ML20235Y830

Affidavit of Am Madsen in Support of Motion for Authorization to Increase Power to 25%.*

ML20235Y830
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/14/1987
From:	Madsen A LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20235Y823	List: ML20235Y822 ML20235Y830
References
OL, NUDOCS 8707270071
Download: ML20235Y830 (7)

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i o N-i4 LILCO, July 14,1987 l

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AFFIDAVIT OF ADAM M. MADSEN IN SUPPORT OF-MOTION FOR AUTHORIZATION TO INCREASE POWER TO 25%

State of New York )

.) To-wit:

City / County of Nassau -)

Adam M. Madsen, being duly sworn, deposes and says:

(1) My name 'is Adam M. Madsen. My business address is Long ' Island Lighting Company,175 E. Old Country Road, HicksOle, 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 on the~ New York Power Pool Planning Committee. Since 1984, I have been LILCO's representative on the Northeast Power Coordinating Council's Joint Coordination Com-mittee.

(3). I hold a Bachelor of Electrical Engineering degree from Manhattan Col- I lege and a Master of Science degree in Nuclear Engineering Science from Long Island University, and I am a registered Professional Engineer in the State of New York.

i (4) As Vice President for Corporate Planning, I have the overall responsibill- -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 pro,)ected loads. In exercising this responsibility, I and persons under my direction and I 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 intimately involved in the Company's efforts to deal with the electric ener-gy crisis that has developed on Long Island.

(5) I previously submitted an affidavit, 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 Request. That description focused on Long Island's immediate need for additional capacity for the 1987 sum er 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-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 opposition to Shoreham (May 11 affidavit at 4-9); summarizes the widespread expert j consensus that a bulk power supply crisis exists now on Long Island, and the extent to which Mr. Davis fails to recognize it (l_d. 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 I of energy supply and reliability on Long Island through 1992 (i_d. at 16-20 and Table 6).  !

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(7) The purpose of this Affidavit is to summarize, 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 ,

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failures in the summer of 1988, (c) the significant likelihood of a shortfall on Long Is-land between now and the summer of 1988, and (d) the overall electric power supply situation on Long Island through 1992.

(8) There is already an electric supply shortage on Lor; Island. In 1986 LILCO'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 summer 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 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 year. Two occurred even prior to the summer period, on February 9 and April 3. A third power alert was declared on June 1; only lower than forecast af ternoon temperatures pre- l vented system disruptions. In each case, only extraordinary emergency spot purchases of power prevented blackouts or brownouts. S_ee LILCO's Request at 104-09; May 11 af-i fidavit,1125-29. And most recently, on July 10, power usage hit a near-record of 3421 l

M W. A power alert was declared late in the af ternoon that day when two of LILCO's i

power plants suffered unexpected outages. LILCO immediately made public appeals for reduced power usage. Fortunately, during the normal peak period demand began to flatten out and system disruptions were averted. Even so, electric usage was only 21 MW short of LILCO's all time record.

(9) Capacity shortages will continue to exist as of the summer of 1987. The total generation and emergency import resources necessary to enable Long Island to meet its 1987 expected peak load of 3695 MW with suitable reliability are 1

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approximately 4888 MW. Long Island's total available resources are approximately 4588 MW, or about 300 MW short. The reliability criterion used by LILCO to determine the amount 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-ity required throughout New York State to meet reliability criteria, assuming infinite system interconnections and emergency help from neighboring power pools, would be about 22%, the margin of generation and interconnection resources required over esti-mated peak load for Long bland is considerably higher. See May 11 affidavit at 20-23 and Tables 5 and 6 thereto.

(10) Since the filing of my earlier affidavits, LILCO's need for additional ca-I pacity in 1987 has been reconfirmed by the most recent study by the North American Electric Reliability Council, the 1987 Summer Assessment. That study indicates, at 10, that:

Generating capacity will be adequate to meet forecast de-mands in all areas of New York except on Long Island where adequacy will be marginal. Delay in the commercial operation of Long Island Lighting Company's Shoreham nu-clear plant, coupled with insufficient transmission capacity to Long Island, are the major reasons for this pro ~olem.

The only other area of the country forecast by the NERC study to face capacity short-ages this summer is the area to which New York State (and particularly Long Island) must look for additional interconnection capacity: New England. There, the NERC study forecasts, at 10, both generating and transmission limitations, and concludes that:

, It is likely that emergency procedures will be required.

Depending on the amount of unplanned outages, emergency procedures could include voltage reductions and requests for voluntary customer load curtailment.

(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 Table 6 of my May 11 affidavit illustrates, if no further capacity is added, the shortfall would increase from approximately 300 megawatts in 1987 to approximately 400 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 included in LILCO's load forecast. See May 11 Affidavit, Table 5. Since the prepara-tion of my May 11 affidavit, LILCO has taken the one significant additional step open to it (se,_e May 11 affidavit at 15-16), and committed to the installation of 200 megawatts of additional combustion turbines, which it had been studying previously.

Even this addition, to N in service in 1989, will serve only 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 the winter of 1987-88. Most of LILCO's steam electric generating units are 30 years of age or older. See Request at 105 note 90. Given the energy crisis on 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 approximately 650 MW of LILCO's capacity during January 1988. In addition, LILCO projects an average forced outage and daily unavailability of approximately 800 MW during the peak winter period of 1987-88. Thus, LILCO's capacity during the winter peak could be reduced by 1450 MW.

(13) LILCO's current forecasts do not predict serious problems in meeting the winter peak because (1) the 1987-88 winter peak is forecast to be about 625 MW lower than the summer peak of 1987, and (2) plants and interconnections both have higher rated capacities in winter than in summer due to lower temperatures. However, system 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 this year allillustrate this problem. These situations can be ameliorated by operating Shoreham at 25% of full power.

(14) In sum, as set out in more detail in the Request and my May 11 Affidavit:

(a) Demand for electricity on Long Island, af ter slowing during the  ;

i 1970s, has grown at an average rate of almost 3% per year for the last 4 years, and

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there is no reason to believe.that that rate will decrease materially during the next four or five years.  ;

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'b) LILCO has aggressively pursued all available alternative sources J of power and conservation / load management, including those recommended by Interve-i nors, and accurately accounted for them in annual load growth predictions. J

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(c) LILCO has accurately predicted its required generation reserve margins through computer programs that consider such factors as the ratings of gener-ators, planned maintenance, forced outage rates and deratings.

(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 shortf all 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 1987-88. The operation of Shoreham is the only viable alternative to ameliorate the en-ergy problem 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.

M . C pg Adam M. Madsen State of New York )-

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City / County of Nassau )

Subscribed and sworn to before me this let day of

~JG '-Y ,1987.

My Commission expires: /J/fs/ff h *- w Notary Public THOMAS S. DAM 100 NOTARY PUBUC, State of New York No. 524612214 Qual. In Suffolk County Comnusson Er.iires bre. 4, /9(f