ML20041B501

Comments on Draft EIS Purpose & Need Section 2.NRC Economic Analysis Contains Highly Questionable Assumptions Which Must Be Supported by Documentation Analysis

ML20041B501
Person / Time
Site:	Clinton
Issue date:	02/17/1982
From:	Penner P AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
ISSUANCES-OL, NUDOCS 8202240140
Download: ML20041B501 (2)

Text

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Dear Sirs:

J Solely as a concerned private citizen, I have reviewed the Clinton Power Station DEIS-OL Stage, and I am concerned about a number of the assertions made in the " purpose and need" section 2. The economic analysis conducted by the staff concerning the Clinton Station appears to contain a number of highly questionable assumptions which must be further supported by documentation and analysis if they are to be believed. Specifically, with regard to page 2-2:

Ia) What economic-dispatch model was used and what was the complete set of input data and assumptions? These data must be shown to be internally consist-ent as well as accurate and appropriate.

(b) As an example of questionable consistency, the report states that the fuel savings computed "would not be significantly altered if the demand for electricity grows at a lower rate than assumed." This runs counter to economic wisdom and must be analytically demonstrated via a production cost model.

(c) Similarly, since IP is a new reactor operator and may not achieve the optimistic capacity factors assumed in the analysis, sensitivity studies should

, be conducted with respect to this key variable.

In addition, section 2.4 seems greviously deficient in that it fails to address the issue that the single Clinton unit will represent almost 25% of IP's system generating capacity. In Illinois Commerce Commission docket 79-0071, CBE witness Edward Kahn, submitted an analysis which found that the addition of a single large unit the size of Clinton adversely affected system reliability. At the very least, the DEIS should consider and discuss this possibility.

Cool eb IO 8202240140 820217 PDR ADOCK 05000461 D PDR ,

l Docketing & Service Branch Nuclear Regulatory Commission

'Page Two February 17, 1982

~ Thank you for the opportunity to comment on this DEIS.

Sincerely, ,

l ter S. Penner 712 W. Clark .treet Urbana, IL 61801 cc Phil Willman Alan Samuelson Charles Bacon

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