate need for additional electric generation and the length of the ongoing emergency planning proceedings, re-quested authorization pursuant to 10 CFR S 50.47(c)(1) to increase power to 25% in time for the 1987 summer peak, and the institution of sufficiently expedited proceed-l Ings by the Commission itself to achieve that goal. On April 27 and May 5 and 6, Inter-venors filed various pleadings in opposition.Y The Staff filed its response on April 29, taking no position on the merits but supporting LILCO's Request insofar as it sought the Commission's expedited consideration. Thereaf ter LILCO responded to tha Interveners' opposit'on on May 12,1987, and on May 13,1987, the Staff filed its Schedule for Review of LILCO's 25% Power Request which indicated that the technical review would tse completed and the final Safety Evaluation Report issued in July.E in April, the Staff and its contractors also commenced a technical review of LILCO's 25% Power Request. The Staff and its contractors met with LILCO several times in April and May to discuss various aspects of LILCO's 25% Power Request.
In-tervenors' representatives were present at these meet.ags. In connection with their re-view, the Staff and its contractors made numerous requests for supplemental 4/
Interveners filed their Response in Opposition to LILCO's Motion for Expedited Commission Consideration, Motloa for Order Directing NRC Staff to Cease Unauthor-Ized Review and Additional Affidavit in Opposition to LILCO's Motion for Expedited Consideration on April 27, May 5 and May 6,1987, respectively. In addition, on May 7 and 11, Interveners sent letters to Victor Stello opposing Staff review of LILCO's 25%
Power Request.
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Coples of all pleadings filed with the Comm!ssion in connection with LILCO's 25% Power Request were served on this Board.
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Information and data concerning the 25% Power technical analyses. LILCO provided this information to the Staff and the Staff's contractors and to Interveners' representa-i 1
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tives as well. As u.nid June,1387, the Staff review was well underway and, if on i
schedule. largely comphte in several respects.
I On June 11,1987, the Commission issued a decision, CLI-87-04, concluding that
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it could not rasolve various issues presented in the 25% Power Request before the end l
of summer 19f 7 if it followed the norma) adjudicatory hearing procedures in 10 CFR S 50.57(c) and 10 CFR Part 2 Subpart G.E Accordingly, the Commission denied the Re-quest, but did so without prejudice on the merits, stating that LILCO "may refile its
[25% Power Request) under 10 CFR S 50.57(c) with the Licensing Board when and if it believes that some useful purpose would be served thereby." CLI-87-04 at 2.
LILCO now avails itself of the opportunity to renew its request by filing with this Licensing Board this Motion adopting, incorporating and thereby renewing the 25%
Power Request. This Motion relies upcn all the technical analyses, data and arguments contained in the 25% Power Request, and extends the informanon related to need for power beyond the summer of 1987. In its 25% Power Request, LILCO estab!!shes three S/
In its decision, the Commission focused specifically on LILCO's claim that Long Island has an immediate summer 1987 need for power. It is important to note that Long Island's immediate and urgent need for power this summer is only one of a number of distinct grounds, each of them sufficient to authorize 25% power operation for Shoreham pursuant to S 50.47(c)(1), urged by LILCO. That provision permits operation of a nuclear plant at above 5% of rated power notwithstandmg the pendency of issues ursder S 50.47(b) upon a showing of any of the following: (1) that deficiercles in the emergency plan or plans are not significant for the plant in questiont (2) that adequate interim compensating measures have been taken or will be taken promptlyt or (3) the existence of other compelling reasons to permit plant operation.
LILCO's Request, which is incorporated into and relied upon as a basis for this Motion, demonstrates that each of these grounds is satisfied.
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~4 distinct " compelling reasons" pursuant to S 50.47(c)(1) for authorizing 25% power op-eration for Shoreham. One of these, Long Island's immediate need for power, focuses chiefly on the summer of 1987. As this hiotion and the accompanying Affidavit of Adam Madsen demonstrate, the need for power on Long Island will continue to grow be-yond the summer of 1987 and will become even more compelling by the summer of 1988 and thereaf ter. This and the fact that Shoreham has long been complete and ready to operate make expeditious tretstment of the 25% Power Request appropriate.
Although the Commission instructed LILCO to refile its 25% Power Request with "the Licensing Board," It did not designate either a Board or a specific docket, leaving it instead in the general docket,50-322-OL. Further, although the 25% Power Request requires' application of an emergency planning regulation, 5 50.47(:)(1), the l
factual issucs required to be determined are of a conventional safety nature rather than involving emergency planning precepts per se. Indeed, the premise of the 25% Power Motion is that various emergency planning matters normally required to be satisfied be-fore full power operation - matters now being litigated before this Board -- are n_ot yet disposed of. Thus there is question about whether the Commission intendell the 25%
Power Motion to f all within this Board's jurisdiction.
In addition to questions of jurisdiction, LILCO is well aware that both this Board and the OL-5 Board are already neavily engaged in hearir.g and deciding various emergency planning issues relating to LILCO's application for a full power license. In-l I
deed, it is the length of and difficulty in reaching cicsure on these proceedings, 7/
LILCO believes that it is clear that the 25% Power Motion does not IcIl within ihe ftirisdiction of the other emergency planning Board, the OL-5 Board, whose jurisdic-tion involves only the February 13,1986 exercise.
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'4 6-l combined with Long Island's immediate need for additional electric capacity, which I
have impelled LILCO to file its 25% Power Motion. LILCO recognizes that, in light of their prior commitments, it would be unrealistic to expect either of the Shoreham Li-censing Boards to adjudicate this Motion and the 25% Power Request expeditiously to a conclusion on the merits at this time. That the OL-3 and OL-5 Boards already share a common member gives added weight to the conclusion that assignment of this Motion to either of those Boards would both hinder their existing work and make expedited I
1 consideration of the merits of this Motion impractical. Accordingly, LILCO is filing with the Commission, simultaneously with this Motion, a Motion for Designation of Li-censing Board and Sctring Expedited Schedule to Rule on LILCO's 25% Power Request.
This Motion to the Commission, a copy of which is attached, also proposes in some de-1 tall a reasonable and expeditious hearing schedule, shou 1d herrings be needed.
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i LILCO thus requests this Board only to take jurisdiction of the 25% Power Mo-tion, but does not request the Board to take any action on it, pending Commission ac-tion.E III. Long Island's Need For Power As is demonstrated in the 25% Power Request and the July 14,19B7 affidavit of Adam Madsen, Long Island's need for power is not a short term concern;it will continue and only worsen into 1988 and beyond. The 1987 summer demand for power exceeds LILCO's current power supply capabilities.EI LILCO hr.s taken aggressive steps to meet g/
in order to minimize any delay otherwise inevitably resulting from the time nee-essary for the Commission to act, LILCO has offered further discovery to Interveners during the interim period. See attached letter of this date from Donald P. Irwin, one of counsei for LILCO to counsel for Interveners.
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See 25% Power Request at 104.
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7 this shortfall. 'However, these steps, by themselves, are inadequatet the only practical
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near-term solution is to operate Shoreham.
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Although LILCO's 25% Power Request focuses primarily on 1987 summer needs, the need !ct power does n0: cnd with the p=ing of this peak Oum=r period. As the accompanying affidavit of Adam M. Madsen indicates, there is a peak win'er period which may also give rise to concern. During the winter peak period of 1987-88, nor-mally scheduled major equipment overhauls and outages will be necessary to preparn for next summer's peak load period. Current planning for January 1988 includes over-hauls at any given time of generating facilities representing up to approximately 650 I
MW of LILCO's generating capacity. In addition, LILCO projects an average forced out-age and daily unavailability of 800 MW during the winter of 1987-88. While current forecasts suggest that LILCO can meet winter peak demands, the energy situation is such that unforeseen loss of generation or transmission capability could result in j
l reliability problems. Already in 1987 LILCO has had to declare power alerts, two of them befcre the June 1 beginning of the r,ummer peak season, and two more since.
Forecasts for the 1988 summer peak loads reflect a progressively worsening situation, with shortfalls of approximately 400 MW cur ently anticipated.E This can be eased by operation of Shoreham at 25% power pending completion of 100% power proceedings.
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Even assuming, artruendo, that action on LILCO's Request could not be complet-
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ed in time to meet the winter peak period of 1987-88, this Request for authorization to operate Shoreham at 25% power still warrants expeditious consideration. Interveners have asserted that initial startup operation at 25% power is itself unreliable. Suffolk County Response at 20. While LILCO does not concur with that position given the ex-tensive 5% low power testing already conducted at Shoreham, operation by early 1988 I
will insure that the Interveners' expressed concerns in this regard can be addressed. By the time the peak summer load of 1988 ts experienced, initial operation and power as-cension testing can be completed.
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, Nor will Long Island's er4ergy crisis end in the foreseeable future.
As Mr. Madsen's July 14,1987 affidavit further shows, continued growth in demand, even accounting for additional interim alternative generating capacity and aggreisive con-servation/ load management efforts, will only worsen the capacity shortfall. In fact, LILCO's prwlicted shortraR9 are anticipetM in increase steadily to 400 MW by 1992, de-spite the addition of 200 MW of new capacity in 1989 and LILCO's aggressive conserva-tion and load management efforts. Without operation of Shoreham to remedy the im-mediate near-term concerns, serious energy deflulences will contin'ie on Long Island.
IV. Conclus'.on For the reasons stated above, LILCO respectfully requests that this Board, pending the Commission's action on LILCO's request for designattan of a successor Board, accept jurisdiction of this Motion. LILCO does not request that this Board initi-ate any proceedings in the interim.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY W. Taylor Reveley, Ili Donald P. Itwin Hunton & Williams Post Office Box 1535 Richmond, Virginia 23212 Anthony F. Earley, Jr.
Long Island Lighting Company 175 East Old Country Road
- Hicksville, New York 11801 DA TED: July 14,1987
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LILCO, July 14,1987 e
AFFIDAVIT OF ADAM M. MADSEN IN SUPPORT OF MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%
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i City / County of Nassau j'
3 Adam M. Madsen, being duly sworn, deposes and says:
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(1)'
My name is Adam M. Madsen.
My business address is Long Island 4
Lighting Company, I'l5 E. Old Country Road, Hicksville, NY.11801.
(2)
I am currently Vice President, Corporate Planning, for the Long Island Lighting Company. I have been employed by the Long Island Lighting Company for 26 years and have served in a number of positions, including Manager of Engineering and Manager of the Planning Department. Since 1978, I have been LILCO's representative 3
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representative on the Northeast Power Coordinating Council's Joint Coordination Com-mittee.
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(3)
I hold a Bachelor of Electrical Engineering degree from Manhattan Col-I j
lege and a Master of Science degree in Nuclear Engineering Science from Long Island Urdversity, and I am a registered Professional Engineer in the State of New York..
(4)
As Vice President for Corporate Planning, I have the overall responsiblil-l ty for supervising and directing the development'of the Company's electric load fore--
casts and the planning of the generation and transmission facilities needed to meet 1
projected loads. In exercising this responsibility, I and persons under my direction and control have developed extensive knowledge of the electric demand and supply.
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situation not only for Long Island but also for New York State and the Northeast region.
I have been intimatelf involved in the Company's efforts to deal with the electric ener-gy crisis that has developed on Long Island.
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I previously submitted an aff! davit, dated April 13, 1987, attached to LILCO's April 14,1987 Request for Authorization to increase Power to 25% (LILCO Re-quest) and attesting to the accuracy of the description of the need for Shoreham's power in LILCO's Reque:;t. That description focused on Long Island's immediate 14eed for additional capacity for the 1987 summer peak (Request at 104-13), the absence of immediately available alternatives to Shoreham to meet it (Request at 113-16), and the need to reduce Long Island's oil dependence (Request at 117-21).
(6)
I have also previously submitted an affidavit, dated May 11,1987, sup-porting LILCO's May 12,1987 Reply to Interveners' Opposition to Expedited Considera-tion of LILCO's 25% Power Request (LILCO Reply). That affidavit responded to the Af-
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fidavit of William E. Davis of the New York State Energy Office, which in turn responded to my April 13,1987 affidavit. My May 11 affidavit analyzes various meth-odological difficulties with Mr. Davis's affidavit which derive from New York State's 1
b opposition to Shoreham (May 11 affidavit' at 4-9); summarizes the widespread expert consensus that a bulk power supply crisis exists now on Long Island, and the extent to which Mr. Davis f ails to recognize it (Ld. at 10-11,16-19)'; demonstrates that each of the alternatives to Shoreham proposed by Mr. Davis has already been taken into account by LILCO in its assessment of energy supplies (id. at 11-16); and presents a further analysis of energy supply and reliability on Long Island through 1992 (Ld. at 16-20 and Table 6).
(7)
The purpose of this Affidavit is to suma.arize, largely by reference, the record on the power supply crisis now existing on Long Island, emphasizing (a) the pres-ent degraded situation, (b) the further likelihood of outright forced power reductions or i
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" the summer of 1988, (c) tne significant likelihood of a shortf all on Long Is-j l
land between now and the summer of 1988, and (d) the overall electric power supply
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1 situation on Long Island through 1992.
(8)
There is already an electric supply shortage en Long Island. In 1986 i
LI.".CO's installed capacity fell short of the reserve margins required by the New York Power Pool. The peak demand for 1986, 3441 MW, substantially exceeded the projec-tions of both LILCO (3380 MW) and the New York State PSC (3372 MW). Brownouts or blackouts were avoided only by the facts that all interconnections were available, the suramer weather was the coolest in 10 years, and, even more important, the amount of generation out of service on LILCO's system at peak was extraordinarily low (about j
315 MW, versus about 700 MW normally out of service on the average over the four summer months). Already, four power alerts have had to be declared this yaar. Two occurred even prior to the summer period, on February 9 and April 3.
A third power alert was declared on June 1; cnly lower than forecast af ternoon temperatures pre-i vented system disruptions. In each case, only extraordinary emergency spot purchases
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of power prevented blackouts or brownouts. See LILCO's Request at 104-09; May 11 af-l fidavit, SS 25-29. And most recently, on July 10, power usage hit a near-record of 3421 M W.
A power alert was declared late in the af ternoon that dry when two of LILCO's l'
power plants suffered unexpected outages. LILCO immediately made public appeals for reduced power usage. Fortunately, during the normal peak period demand began to l
flatten out and system disruptions were averted. Even so, electrJe dsage was only 21 MW chort of LILCO's all time record.
1 (9)
Capacity shortages will continue to exist as of the summer of 1987. The total generation and emergency import resources necessary to enable Lcng Island to meet its 1987 expected peak load of 3695 MW with suitable reliability are i
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i o7 approximately 4888 MW.
Long Island's total avaliable resources are approximately 4588 MW, or about 300 MW short. The reliability criterion used by LILCO to determine the a, mount of capacity needed is 3 voltage reductions on the LILCO system annually -
itself an adaptation of an annual quota of four reductions (or one day's loss of load per 10 years) statewide set by the New York State Power Pool. The exact reserve levels needed to meet reliability criteria are calculated using complex system loading data and loss-of-load probability methods. While the average installed generation reserve capac-4 1
ity required throughout New York State to meet reliability criteria, assuming infinite i
system interconnections and emergency help from neigh _ boring power pools, would be i
about 22%, the margin of generation and interconnection resources require:1 over esti-1 mated peak load for tong Island is considerably higher. See May 11 affidavit at 20-23 l
and Tables 5 and 6 thereto.
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(10)
Since the filing of my earlier affidavits, LILCO's need for additional ca-pac!!y in 1987 has been reconfirmed by the most recent study by the North American l
Electric Reliability Council, the 1987 Summer Assess:nent. That study indicates, at 10,
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that:
I Generating capacity will be adequate to meet forecast de-
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mands in all areas of New York except on Long Island I
where adequacy will be marginal. Delay in the commercial -
i operation of Long Is'and Lighting Company's Shoreham nu-clear plant, coupled with insufficient transmission capacity to Long Island, are the major reasons for this problem. -
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The only cther area of the country forecast by the NERC study to face capacity short-l
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f ages this summer is the arca to which New York State (and particularly Long Island) l must look for additional interconnection capacity: New England. There, the NERC I
study forecasts, at 10, both generating and transmission limitations, and concludes that:
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.y It is likely that emergency procedures wm tw required.
Depending en the amount of unplanned outages, emergency procedures could include voltage reductions and requests for voluntary customer load curtallraent.
(11)
Af ter 1987, the relationship of LILCO's capacity relative to anticipated demand will continue to deteriorate for the next five years, i.e., through 1992, unless additional generating capacity from Shoreham or elsewhere becomes available. As j
Table 6 of my May 11 affidavit illustrates, if no further capacity is added, the shortfall l
would increase from approximately 300 megawatts in 1987 to approximately 400 f
megawatts in 1988 and approximately 600 megawatts in 1992. This is true notwith-standing LILCO's aggressive conservation and local management efforts, which are projected to grow from an estimated level of 91 MW in 1987 to 480 MW by 1992 and are 1
included in LILCO's load forecast. See May 11 Affidavit, Table 5. Since the prepara-I tion of my laay 11 affidavit, LILCO has taken the one significant additional step open to it (Eee May 11 affidavit at 15-16), and committed to the installation of 200 megawatts of additional combustion turbines, which it had been studying previously.
j Even this addition, to be in service in 1989, will serve o.nly to reduce anticipated shortfalls during this period from the range of 400-600 megawatts to the range of 200-400 megawatts.
(12)
Capacity shortfalls, while not anticipated, could appear even before the next summer peak, i.e., during tne winter of 1987-88. Most of LILCO's steam electric generating units are 30 years of age or older. SE Request at 105 note 90. Given the energy crisis cn Long Island, LILCO has been forced to operate its base load generating stations, including its older stations, for extended periods of time. LILCO has imple-mented a program designed to enhance and accelerate preventive maintenance on these generating stations, particularly in light of their advanced age and extensive usage. Nevertheless, operation of this equipment has been so heavy that normal plant
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overhauls are expected to last longer than usual due to the extensive maintenance re-quired. Current planning includes overhauls of generating facilities representing up to l
approximately 650 MW of LILCO's capacity during January 19P.8. In addition, LILCO projects an average forced outage and daily unaval! ability of approximately 800 MW during the peak winter period of 1987-88. Thus, LILCO's capacity during the winter l
peak eculd be reduced by 1450 MW.
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(13)
LILCO's current forecasts do not predict serious problems in meeting the j
l winter peak because (1) the 1937-88 winter peak is forecast to be about 625 MW lower l
I than the summer peak of 1937, and (2) plants and interconnections both have higher l
rated capacities in winter than in summer due to lower temperatures. However, system l
reliability will be such that the loss of any one of LILCO's remaining large base generating stations beyond the normally anticipated outages, or the outage of the 345 KV interconnection, would place Long Island, in winter months, in a perilous
. shortfall position similar to that of the summer. The forced power alerts of February 9, April 3, June 1 and July 10 of tnis year allillustrate this problem. These situations can be ameliorated t'y operating Shoreham at 25% of full power.
(14)
In sum, as set out in more deta!!in the Request and my May 11 Affidavit:
(a)
Demand for electricity on Long Island, af ter slowing during the 1970s, has grown at an average rate of alrr.ost 3% per year for the last 4 years, and there is no reason to believe that that rate will decrease materially during the next four or five years.
(b)
LILCO has aggressively pursued all available alternative sources of power and conservation / load management, including those recommended by Interve-nors, and accurately accounted for them in annual load growth predictions.
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(c)
LILCO has accurately prod!cted its required generation reserve margins through computer programs that consider such factors as the ratings of gener-ators, planned maintenance, f orced outage rates and deratings.
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i (d)
A serious capacity shortfall of about 300 MW now exists on Long
' Island relative to anticipated 1987 summer peak. Even with aggressive conserva-tion / load management campaigns and the scheduled addition of 200 MW of combustion turbines, this shortfall will become more acute over time and is projected to increase to 400 megawatts by 1992. Winter shortfalls could develop as early as'the winter of j
1987-88. The operation of Shoreham is the only viable alternative to ameliorate the en-4 crgy problera immediately. Operation at 25% of rated capacity, which would provide a net of approximately 170 MW to the system, would materially ease the current shortfall until a full power license is finally issued.
Adam M. Madsen State of New York
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City / County of Nassau
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Subscribed and sworn to before me this day of 1987.
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My Commission expires:
l Notary Public i
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l IIUNTON Oc WILLIAMS 107 EAST MMN starrt P.C. Don 153 5
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8357-Lawrence Coe Lanpher, Esq.
Stephen B. Latham, Esq.
Kirkpatrick & Lockhart Twomey, Latham T. Shes i
South Lobby - 9th Floor 33 West Second Street 1800 M Street, N.W.
P.O.
Box 293 Washington, DC 20036-5891 Riverhead, New York 11901 l
Fabian G. Falomino, Esq.
l Special Counsel to the Governor i
Executive Chamber, Room 229 I
State Capitol-Albany, New York 12224 25% Power Motion:
Discovery
Dear Lar:
y, Fabian and Steve:
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This letter will notify you that in crder to expedite pro-ceedings on its Motion for Authorir,ation to Increase Power to 25%, being filed and cerved on you with this letter, beginning immediately LILCO will voluntarily respond in the manner set i
forth in the Commission's Rules of Practice, 10 CFR Part 2 i
l Subpart G, to discovery requests from Interveners which are con-l sistent with those Rules, notwithstanding that certain initici precedural issues remain to be resolved by the Commission, so i
long as those discovery requests are coordinated among and made i
jointly for Interveners.
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Sincerely yours, i
N Donald P.
Irwin One of Counsel for Long Island Lighting Company c::
Edwin J.
Reis, Esq.
Service List 91/730 1
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Chairmen Atomic Safety and Licensing i;
Bo-ard Panel I
U.S. Nuclear Regulatory Commission East-West Towers.
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Bethesda, MD 20814 I
l Long Island Lighting Company j
!Shoreham Nuclear Power Station, Unit 1) t NRC Docket 50-322-OL
Dear Judge Cotter:
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Enclosed you vill find three copies of documents being filed
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today by Long Island Lighting Con.pany in the Shoreham proceeding, tequesting the Licensing Board to authorize an increase.at Shoreham to 25% of rated power, and requesting the Commission to appoint an additional licensing board to' determine issues arising i
ur. der this request.
Also enclosed are three copies of the ittested documents, with attachments, previously submitted by LILCO in this matter.
1 This submission is intended as a courtesy to the members of-i i
a successor licensing board, should the Commission appoint one as LILCO has requested.
Copies of each of the enclosed documents j
have been served on each of the parties in the proceeding.
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Very truly you s, l
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1 Donald P.
Yrwin i
Onc of counsel for Long Island Lighting Company I
Enclosures:
As Stated 1
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CC:
Attached Service List 91/730
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LILCO,-Jdly 15,1987 i'-
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CERTIFIC ATE OF SERVICE
'87 Jul.15 P12:06 In the Matter of LONG ISLAND LIGHTING COMPANY -
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'(Shoreham Nuc! car Power Station, Unit 1) 00cei 1.w.t,...,
Docket No. 50-322-OL D'k' i
j 1 hereby certify that copies of LILCO's MOTION FOR DESIGNATION OF LICENS-ING BOARD AND SETTING SCHEDULE TO RULE ON LILCO'S 25% POWER REQUEST, l
AFFIDAVIT OF ADAM M. MADSEN IN SUPPORT OF MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%, MOTION FOR AUTHORIZATION TO INCREASE POWER TO l
25%, and letters from Donald P. Irwin to Lawrence Coe Lanpher, et al. and to B. Paul Cotter, all dated July 14, 1987, were served this date upon the following by hand as indi-cated by an asterisk (*), or on July 14,1987 by Federal Express as indicated by two aster-1 isks (**) or by first-class mail, postage prepaid.
j Lando W. Zech, Jr., Chairman
- Alan S. Rosenthal, Chairman **
l U.S. Nuclear Regulatory Commission Atomic Safety and Licensing 1717 H Street, N.W.
Appeal Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Fif th Floor (North Tower)
Commissioner Thomas M. Roberts
- East-West Towers U.S. Nuc! car Regulatory Commission 4350 East-West Highway i
1717 H Street, N.W.
Bethesda, MD 20814 Washington, DC 20555 l
Gary J. Edles, Esq. *
- Commissioner Frederick M. Bernthai
- Atomic. Safety and L! censing U.S. Nuclear Regulatory Commission Appeal Board 1717 H Street, N.W.
U.S. Nuclear Regulatory Commission Washington, DC 20555 Fif th Floor (North Tower) l East-West Towers l
Commissioner Kenneth M. Carr
- 4350 East-West Highway i
U.S. Nuclear Regulatory Commission Bethesda, MD 20814 1717 H Street, N.W.
Washington, DC 20555 Dr. Howard A. Wilber **
Atomic Safety and Licensing William C. Parler, Esq.
- Appeal Board General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Fif th Floor (North Tower) 1717 H Street, N.W.
East-West Towers Washington, DC 20555 4350 East-West Highway Bethesda, MD 20814
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John H. Frye, III, Chairman ** '
Atomic Safety and Licensing I
Atomic Safety and Licensing Board Panal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East-West Towers
. Washington, DC 20555 4350 East-West Hwy.
B. Paul Cotter Esq. **
Bethesda, MD 20814 Chairman Atomic Safety and Licensing Dr. Oscar H. Paris **
Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Commission -
Board East-West Towers U.S. Nuclear Regulatory Commission 4350 East-West Highway East-West Towers Bethesda, MD 20814 4350 East-West Hwy.
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Bethesda, MD 20814 Edwin J. Reis. Esq.
- U.S Nuclear Regulatory Commission i
Mr. Frederick J. Shen
- 7735 Old Georgetown Road j
Atom!c Safety and Licensing (to mLilroom)
' Board.
Bethesda, MD 20814 U.S. Nuclear Regulatory Commission East-West Towers, Rm. 430 Lawrence Coe Lanpher, Esq.
- 4350 East-West Hwy.
Karla J. Letsche, Esq.
i Bethesda, MD 20814 Kirkpatrick & Lockhart South Lobby - Sth Floor Morton D. Margulies, Chairman
- 1800 M Street, N.W.
Atomic Safety and Licensing Washington, DC 20036-S891 Board U.S. Nuclear Regulatory Commission Fabian G. Palomino, Esq. **
East-West Towers, Rm. 407 Ricnard J. Zahnleuter, Esq.
4350 East-West Hwy.
Special Counsel to the Governor Bethesda, MD 20814 Executive Chamber l
i Room 229 '
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Dr. Jerry R. Kline
- State Capitol j
Atomic Safety and Licensing Albany, New York 12224 Board U.S. Nuclear Regulatory Commission Mary Gundrum, Esq.
East-West Towers, Rm. 427 Assistant Attorney General I
4350 East-West Hwy.
120 Broadway
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Dethr.sda, MD 20814 Third Floor, Room 3-116 New York, New York 10271 Secretary of the Commission i
Atiention Docketing and Service Spence W. Perry, Esq.
- Section William R. Cumming, Esq.
l U.S, Nucl ear Regulatory Commission Federal Emergency Management i
1717 H Street, N.W.
Agency Washington, DC 20555 500 C Street, S.W., Room 840 Washington, DC 20472 Atomic Safety and Licensing Appeal Board Panel Mr. Philip McIntire U.S. Nuclear Regulatory Commission Federal Emergency Management l
Washington, DC 20555 Agency 1
26 Federal Plaza New York, New York 10278
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Mr. Jay Dunkleberger Gerald C. Crotty, Esq.
New York State Energy Office Counsel to the Governor Agency Building 2 Executive Chamber Empire State Plaza State Capitol' Albany, New York 12223 Albany, New York 12224 Steptien B. Latham, Esq. **
Martin Brad!cy Asharc, Esq.
Twomey, Latham & Shea Eugene R. Kelly, Esq.
33 West Second Street Suffolk County Attorney P.O. Box 295 H. Lee Dennison Building Riverhead, New York 11901 Veterans Memorial Highway Hauppauge, New York 11787 Jonathan D. Feinberg, Esq.
New York State Department of Dr. Monroe Schneider Public Service, Staff Counsel North Shore Committee Three Rockefeller Pla::a P.O. Box 231 Albany, New York 12223 Wading River, NY 11792 Ms. Nora Bredes Executive Coordinator Shoreham Opponents' Coalition 195 East Main Street l
Smithtown, New York 11787
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Donald P. Irwin Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 l
l DATED: July 15,1987 l
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