In April 2017 Governor Cuomo announced the closure of the Indian Point Energy Center by April 2021. According to the Governor “the aging 2,000 megawatt nuclear power plant, located 25 miles north of New York City, has presented numerous threats to the safety of over 20 million residents and the environmental health of the area”. In April 2020 Indian Point 2 was shutdown. This post updates some of my previous posts on this subject.
This is a follow-up to five previous posts published between January 2017 and March 2018 on Indian Point replacement power. The first and a subsequent update considered New York State projects that had been permitted to see if there was replacement power in the pipeline that could replace its output. I also analyzed whether renewables and energy efficiency were a realistic alternative and concluded that approach was unlikely to succeed. I also looked at a proposal from the New York Battery and Energy Storage Technology Consortiums to use energy storage as a potential replacement for Indian Point. I concluded that would also not likely succeed. Finally, I reviewed the New York Independent System Operator (NYISO) response to the question about the replacement power needed to replace Indian Point’s output.
In July 2019, at a press conference announcing the Climate Leadership and Community Protection Act (“Climate Act”) Cuomo said “The environment and climate change are the most critically important policy priorities we face – they literally will determine the future – or the lack thereof.” Indian Point 2 (1,299 MW nameplate capacity) has an in-service date of August 1973 and Indian Point 3 (1,012 MW nameplate capacity) was placed in service in April 1976. The 2020 NYISO Gold Book notes that the 2020 summer capability of the two units is 2,067 MW. The owner, Entergy Nuclear Operations Inc., had applied for renewal of the operating licenses in April 2007, seeking an additional 20 years of operation beyond the original expiration dates of 2013 and 2015. The Nuclear Regulatory Commission renewed the operating licenses for the Indian Point nuclear power plant, Unit 2 and Unit 3, on Sept. 17, 2018 so the units would have been able to run until 2033 and 2035, respectively. However, under the settlement between Entergy and the state of New York announced a settlement under which Entergy closed Unit 2 by April 30, 2020 and will permanently close Unit 3 by April 30, 2021.
New York Control Area Energy Production
In order to fully grasp the innumeracy of shutting down 2,0067 MW of CO2-emission free generation at the same time the Climate Act legislates that electricity generation in 2040 will not include any fossil-fired power, we need to look at the energy production numbers in New York. In the following table I have extracted the energy production by fuel type numbers from the NYISO Gold Book and combined that with the operating data from Indian Point 2 and 3.
NYISO Gold Book Figure III-3: NYCA Energy Production (GWh) by Fuel Type
| 2016 | 2017 | 2018 | 2019 | |
| Generator Fuel Types | Production | Production | Production | Production |
| Gas | 7,787 | 6,697 | 7,594 | 7,273 |
| Oil | 136 | 74 | 152 | 104 |
| Gas & Oil | 52,450 | 44,135 | 47,526 | 44,068 |
| Coal | 1,493 | 567 | 692 | 425 |
| Nuclear | 41,638 | 42,175 | 43,003 | 44,788 |
| Pumped Storage | 836 | 795 | 811 | 583 |
| Hydro | 26,314 | 29,554 | 29,045 | 30,141 |
| Wind | 3,943 | 4,219 | 3,985 | 4,454 |
| Other | 2,881 | 2,919 | 2,729 | 2,648 |
| Solar | 54 | 47 | 49 | 52 |
| Total | 137,532 | 131,183 | 135,585 | 134,536 |
| Indian Point 2 | 6,050 | 8,352 | 8,001 | 8,352 |
| Indian Point 3 | 9,076 | 6,953 | 8,334 | 8,343 |
While it is clear by the energy production numbers that Indian Point has a significant contribution to the state’s power production the percentages make the point even better. The two units generated approximately 12% of all the power produced over the last four years.
NYISO Gold Book NYCA Energy Production (%) by Fuel Type
| 2016 | 2017 | 2018 | 2019 | |
| Generator Fuel Types | Production | Production | Production | Production |
| Gas | 5.7% | 5.1% | 5.6% | 5.4% |
| Oil | 0.1% | 0.1% | 0.1% | 0.1% |
| Gas & Oil | 38.1% | 33.6% | 35.1% | 32.8% |
| Coal | 1.1% | 0.4% | 0.5% | 0.3% |
| Nuclear | 30.3% | 32.1% | 31.7% | 33.3% |
| Pumped Storage | 0.6% | 0.6% | 0.6% | 0.4% |
| Hydro | 19.1% | 22.5% | 21.4% | 22.4% |
| Wind | 2.9% | 3.2% | 2.9% | 3.3% |
| Other | 2.1% | 2.2% | 2.0% | 2.0% |
| Solar | 0.0% | 0.0% | 0.0% | 0.0% |
| Indian Point 2 | 4.4% | 6.4% | 5.9% | 6.2% |
| Indian Point 3 | 6.6% | 5.3% | 6.1% | 6.2% |
New York Climate Act Energy Production Targets
The Regulatory Impact Statement for the New York Department of Environmental Conservation (DEC) proposed revisions to 6 NYCRR Part 242, “CO2 Budget Trading Program” states the following:
“Finally, the primary objective of the State’s clean energy and energy storage commitments are to combat climate change, reduce air pollution, and ensure a reliable and diverse low carbon energy supply. In January 2019 as part of the State of the State, Governor Cuomo announced the most aggressive clean energy targets in the nation under New York’s Green New Deal – a nation leading clean energy and jobs agenda. This includes a significant increase of the New York’s Clean Energy Standard where the share of the State’s electricity coming from renewable resources will go from 50 percent to 70 percent by 2030. This will be supported by several critical components:
Quadrupling New York’s offshore wind target to 9,000 megawatts by 2035, up from 2,400 megawatts by 2030.
Doubling distributed solar deployment to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023.
Deploying 3,000 megawatts of energy storage.
More than doubling new large-scale land-based wind and solar resources through the Clean Energy Standard.”
Two of the critical components, offshore wind (9,000 MW) and distributed solar deployment (6,000 MW) total 12,933 more MW than Indian Point 2 and 3. Assuming an offshore wind capacity factor of 42.5% and fixed-tilt PV solar capacity factor of 20%, then the energy produced by these components could total 33,507 GWh for offshore wind and 10,512 GWh for the distributed solar. While that all sounds good, there are issues. For starters, given the alleged urgency for implementing emission reductions for the Climate Act, I would think that timing the closedown until after replacement power was at least permitted would have been appropriate. More importantly, the problem is not as much the power, it is the energy produced that is of concern as shown below.
Future Energy System Implications
Power is the rate work is performed and is described in MW while energy is the amount of work performed measured in MWh. The Climate Act includes a provision to outlaw the use of fossil fuels for electric generation by 2040 and another provision to reduce all fossil fuel emissions to 85% of 1990 levels by 2050 despite not having come up with a plan to change the electric system to meet the energy requirements. I maintain that it is absolutely necessary to use historical wind and solar insolation data to determine the resources available to meet expected load when transportation and heating are electrified. My particular concern is the inevitable winter peak periods.
In one analysis I found that there were two no wind energy output periods on 3-4 January 2018 during an intense cold snap when electric load is high as shown in the New York Off-Shore Wind Generation Estimate for 9000 MW CLCPA Off-Shore Target table. I was surprised to see that the wind resource went to zero during a high load period not only when the winds were light on January 3 but also when a deep low pressure developed and the wind speeds exceeded 25 m/s on the very next day. The wind generation estimate table lists the output from a single 10.2 MW wind turbine, 80 turbines in the Equinor proposed offshore wind facility and for all 9,000 MW of Cuomo’s CLCPA target for off-shore wind. It is important to note that adding even more wind turbines still does not preclude the need for substantial energy storage. While all the New York off-shore wind resource may not go to zero simultaneously that resource is going to be highly correlated across the available area so they all will track closely. Keep in mind that this example winter peak period occurs at the time that solar energy is very much reduced due to length of the day, angle of the sun and potential snow covering panels.
I followed up on that analysis with an attempt to estimate how much energy storage would be required for this example winter peak. One of the unmentioned difficulties with Li-Ion battery storage is that they can only be operated over a limited range to get them to last ten years, i.e., they must use active thermal management and cycle the battery within a restricted 54% operating range. As shown in the Combined Energy Storage Capacity and Cost With Storage 54% Limitation table, in order to meet the 2040 no fossil-fuel requirement I estimate that the price of energy storage alone will be $96.0 billion, and, because they still only have a lifetime of ten years they will have to be replaced in 2050 at an estimated additional cost of $80.4 billion. The expected cost of the batteries needed for just energy storage is the sum or $176.3 billion.
One of the critical components mentioned above is to deploy 3,000 megawatts of energy storage. It is very frustrating that many of the forecasts for energy storage just list the power capacity. It makes a huge difference when trying to figure out how well the energy storage will be able to handle the peak load forecasts in an all-renewable energy system. In the absence of that information, I assumed that the 3,000 MW will have four hours of storage or 12,000 MWh. In the example given above I estimated that much more energy storage capacity and energy would be needed – 40,926 MW with energy potential of 278,519 MWh in 2040 and 30,556 MW of battery storage with 236,667 MWh of energy potential in 2050. The critical point is that the overview estimates to date apparently only look at annual numbers. In order to keep the electric power on when society needs it most, winter peak load analyses have to be done.
That is not all, unfortunately. In an earlier post on Indian Point I pointed out I originally thought the only energy storage issue was building enough batteries to store the renewable energy for when it is needed.
Not surprisingly, it turns out that it is more complicated than that. PG&E recently reported on the results of a battery storage demonstration project that described how their batteries were used on the grid. The project participated in the day ahead energy market which is used to procure the majority of supply to meet that day’s predicted electric load. The California ISO also has a real-time energy market and the battery system provided services for short-term fluctuations from the day ahead forecast. In addition to the energy market, batteries can be used for the ancillary services of frequency regulation and spinning reserves. Finally, the report notes that it takes more energy to charge the batteries than battery discharges. Also note that the energy storage association has a longer list of battery technology applications. Until such time that New York proves that renewable energy and energy storage can keep the power on when it is needed most I think we are headed blindly to a bad ending.
Capacity Change Reality
Previously (here and here), I considered New York State projects that had been permitted to see if there was replacement power in the pipeline that could replace its output. The NYISO Gold Book also documents changes in the changes of capacity of New York generating sources since the announcement of the closure plan. I extracted data from the Gold Books since 2017 when Cuomo announced the closure of Indian Point to see how the market has reacted to the loss of Indian Point’s carbon-free generation. I list the 2017 and 2020 summer capacity for each generator fuel type taken directly from the Gold Book. There are four types of changes listed in these data: deactivations when a unit is retired, additions and uprates when a new unit is added or existing unit is modified to increase capacity, reclassifications when a unit’s fuel type is changed, and ratings changes which occur based on performance testing. The biggest change over the last three years has been the addition of new combustion turbines totaling 1,868 MW.
NYISO Gold Book Table II-1a: 2017 to 2020 Summary of Changes in Summer Capacity (MW)
| Generator | 2017 | Additions | Reclassi- | Ratings | 2020 | |
| Fuel Types | Capacity | Deactivations | & Uprates | fications | Changes | Capacity |
| Gas | 3,588 | -4 | 1,124 | 23 | -5 | 4,725 |
| Oil | 2,499 | -33 | 0 | 0 | -50 | 2,416 |
| Gas & Oil | 18,529 | -274 | 744 | 0 | 231 | 19,230 |
| Coal | 1,011 | -291 | 0 | -23 | -21 | 676 |
| Nuclear | 5,375 | 0 | 0 | 0 | 16 | 5,391 |
| Pumped Storage | 1,407 | 0 | 0 | 0 | 0 | 1,407 |
| Hydro | 4,251 | 0 | 0 | 0 | -4 | 4,247 |
| Wind | 1,740 | 0 | 0 | 0 | -1 | 1,739 |
| Other | 378 | -25 | 0 | 0 | 5 | 359 |
| Total | 38,778 | -627 | 1,868 | 0 | 171 | 40,191 |
Note that there has been no renewable capacity added over this period. I believe that is a result of detailed permitting requirements that include environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws. In April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget. This legislation is intended to ensure that renewable generation is sited in a “timely and cost-effective manner”. In any event, in the past 12 months wind projects totaling nearly 1,300 MW have been permitted and will show up on this table once construction is complete.
Importantly, those who say that the closure of Indian Point won’t increase fossil-fired emissions are mistaken. Because the fuel costs of existing renewable projects are essentially zero all the output of existing projects is already spoken for and no increased output to respond to Indian Point closure is possible. Replacement renewable replacement power has to be new sources. Nuclear and hydro are normally lower cost sources than fossil fuel sources. As a result, the only source left source left to replace Indian Point’s lost energy are fossil plants.
The NYISO recent full 2020 summer assessment notes that despite a 506 MW decrease of the capacity margin surplus for baseline peak weather conditions, there is margin above the baseline plus needed operating reserves. However, if extreme weather conditions occur there is no capacity margin surplus and the system may have to rely on emergency operating procedures to provide relief. The presentation notes that 2,273 MW have been deactivated this year but that 1,177 MW of natural gas fired power has been added. It appears that the closure of Indian Point 2 should not affect reliability this summer unless there are extraordinary conditions.
Conclusion
Governor Cuomo said “The environment and climate change are the most critically important policy priorities we face – they literally will determine the future – or the lack thereof.” Nonetheless the hypocritical implementation of his policies suggests that there are other factors driving these initiatives. The closure of Indian Point was not coordinated with implementation of renewable energy to replace it. I am positive that this will result in increased CO2 emissions for some part of the more than a decade useful life of these units that has been short-circuited. In this instance, the alleged environmental impacts of Indian Point were more of a concern than climate change. On the other hand, there is no requirement for a cumulative environmental impact of all the renewable energy resources needed by the Climate Act. (By the way, that is a moot point until the State actually comes up with the plan to convert the electric system completely away from fossil fuels.) Compounding the risk that the environmental impacts of the Climate Act could be worse than the averted climate change impacts is the AREGCBA law that now circumvents the requirements for detailed site-specific requirements for environmental and public health studies now in place. So, on one hand, environmental risks trump climate change risks but on the other hand climate change risks overrule the obvious need to consider environmental impacts of massive wind, solar, and transmission deployment.
Finally, the State will undoubtedly claim that it will be cheaper to use offshore wind, distributed solar deployment, and doubling new large-scale land-based wind and solar resources through the Clean Energy Standard than building new fossil-fired generation to replace electric energy from Indian Point 2 and 3. However, the fact is that the renewable resources come with a hidden price tag because of the necessity of including energy storage for the periods when intermittent wind and solar are unavailable and grid services because diffuse wind and solar require transmission support. Not only are there significant cost financial implications, the fact that no jurisdiction anywhere has successfully implemented an electric system with such a high dependency upon renewables without becoming dependent upon adjoining electric systems for support, should give the State sufficient incentive to re-consider the ambitious schedule for the aspirational targets of the Climate Act until proper feasibility and cumulative environmental impact analyses have been completed.
Pragmatic Environmentalist of New York 