ML090720671

Comment (58) E-mail Regarding Iplr Dseis

ML090720671
Person / Time
Site:	Indian Point
Issue date:	03/11/2009
From:	Public Commenter Public Commenter
To:	Division of License Renewal
NRC/NRR/DLR
References
73FR80440
Download: ML090720671 (3)

Text

IPRenewalCEmails From: Kennis Koldewyn [kennis.koldewyn@gmail.com]

Sent: Wednesday, March 11, 2009 11:25 AM To: IndianPointEIS Resource

Subject:

Comment on Draft EIS for Indian Point I would like to comment on the draft environmental impact statement for a 20-year extension of the operating license for the Indian Point nuclear power plant generators 2 and 3. Among the many serious problems with this document, I would like to concentrate on one in particular: it does not seriously consider conservation as an alternative to license renewal, and even goes so far as to deliberately misstate the results of a 2006 National Research Council report into alternatives.

The Draft EIS claims that the National Research Council report "concludes that energy efficiency and demand-side management have great economic potential and could replace at least 800 MW(e) of the energy produced by IP2 and IP3 and possibly much more" [1], but then goes on to claim that the NRC "predicted that only about 800 MW(e) could be reduced from the IP2 and IP3 service area" [2]. The first claim significantly understates the actual conclusion of the National Research Council's report, and the second claim is simply false. The NRC report actually concludes that "additional cost-effective demand-side investments in energy efficiency, demand response, and combined heat and power facilities can signifcantly offset peak demand...[and] could reduce peak demand by 1 GW or more by 2010 and 1.5 GW by 2015. If the cost of distributed photovoltaics can be brought to near-competitive levels over the next decade (see Table 2-7), demand-side measures could contribute 1.7 GW by 2015, thus approaching the capacity of Indian Point" [3] (emphasis added).

It is hard to interpret the discrepancy between what the Draft EIS claims the National Research Council report concluded and what the NRC report actually concluded as merely an accidental oversight or an innocent mistake. Nowhere does the NRC report make any predictions even remotely similar to demand-side measures only reducing 800 MW(e) from the Indian Point service area. The report is online and electronically searchable, making this easy to verify. Instead, the report explicitly states that demand-side measures alone could reasonably be expected to contribute nearly the entire capacity of Indian Point! How can the staff of the Nuclear Regulatory Commission in good conscience write "the NRC staff does not expect that conservation efforts alone will be sufficient to replace either of the IP2 or IP3 units" [4]? This conduct is extremely irresponsible at best, and casts serious doubt as to the veracity and accuracy of the Draft EIS as a whole.

Thanks for your consideration of this comment.

Kennis Koldewyn 13 Ogden Avenue White Plains, NY 10605 914-421-0018 kennis.koldewyn@gmail.com Notes:

1. U.S. Nuclear Regulatory Commission (2008). Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Indian Point Nuclear Generating Unit Nos. 2 and 3 (NUREG-1437, Supplement 38, Vol. 1). Page 8-59, lines 18 through 20. Retrieved March 11, 2009 from http://adamswebsearch2.nrc.gov/idmws/ViewDocByAccession.asp?AccessionNumber=ML083540594

2. Ibid., page 8-59, lines 23 and 24.

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3. National Research Council (2006). Alternatives to the Indian Point Energy Center for Meeting New York Electric Power Needs. Washington, D.C.: National Academies Press. Page 30. Retrieved March 11, 2009 from http://books.nap.edu/openbook.php?record_id=11666&page=30

4. U.S. Nuclear Regulatory Commission (2008). Page 8-59, lines 24 and 25.

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Federal Register Notice: 73FR80440 Comment Number: 58 Mail Envelope Properties (405c403e0903110825h183dbb52wb600b413867d2f1d)

Subject:

Comment on Draft EIS for Indian Point Sent Date: 3/11/2009 11:25:16 AM Received Date: 3/11/2009 11:25:17 AM From: Kennis Koldewyn Created By: kennis.koldewyn@gmail.com Recipients:

"IndianPointEIS Resource" <IndianPoint.EIS@nrc.gov>

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