ML19253A573
| ML19253A573 | |
| Person / Time | |
|---|---|
| Site: | New England Power |
| Issue date: | 05/31/1979 |
| From: | Hellman R RHODE ISLAND, UNIV. OF, KINGSTON, RI |
| To: | |
| Shared Package | |
| ML19253A572 | List: |
| References | |
| RTR-NUREG-0529, RTR-NUREG-529 NUDOCS 7909100344 | |
| Download: ML19253A573 (20) | |
Text
e F
Richard Hellman Professor of Econmics University of Phode Island TiVIEd CF ECCtG1IC ASALYSIS CF ALTEFSATL'ES FCR CiARLESIGN NCCIZAR PCER PLWT AS SEf FCR"H EI CPE ENIRCt:CCAL STAGEC CF NUCIZAR Flrv'IATCRY COMISSICII MAY 1979 (WFEG 0529)
For Ca w.cr's Enercy Office, Phode !.sland Stimitted Jt:ne 26, 1979 Edited Augt:st 8,1979 4
3Yfb 7909100 3,,
(
I.
l '/ {
MY ASSIGNMENT I have been asked to review the sections of the, DES cn the ccm-arative economics of the proposed Charlestown nuclear plant e
with generation by coal and other alternatives My sections are:
9.1, 10.2, 10.4, 10.5 and Appendix D.
My review is structured as follows:
- 1. A brief background statement of the scope of the project and the apprcpriate response for an economic. analysis of costs.
- 11. An itemi:ation of the essential factors that must be specified in an NRC econcmic analysis, and a parallel evaluation of how far each of these items has been covered, or not covered by NRC staff.
This is done on a scale of 10 for the optimum response and showin~ for each item what part of 10 has been cevered by NRC, w
in my estimation.
These cuantifications are necessarily approxi-mate, but relatively valid.
III. An item by item review of the sections assigned to me on the alte=atives to nuclear pcwer other than cral.
IV. Nuclear and coal generation a
V.
Conclusion e
I.
BACKGRCUND The DES is for a 2 unit nuclear power plant of 2300 Mw costing S2.8 billion.
Since this assumes a 5% escalation to 1988, and inflation rates have beer higher, we may take a rounded cost of S3 billion.
Also, since provision is made on the site for another 2 units, the cost in 1988 dollars could go to $6 billion.
The investment, at either the 3 or 6 billicn levels, more than justifies a thorough, ccmprehensive and adequc 3 sts J r of the comparative (ccmpetitive) ecencmics of the prcposed t' ants versus coal and other alternt ;ies.
Under certain circumstances, the economic study can be crucial to the question of whether to build a nuclear power plant.
If the ecencmics for nuclear were no better at best, cr worse, chan coal, say, then the cost-benefit questten arises of why build tle nuclear plant and subject RI and neighboring states to the costs and risks of possible meltdowns, icw level radiation during rcutine operation, and the presently unsolved waste storage for thcusands of years.
This economic posstbility happens to be well within the range of the best economic studies I have seen, even including that of the NRC in its OES.
Contrariwise, if nuclear were clearly and substantially cheaper than coal er other alternatives, there would then be the massive, often subjective, task of measuring against this benefit the ccsts ncted in the abcve. carac.raoh.
This possibility appears to be much more remote than the opcosite pcssibility.
I will now address myself to the questica cf the adequacy of the NRC Staff's " independent" econcmic analysis.
(
/
1.
i,)
e a
II.
RECUISITES OF AN ADEQUATE ECCNCMIC ANALYSIS Factors which are essential to a comprehen5ive statistical and qualitative analv. sis ara listed in Table 1.
The explanator"2 adec.uacv.
of the NRC staff's analysis as contained in the DES is rated for each factor on a scale of 10.
The number 10 represents optimal adequacy.
The rating can only be approximate, but is an indicator of the area of adequacy.
A 2, for example, says that the staff's treatment of the factor is not far from "0",
but has some small amount of explana-tary and analytical value.
My matrix shows 10 factors for nuclear and coal.
Half have been given virtually no qualitative analysis in depth.
Except for 0 5 M, the othersare close to zero.
Jhe average for nuclea-is 1.3, for coal 0.7.
Just what these icw ratings mean is now explained, item by its.
- 1. Capacity factor definition etc.
How this is defined can make a3 to 5 percentage point difference.
For Millstone 2 nuclear power plant at Waterford, Connecticut, eg, the monthly " Gray Book" re-port shows the following capacities:
Nameplate rating 910 MW Design electrical rating, ne:
830 Maximum Dependable Capacity, 842 (gross)
Maximum Dependable Capacity, 310 io, (net)
Unit capacity facecrs are shcwn for MCC ne: and DER net, but not fcr nameplate.
In this case, the MDC capacity factor is lit less t h a.-
that based on nameplate rating.
The curious fact is tnat the Federal Power Ccamission frcm the beginning has expressed capacity factors only in terms of net genera-tien and nameplate rating.
The problem for individual plants and
o:5er capacity factor definitions has arisen pretty much only sinca the nuclear power plants have come in.
The only cbjective capacity is the nameplate rating fixed to the generator by the manufacturer, It is true that companies may unintentionally misreport namepla'te ratings, but on the whole errors will be symmetric for other definitions, so that nameplate remains the best sin 9 e basis for cacacity factor.
l The NRC staff estimates do not specify which basis is used for capacity factor, but I believe that MCC net is used, because this is the definition.which NRC a pears to favor in, eg, the Gray Book e
when calculating actual versus potential energy production monthly.
I wculd recommend that nameplate ratings be used by NRC.
e e
a
TABLE 1: EXPLANATORY ADECUACY OF NEC STAFF ANALYSIS ITEM 10 = optimal adecuate NL' CLEAR CCAL 1.
Capacity factor: a conceptual, defi-1 1
nitional, functional and methodological examination 2.
Senescence: of plant & capacity factors 2
0 3.
Economic life of plant 2
?
4.
Lifetime capacity factor ( 1-2 + 3 )
2 1
5.
YoYo effect, with histograms. More im po rtant, perhaps, than capacity factor 0
0
- 6. Operation and maintenance costs:
historical vs design 5
5 7.
Scale (size) effects: for primary and secondary nuclear circuits 0
0 8.
Technological constraints - cos: & safety 0
0 welding art for containment vessels and piping and tubing, valving, pumps, metering etc 9.
Human factor constraints, costs, safety:
0 0
a.
management & labor at power plants b.
Similarly at equipment manufacturer
- c. Similarly on construction site
- 10. Low sulfur Eastern ccal, as alternate for Western coal in New England N.A.
0
=
n Simple arithmetic average 1.3 0.7 e
4 1 10
.o.
2.
Senescence This is the decline in capacit.y facter with age of the clant.
It has been 3-iven virtually no attention in American literature.
New England Power (NEP) assumes a rise in CF to the 6th year and a leveling off thereafter at 76.2%:
Year 1............ 59.2%
Year 2 60.9%
5 66.8%
4 & 5 71.0%
6-76.21 30 yr. average 74.5-40 74.9
.3
< 4. 3,.
'l.6 7^U
/_
NRC staff assumes a 603 CF with a range Of 50% and 70s but dces not specify any senescence facecr.
ERDA (Energy Research and Development Administratica) in a 1975 publication assumed the fellowing senescence:
Year 1& 2 651 3 to 15 75% high 70% low 16 to 30 minus 21 per year to a minimum of 403 Source: ERDA, " Total Energy, Electric Energy, and Nuclear Pcwer Projections, L'nited S tates " (Feb. 1975)
- c. 6.
In mv. d'scussions with RWE, the larc.es: German electric utility they felt that senescence was a correct principle, but sculd star:
a
..w. o
- - e. & 4..,. :,
-r 2
. w. e
. 3.". v, o_ m'..
u.
w.
...e
.i.3_.__...e cm 4,, c
..w. m,.. seneseencn
.a
,. a c.,,c_4,-
_aac._
. 4
.w 2
a
.v.a m.
OCOnCmics Cf a nuclear power plant, or CcaL plant and that the ab-I sence of any consideration in the DES is a seriouc flaw.
- 3. ECONCMIC LIFE OF PLAST With the high capital intensity in a nuclear plant, and a high but scmewhat lesser intensity for coal plants, the life assumed for the plant is vital in any econcmic analysis.
The standard assumption of government and utilities is 30 years for both plant typer, and this is the assumption of the NRC staff.
The assumption, hcwever, is not pure.
At pages 7-1, 10-12 and 10-15 the staff also uses 40 years.
Scme utilities, including NEP, have begun to use a 40 year life, apparently in order to make nuclear costs seem lower, but this is unsystematic.
NEP's assumed life in the CES is not scecified, and is =.erha s 30 vears.
A mest significant deviation from the 30 year assumptien for nuclear is embodied in the study done for NEP by Arthur D.
Little
~
Company in 1975, which is understcod to be the basis en which the NEP directors decided to build the RI nuclear plants.
This report dces not state the assumed lives of coal and nuclear, but at my recuest NEP found cut from ADL that a 30 year life was assumed for the coal
.clant, but 28.vears for nuclear.
This drop to 28 years for nuclear is importan t not so much fcr that particular number, but as an indicator that ADL felt that nuclear would have technological problems which would shorten its life.
The 28 is simply a c. ror1 for this.crinciple, and not significant as that pcrticular number by itself.
The French use a 20 to 21 year econcmic life for nuclear, the UK 20 years at a derated CF, the Germans 20 years.
RWE, the German
~
utility, uses a technical life of 30 to 32 years, but an economic life, based on internal calculations, of 20 years,bcth for nuclear and for coal.
Dr. Schech, who is manager of the generati.g staticn Mannheim in Germany and head of the national T'Ol as well as at
--a
Saden TUV, has told me that he :hinks the nuclear plant Itfe is under 20 years, and would have to cost more to bring it up to 20 years.
I have tried to give some idea of the importance of the assumed life of a nuclear versus a coal plant in the comparative cost analysis.
The omission of any analysis on this point in the DES is serious.
4.
Lifetime capacity factor This is dependent on points 1, 2, 3, above and nothing more need be added here.
- 5. YcYo effect If one looks at the annual chart of daily CF's for nuclear power plants, which are known as histograms, he will see that these CF's rise and f all like a yoyo with considerable frequency.
This fluctuation factor can be more important than the CF itself.
Thus, two plants with 55% CFs could be entirely different if in ene the availability can be controlled to be had at the peak, but if in the other this u abulty was only poorly predictable.
An example s
is the cold spell in March 1973, when there was an auxiltary peak, but both Millstone nuclear plants were shut down.
Dr. Schoch, who must sell his power wholesale competitively, told me he could not operate with the nuclear histogram patterns.
He must have 90% availability at the peak in winter, with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> overicad capability.
The somewhat stochastt quality of the nuclear histogram is one of the main reasons, he told me, for his.not_ buying 4
/
a nuclear plant.
There is no attention to the yoyo, cr reliability, effect, as distingutshed from CF, in the DES and virtually ncne elsewhere in the literature.
It must be an essential of any val.d econcmic analysis 7.f
.uclea r ecwer.
6.
Cperatien and maintenance costs O& M costs are available for nuclear and fossil fuel plants in the necessary detail.Tainly in the FPC/FERC Form-1 reports of utilities.
Sinca so much of the low capacity factor below the 30%
design for nuclear plants is due to technological problems, they should be reflected in' erratic patterns of 0 & M from year to year as CF fluctuates.
As CF drops, O& M, if fully reflected in utility accounts,should rise.
Conversely, for fossil plants, assuming in general that lower CFs are due to load following (ie. drops in de-mand), 0 & M should drop.
Staff uses a comparison of 2 x 1150 MW nuclear units with 3 x 767 coal units wi - #1ue gas desulfurization (w/FGD).
0& M is civen as follows:
~
Mills cer Kwh Coal with
_C _F NUCLEAR COAL NUCLEAR = 100 e
,V
/.,.
- 1.7 1,
.3.
60 6.2 10.1 1,63 70 c.,,
9.,,
e, To see what comparisons of actual plants 1cck like, I prepared the following table for the Millstone nuclear power plant #1, 662 MW, commercial in 1970, with the Canal fossil fuel plant in Massachusetts, 542 MW, ccmmercial in 196 3, and burning fuel cil.
Mills /kwh Nuclear CF Year Nuclear Canal
= 100 Nucicar Canal 2 9 s o-3.e, 1.43 s3 6_3 s
,o ea
..UU
,o 3
s.V-o/
e.,
so w
')
,_ s e
7.t.7
,..Jg 3,.
c.
l.
S M
( g a-1, en J
1.V/
./4 5
J4 3,.
.n.1,
./,
JU
-m
,n 03
/ L 3
.92
./3 oo c,
sa
(*)
First year of cperation, which is usually icw in O & M.
I've also compared 3 Mifwestern plants burning ccal with the Kewaunea
~
ow
+.
. u..
C., a,.
..C=na-w.-
as
.J
.s.4
- c. -.-.=~
., ;: ; =.,.
,,,,a 6
M J
-v t a
is 535 MW.
Kewaunae 0 & M was 2.17 mills /kwh in 1976, ccmpared with
.66,
.69 and.34 mills for the 3 coal plants.
With Kewaunee at 100, the coals were 21,22 and 26.
CFs for coal were 60%, 521 and 49%, and for Kewaunee 721.
Point Beach nuclear plant, one of the better managed apparently, operated at.92 mills, with the coals then being 72, 75 and 91 percent respe ctivelv. of point Beach.
What this means is that the actual numbers, selected at randem, are opposite to the o & M relationships of nuclear and fossil fuel plants assumed by the NRC staff.
This illustrates my point that scme qualitative analysis of O&M is essential in an econcmic analysis of nuclear versus coal, and that this is entirely missing from the DES.
7.
Scale Scaling up of size of nuclear power plants has engendered twc problems, large jumps in size without first exploring on prototypes the effects of moving well up the line on size; and the aggravation of this risk in nuclear plants as opposed to these using fossil fuel.
I asked Siemens, which has made all nuclear power plants in Germany, why the non-nuclear part of the plant seemed to have more casualties than the primary nuclear circuit -- something I had cbserved in review-ing the individual plant data from the International Atcmic Energy Agency.
The answer is that since pressures and temperatures of steam in nuclear plants are a fraction of those in fcssil fuel plants, the size of the equipment such as boilers anc turbogeneratcrs must be much larger, and has breached the experienced limits of scale.
I give examples I have selected at randen in Table 2.
This f actor must be censidered in a ccmprehensive analysis of future plant econcmics, but has been overlocked in the DES.
U
,)
1 hl
o u.i). /:
1 t e: ;ut... net
- g. t.at u-21 Co, i l and fluclear l'u..= >r PlanL';
COAL r1 0 C I.C A R flana-Wans-flans-Roll Drowns S t:.
Indian j
UllIT _
tee ley field Run_
Ferry _
Trojan Beaver V I,ucie P o i si t _ _3_
~~
Company F1 PI, GaPC
- FIPI, PAPflY f1W 863 952 914 950 1152 1216 923 850 1125 Year Built
'76
'76
'76
'67
'74
'76
'76
'76
'76 Type nwR PWR PUR Pwn Pug s
Turbine:
a.
PSI-2400 3500 3500 950 873 735 750 715
- b. OF 1000 1000 1000 575 533 r.17 513 507 c.
RPft 3600 3600 3600 1800 1800 1000 1800 1800 aoilors:
a.
t1 umber 1
1 1
2 b.
PSI 2500 3625 3785 3650 1005 895 781 750 O
c.
F 1000 1000 1000 1003 575 533 517 513 507 U
Source: FPC/FORC, Statistics of Steam Electric Plants, 1976 and earlier years.
- 3. Te<&.nolecical ccnstrai.ts There are sericus questiens of ccrrcsicn in nuclear o.cwer clants, m-cludin9 leaka es frc:n the c.rirar./ into the seccndarv. circuits. The best state w
of the art of 'aeldinas is in questica for de cen*'i. rent vessels. The retallure."2 and welding and wall thicknesses cf piping and t2ing is also in cues-den. The quality and adequacy of valving, ptrps, metering etc. are also uncertain. The Ge rans and British, particularly, have b e uneasy cn dese points and have cc:r.issicned e.v. tensive studies of de facecrs involved. The CES gives no.untien C#
- -".a s e.".'.dr".
.#.'.Ct'.'.'.'"a-
.' n "y.'-M-4 " 4 C.
o.#. C-4u' *.".d *I'.
C. a-..'t.'"-.'c'" "l'.,".*c,"".
e
~
rentica is essential.
9.
L,..,n.
ec.s..,4.-
r n
. - a A cer-'in high level of quality centrol is essential at all levels of
..,,o, C'^ _
,,,, e,,..
n,, C
,. ~. 4, n w,.a Cpo., 4
.4 - de,~.,.2, un.
~v
.. ~ - - - -
.. - ~
4 a
,,w-ca.nagerent and desi~tn eerscnnel as r.uch as en pure tecn.ciccy.
'"here are sericus i
q.'s*4 c.a-cf
".e.' e". e.' o.#. ". '.. '. e.v.ca.'.' e.~- ' ".
".ese u' e.'.a-
.a....o -.# ~,.'.~..'.v.
^
a...ilable, adequacy fer Se requirerents of the se.sitive nuclear tec".nciccy, ard willingness to 'acrk in de nuclear pcwer industry. Three Mile Island caly brough:
-.o e _c_c -.
.o
.w-.m e.,.i c a+- e..
d n, "u
- c. ' "f.m. c.-a.
e:.ea. -".m'n
".e
.-c.c..a-
.w n
a
.~. a.
e v
i Fer:./ Fire. These c.uesticns c.o to de heart of de real 'arrld feasibilir.e and c^s a cf nuclear gewer. Ecwever, no reccgnitica has been given to it in de CES.
- 10. Lcw sulfur Eastern ccal, as alte nate for Western Coal in New England
-w...e.ES
.i.a-c uc".~3 a.
d m.'".
n
.a...o c ' e i -"a..-
. m'.'. e."m'.#" -
-.r.as- -.. c,..C m.
a-wi h FGD, or icw sulfur Western ccal wi dcut.G.
There is anc ier real pcssibili y CW s,u,.,....
.r s,.. Ccu,.,.
.e
,-n u,.;.,.,.4C..a,.
..s v.e.w4 st...
v.
-.. a v u,..
_4 m.rn
..o
,33 e ~,.14..e 4. C . ' # eVa' 'w3* o *..i s Eca o.'.'*.'.' # ".'j.
j
' n i
\\j
~J
III. SPECIFIC CC SIENTS CN DES I now comment on specific items referring to the page in the DES.
Six general comments can be made by way of the DES frame of reference.
-- It uses a strict time horizon of 1986-90.
Any alternative which will not produce 2300 MW by that time is eliminated as a possible substitute for nuclear power plants.
For several of the alternatives, h owe ver, their additive effect exceeds the output of at least one, possibly the two nuclear units, but this has not been considered by the DES.
Also, there is substantial evidence that there is conventional non-nuclear fossil fuel suc. c. iv (oil, coal hydro) which, with a reascnable degree of conservation, will carry us througn a 50 year time horizon.
Therefore, it is not necessary to pcsit nuclear plants for 1990 if other costs, such as risks and radicactivity are considered primary.
I am not advocating that position here, but making the point that it should have been given some recognition in the time frame of the DES.
-- The DES bases its economic analysis on a 60%,_.101 capacity facter.
Operation and maintenance costs are then keyed to this as the normal expecta. tion in planning the nuclear capacity.
There is a possible error of assc=ption here.
If the company ordering the nuclear -lant assumes a hivher CF, and bases its cower su.c.civ.olanning e
on that assumo. tion, then any serious shortfall rec.uires it to curchase pcwer to replace the deficit.
The cost of purchased power is very high because it generally is frcm older and less efficient fossil fuel plants.
This is the case at hand.
NEP assumes a 741 CF.
The a
__ s sac rt:aa.,. wnen o0_s is acnievec, Or 20 to ca,,
engenders two excenses included in the CES staff analysis: purchased pcwer, and high not costs of repairing the casualties or other defects which cause the
shortfall.
On this ground, the DES analysis is seriously defective.
If correcelons are made for purchased power and maintenance, the excess of 15% for coal generating costs over nuelear costs estimated by the staff at 60% CF (at p.
9-27) more than disappears, and on these two points alone coal becomes cheaper.
-- The DES assumes that coal and nuclear will be paired at the same CFs.
This is an error.
Nuclear power must be treated as close to run-of-stream hydro, therefore used whenever available (with few exceptions).
Coal is load-folicwing and will be shut down in regions such as upstate NY (where the Niagara and St.
Lawrence hydroelectric.crojects, run-cf-stream, suc..olv. half the energy) whenever demand is less than run-of-stream supply.
This will occur 11 pm to 6 am, and weekends and holidays.
Xhen con-sidering new plants, a baseload coal plant can censistently average 75 to 85 cercent, as shown by actual data of large units.
The 50 to 60 percent limitation on nuclear is entirely due to technolo-gical shcrtfalls belcw the 80% design.
If these shortfalls can be corrected, the costs would rise substantially for nuclear power.
The DES has completely ignored the considerations in this para raph.
8
- The DES overicoks the purely fuel savings value of substitutin.
cheap pcwer on a ncn-base load arrangement in certain situations.
Thic is due to the reversed ratio of fuel to total generating cost between 19 6 8 and 19 79.
In '63 this ratio was about 401, today it is about 60%
Therefore, substitution of Canadian pcwer when it is available, if the rates are icw enough,or wind, solar and solid waste alternatives may be ectncnic. There shculd be a good degree cf analysis of this factor.
The DES is flawed in not icoking a: the total interrelated energy picture.
For example, the high use of geothermal, solar, cil shale, etc. in other areas reduces the world and US demand for h4 gh marginally priced oil and other synthetic substitutes, and thus reduces the cost of, say, oil to Nea England. This in turn would reduce the ecencmic value of nuclear poaer in crg3cn with coal or oil.
- The effect of using danestic sources of alternatives to nuclear pcher en military exp2.dtures, the balance of payment prcblems, and i.y flatica due,to CPE pricing, is vital in today's centext to an econcric analysis of such use. Sare sericus attenticn shculd be given to these factors in the CES.
e
(-
/
- 15a -
The NRC staff eliminates as feasible substitutions for the 2 nuclear power plants all alternatives except coal.
In Table 3, I indicate, on a scale of 10 optimum, my evaluation of the adecuacy of the staff analysis, and in some items my agreement with the Staff conclusion.
I add specific ccmments belcw.
~
Power purchased from Canada:
the incremental hydro unit is so large relatively to the small Canadian market, that there is advantage for the Canadian provinces to send this pcwer to US cheaply for several years.
This would affect the a=cune and timing of nuclear power in New England, depending on prices and estimates of future need by Canadians of their hydro.
The DES needs =cre analysis.
Modernization, in view of the reversed fuel to total generatin; cost of pcwer, should be given more attention in the DES.
Natural Gas:
the DES is not aware that in the past 3 years the natural gas deficit has become a surplus, and that in New England eg, the gas companies are advertising for new cus:ccers.
The DES shculd revise its analysis.
Solar: The DES treatment here is not too profound.
For example, I use 1100 kwh a month in my house.
Half is for electric hot water.
If I can get 60 to 30 percene cf this frc= solar, the drop in need for electricity is great.
Even if the solar sub-stitutes for oil or gas, the interrelated demands for fuel will affect the supply and price of oil or coal for electricity genera-tion.
, i
. \\.I L
.v-TA3LE 3t Non-Coal alternatives to Nuclear Power, Evaluation of SRC Staff Positions Mec.uaCV Of
.M./ "Csi.1Cn Cn e
Ac. c. rox.
NPC Anal"1 sis N?C staff re-
_lterna-lve in Pace No.
Value 207 10=Ctti:=n jecticn
-2 Pcwer purchase frcm Canada 3
agree, generally
-2 Pcdernication of cider fossil plants 600 4
.bre anal. needec
-2 Baselcaling pea'd.ng capacity 8
e
>-3 Oil 0
S
'- 4 Natural Gas 0
7 M.al": sis tco spa:
and sure ##
-a
- d. vc.ro
. 00 a
--5 Mac.netchydrcdynar,ics CCC) 9 I agree
-5 E'uel Calls, 1990 4
I acree with rese Vaticns
-7 Cil Shale 2.5 MED 5
- 7PC tco Negative
-7 Ge -herr.31 3
I acree with resecrazians 3 Sc' id h'aste, =.:.cipal 2300 6
NPC cco necati.-
-> It icn, c rnercial by 2,000 AD 3
agree ge.erall,
.a ciar y
coc negat.:.ve
- 3.., e.w.
_ -,so _, _,. --
a
_ la* *..*.- g e
1
-15 Ccceneraticn 7
Total 5:00 2.5 :GD cil t
G 1
l \\I
(
L.
C n n.1.. m m. I u. r G r.,r r.n _ r v~.I
- r.,/.
e c.,.,C. r CS C e.Ir. ~ e._n R a,..D C n,r-am
_u..
.. a As a general ccmment on the health effects of nuclear and coal plants, particularly coal, they are too nebulous, too little is known as yet today, to factor them into cost comparisons.
I am not sure these areas are for =e to cornent on, in any case.
(pp. 9-17 to 9-26).
My main comment will be on Appendix D cn the coal-nuclear comparison.
I will not repeat comments where they have already been made above.
1.
No,of units.
The DES assumes 2 x 1150 MW nuclear units and 3 x 767 units for coal.
There are already 1350 coal units, and a number at 1,000 Using 2 - 1150 for coal as well would pari passa with nuclear, reduce the relative cost of coal, and might come closa Oc eliminating the advantage of nuclear given by NF.C staff (15% at 60% CF).
2.
The only mention of using Eastern coal (p. D-9) is for high sulfur coa'..
There are billlens of tons of Eastarn 1cw sulfur coal -
this availability should have been analyzed.
3.
Capital costs:
the NRC ccmcarison is of a hic.h sulfur Eastern ccal with FGD with nuclear.
The investment cost ratis of ccal to nuclear is 83%.
I would like to cite an excellent study of ccal versus nuclear by E:c<cn's Pesearch and Engineering Divisicn. This private internal study was race available to me.
Unlirited rescurces were put in*w the stM/
by E:c<cn. It shcws an investment ratio for a Ne.e England plant for nuclear 2.nd high sulfur Eastern coal cf 72%.
E g_
I suggest further analysis by DES cf the investment factor, cecause :P Exxcn ratio would come close to wiping out the nuclear advantage of NRC staff.
Furthermore, for Appalachian low sulfur coal without FGD -
a possibility I have criticised the NRC study for neglecting -- its ratio is only 531.
a 4
. ~.. _
4.
0& M:
I have already commented on this above, and need nc: repeat here.
,/.
u s Cr.r,d r cs,.
n,
_v
- could submit numerous significant annotations on the e,so, but have covered the more important ones.
"he ccaclusion of my analysis of the DES is that its arissicrs of ccverage, and its defects of assumptions, T.ethcdologies, numbers, note of other studies such as tne Exxon study, and overall cover _;e are so great as to require a re ection of the study as it new stands.
With investments of 3 to 6 billion dollars, a more adecuate NRC study is warra t ed.
n "e
e i v