ML20083P736

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Affidavit of W Eddleman Opposing Summary Disposition of Eddleman Contention 15AA
ML20083P736
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 04/16/1984
From: Eddleman W
EDDLEMAN, W.
To:
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ML20083P695 List:
References
NUDOCS 8404200138
Download: ML20083P736 (13)


Text

,

a AFFIDAVTT OF S EDDLEMAN Opposing Summary sposition of Eddleman Contention 15-AA

)

My name is Wells Eddleman.

I am an energy consultant and live at 718-A Iredell St., Durham NC 27705 A short statement of my

,B9 ca %cis sJ bispak" bcut of.3 is 9W f

qualifications is attached as Exhibit Q.

I have repeatedly been Ydr.

recognized as an expert in energy systems and energy conservation as an expert before the NC Utilities Commission.

I have twice nresented capacity 3

f before that Commission.

ykatementofMaterial factor studies by an The statementsgn Navon PaNany ng S

e acco Facts in Dispute on Eddleman Contention 15AA" are true to the best of my knowledge and belief at present.

Most are verified also in the affidavit of Charles Komanoff and his acconnanying letter and calculations, which are verified in his affidavit.

Komanoff and I (and others) agree that there is no way to be sure in advance what the capacity factor of a nuclear plant will be, whether for a year or over an operating lifetime.

It may be 70%,

or 140%, or (as in the case of TMI-2) under 1% on a 25 or 30-year lifetime basis.

However, NRC Staff has a record of overestinating future performance of nuclear niants.

In assigning benefits to something that hasn't haopened yet (e.g. Harris 1 operation), the most reasonable procedure is to make conservative assumptions and calculations.

The Staff's and Applicants ' analysis of Harris CF is not sufficiently conservative, particularly for the reasons stated in " Statement of or Material Pacts in Dispute on Eddleman Contention 15AA" and/noted in Komanoff's affidavit and suonorting materials.

Staff excludes from its statistics the nuclear plants shut down for 2.ong periods or indefinitely.

A sample of the remaining plants is thus biased ag toward higher performance levels, since a shut-down plant has zero C.F.

h during the period it is shut down.

ru <

I am familiar with two NCUC cases in which CP&L was penalized O

by the NC Utilities Comission for misnanagement of the Brunswick l

plant, each involving an outage of more than 70 days attributed to

4 such mismanagement (Dockets E-2 sub hh4 and E-2 sub h61).

In the' latter case, the outage was caused by failure to conduct NRC-required leak rate tests on the Brunswick plant containment for h years.

NRC fined CP&L $600,000 for this failure.

Based on this and other evidence of CP&L's effect on performance at its Brunswick plant, including bad design, mismanagement, and failure to conrly with regulations, I conclude that the greater CP&L's involvedment in designing and building a nuclear plant, the more problems it has.

This is surely true in connaring CP&L's Robinson 2 plant, a turnkey Westinghouse project, to Brunswick.

The Robinson plant's performance is about average for a plant of its size, not statistically different from the size-adjusted average or norm by any reliable measure I've seen.

Brunswick, in contrast, is the worst-performing pair of BWMs in the nation; individually the units are worst and 2d worst in lifetime caoacity factor.

The Brunwsick plant is so far below the BWR norm that the capacity-factor-vs.-size arrangement for BWRS I

has a swayback shape with Brunswick the bottom of the awayback.

j Other studies, e.g. Komanoff8c, have statistically found what I view as empirically true: Brunswick's low capacity factor cannot be explained by the factor of " salt" (i.e. brackianh) water cooling.

Brunswick does have a history of mismanagement that is more extensive than that of any other nuclear plant I am familiar with.

It has had repeated and extensive (even overwhelming) problems while having a high rate of staff turnover and others management-related deficiencies.

In my view, non-statittical factors such as mismanagement, CP&L involvement in design, and poor operating practice by CP&L, explain most of the difference between Brunswick's actual CF and the norm or expected CF for a BWM unit of similar size (821 MWe DEM).

t L

2 i !

4 No one, to my knowledge, has done an extensive comparison of l

j the Harris design with other Westinghouse PWRs in oneration or 1

}

under construction which would be a valid basis for omstimating i

exactly the effects of design similarities or differences on Harris j

(vs. other plants') capacity factor.

CP&L's Koppe affidavit does not address seecific problems of the Harria desien.

l Nor has anyone validated that Harris is built as designed, as j

far as I know.

The NMC construction audit of Harris may have been l:

cottoleted, but I have not seen the renort of this audit or been able i

l to check into it.

NRC doesn't have the personnel or time to verify l

the plant's design as-built.

l Therefore, it is reasonable to look at similar vlants for i

indications of Harris' capacity factor.

Westinghouse model D steam generators are already associated with onerating problems.

Too little operating experience has been had with the "fix" for 3

l these steam generators to be sure how well it works or what the i

j steam generator performance will be over a long time.

CP&L identified Beaver Valley and North Anna 1 and 2 as

)

plants similar to Harris, back in the early days of the Harris project.

l Menver Valley is the " Brunswick of Wasptinghonme PWD5" with a ennacity l

I l

factor of under 38% on a design-electrical-rating basis at 12-31-83

{

The North Anna units have performed better, but the 3 average under 55% C.F., with the longest-operating unit (uBeaver va11 y 1) having

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the lowest capacity factor. This indicates to me that 55% is too high an estimate for Harris C.F.

NRC's record of overestinating C.F. in r

l licensing proceedings (both as I know it and upon information & beller),

i adds strength to this view on my part, Finally, CP&L is even more involved in the Harris nroject than in Brunswick.

The "CP&L effect" on Brunswick is substantial, a drop of something like 8 to 15% in espacity factor.

The drop for Harris could well be greater, given CP6L's greater involvement.

h STATE OF NORTH CAROLINA COUNTY OP OMEANGE

+1 i

Today Wells Eddleman personsfly"apposreed before me and affirmed that the statements in his Aeftdavit Opposina Summary

~

Disposition of Eddleman Contention 1pAA, and 2n'h$ a Response in opposition to Sunnary Disposition on IF AA, s.re true and correct to the best of his present knowledge and belief.

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.' ~nex 16 April, 19814 Wells Eddleman

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/.TFIDAVIT 0" CHA9LE3 K0:MOFF Chanlas Ko-anorr, bairr duly effir-ad, danvoses and ravs

1. I an princiaal of Komanoff Energy Associates, autboa of Power Plant Cost Escalation and of nunerous studies of nuc! car nower nlant capacity factors.

A statenent of my credentials cod experience is attached.

2. I ran certain statistics for Wo31s Eddlerar of 718-A Iredell S.,

t Durham, NC 27705, which sac stated in ny Inttcr te Uells 7dtimse of 715-A Urede]1 f.t Durhan No 27705, dated 3/lyCL.

These statis tica are valid in ny view.

3.

The average canacity fatter of c11 Westinghouse units is a hichly inanoropriate way to estimate capacity factor for a Ucst.*rrhouse unit of appactimatelf 900MWe, euch as Shecren Harris.

The statistien1 difference between Westig;huune unite under 600 MWe and thoce 12*rer units (over 600 Ths) la ci6nificant beyond M e 90.9% confidence level.

See iten 8 of 97 3 et ter to Fddlenan, referred to above.

h. Carolina Power and Light Co90any identified Beaver Vallay 1 and

'Nrth Anna 1 and 0 as unite similcr to Parris 1 in its tent?9ery in NC Utilities Conmission docket E-2 sub 203 (seePirc a Certificctc of Dublic Convenience and Necessity to construct Harris), and tht t similarity is reflected ir. the N Connission's Order awarding the certificate.

CF&L discovery documente in ny possession confirr that CD&L odmits it ic the source of this statement as to which units are similst to Harris, b.

In ry cpinion, Harris is nost ninilar to units ordered at the scne time, not to units completed at the sane time.

This would nape 3eaver Va.Iley 1, North Anna 1 and P, end nerhans V.C. Summer, the nont similar ninnts to Haaat,.

Tha avannge parc anneca or Paave- " alley 1, nnd tre o

two North Anna units to date, is under 55d capacity factor.

F.

Performance of all DVRe of a similaw usima to Harris should include Three Mile Island 1 and 2, which hnvr very snell lifeti e caracity factors.

In any cane, the univer:e of all similar sized DWFs is not an aunropriate nredictaiva geouping for Harris 1 because of differences in design, nanufacturer, overatorn, and ether differences.

Net is all P,l13 an averopricte predictive group for Harria 1 nerfoanarce, f or the same ennens that all similar sized DW9s is not annropriata.

Finally, the architect / engineer's exneaience on niants of all tynes and sizen is enrticularly inanteropriate for nredicting the nearcrnance of a plant built with the cano architect / engineer.

{c,g,

6. The canacity facters of nuclear plants inir.g
a. 1W af ter 1970

[c,

'C..b.

o(.suc.h as Harris ) have actually been decrensed reintive to !ber-!

)

'- 1978 and earlier.

My statintieni ntudies show this deprencion in significant at the 99.8 to 99.9$ cerff dence levels or above.

Actuci.orformance nhous no basis for assuming inoroved nerformance by units such an Harris cc9tng on line after 1979.

7. There is a statistically significant denrestion of capacity factor associated with the Brunswick plant operated by Cr&L nnd built with nuch greater input and work by CP&L than was Robinson 2 (a turnkey nlort).

The two higher nultiple-9'c found for statistical analysin of thin factor and cthors affedting E of ?.Pi significant at the 955{9 nerforrance show resnectivelv a lens conridence level and a loan theton of 115$ sign!rigant at the 49.54 confidence level.

Prunguick in statistic-ally diffeaen ren c.11 other BU9s (in entacity factor) at the 90.0 c

0

c s

l Konanoff affidavit, URC Dockat 50-!;00, nage two ecnfidence level.

tha echuni panr vnance o* Mobinson unit 2 P.

"ha diffaranca hatuaan o

and the statictical,norn for such a Westinghouse reactor is not It is about pl.us three nercent. Robins ce nost of 1984 for etean generator renlacenenSn 2 will be out of serv.ficant.

statistically signi 9.

The depression of canacity factor associated with Brunswick is distinct from the lowering of capacity factor due to salt (or brackich) water cooling.

See iten 8 of nv letter to Wells Fddlenan.

10.

One difference between Robinson P and Brunswick was CP&L's 6reater involvement with constructing Brunswick.

I understand that CP&L's involvement in constructing Harais la even greater than its involvenent with 3runswick.

Mapujg 11.

The effect __of Westinghouse 7odel' D stean generators on nuclear olant terrornancelhee been to reduce rerfornance.

The evaluation

,ggy of nerforrance followirg vsrious " fixes" of these tynes of stean y,kdM#

generators nust await the aceunulation of sore years of data on 2

(zug actual cerformance of n1 ants on which such "fixos" have been nerferned.

[CL) 12.

destinchouse 3-loon PJRS are associated with a recuction of 11.5 significant in ny analysis beyond the 99.9%

to 11.d5 in capacity fcetcq,is a 3-loop Westinghouse PUP.

confidence level.

Harris 1 NbI*E 13 If Robinson 2 achieved 100% CF for 2 nenths of 199h and scent 140d the rest of the year in its nianned 10 nnnth stean generator verlacenent p[ OMS cutage, its lifetine catacity factor as of the end of 196h, ixx would likely fall by about 3h ver6entage noints, i.e.

to at or below the b'h nresert Uestinghouse 'It norn as I calculate it.

Ih.

There is no ahnwice that CohL nanaia ent is Mo* to blane #or the lower canacity factor of the 3runswick clants.

CP&L discovery docur.snts in my possession show that the NC Ut11' ties Com.nissi6n has twice nenalized Co&L for nisnancgenent in extenied outages at the Brunswick nlant, and that CP&L agrees that ' outages reduce espacity factor.

16 It is not reasonable in the light of the above irfornation to assune that Harris l'will have a lifetine canacity factor above $$

nercsnt in connercial oceration, throughout its exrected enerating lifetime.

Historically, nuclear plants have not oerforned as well as either the curers, manufacturers or USC Staff have credicted.

16.

There is no reason knoun to ne to alcune that CCEL will do ch better job of constructing, or of nanaging or oneratirg Earris, than CP&L did at 3runxzswick.

l L/

Charles Konanoff f

Filing of this affidavit without a notan's seal was aeproved by Judge Kelley, oral order of April 13, 1984.

Komanoff has much difficulty getting to a notary.

W.E.

I I

KOMANOFF ENERGY ASSOCIATES 12 March 1984 Mr. Wells Edelman 718-A Uredell St Durham, NC 27705

Dear Wells:

Pursuant to our telephone conversation yesterday, I ran certain statistics concerning the capacity factors of the Brunswick and Robinson nuclear units of Carolina power & Light, of General Electric design units as a whole, and of Westinghouse design units as a whole.

I've attached print-outs of the results. This letter will summarize the results and the definitions underlying the calculations.

Komanoff Energy Associates calculates capacity factors based on the oricinal " design electrical ratings" published for each unit when it was first listed in the NRC " Gray Book."

Thus, CP&L units have design ratings of 821 MW for Brunswick and 707 MW for Robinson 2.

We exclude all small (less than 400 MW) units. We also exclude operation by each unit in its initial partial year of commercial operation, i.e.,

prior to the first New Years Day on which the unit was in commercial service.

Capacity factors are calculated through 1983.

The results of the calculations are as follows:

l. Brunswick 1 has a lifetime capacity factor of 44.2% for 6 years of operation. This is the 9th lowest lifetime capacity factor among U.S.

nuclear units, and the 2nd lowest among GE-design units.

2. Brunswick 2 has a lifetime capacity factor of 42.34 for 8 years of operation. This is the 6th lowest lifetime capacity factor among U.S.

nuclear units, and the lowest among GE-design units.

3. The two Brunswick units together have a lifetime capacity factor of 43.1x for 14 years of operation.
4. All U.S. GE-design nuclear units have an average lifetime capacity factor of 58.24 for 213 years of operation.
5. All U.S. GE-design nuclear units excluding Brunswick 1 and 2 have en average lifetime capacity factor of 59.2% for 199 years of opeartion.
6. The difference between the average capacity factor for Brunswick and i

the average for non-Brunswick GE-design units is 16.1x.

This l

difference is statistically significant to the 99.84 confidence level, l

indicating that the capacity factor difference between Brunswick and l

other GE units is not the result of random factors.

7. Some of the difference between the performance of Brunswick and that of other GE units appears to be due to the deleterious effects of 451 BROOME ST 11th FLOOR NYC 10013 212-334-9767 l

Komanoff letter to Edelman / 12 March 1984 saltwater cooling at Brunswick. However, multiple regression analysis of all GE performance to date indicates that, controlling for the difference between performance of GE salt-cooled units and GE non salt-cooled units, there is a " Brunswick factor" which implies about an 8 percentage point loss in performance, which is significant to about the 904 confidence level. Moreover, other regression formulations indicate that the Brunswick factor may be larger, implying about an 11.5 percentage point performance loss, which is significant to beyond the 994 confidence level.

8. A separate examination of the performance of U.S. Westinghouse-design nuclear units indicates that the average capacity factor of all such units of less than 600 MW capacity is 70.44 to date, for 97 years of operation, while the average capacity factor of Westinghouse units larger than 600 MW has been 55.24, for 147 years of operation. The difference between the averages for the two groups, 15.34, is significant beyond the 99.9% confidence level.
9. Cp&L's Robinson 2 unit has a lifetime capacity factor of 63.2% for its 12 years of operation.

It has out-performed the Westinghouse norm by an average of 3 percentage points per year. The norm is not an average of Westinghouse capacity factors, but rather a statistical construct based on causal factors, such as year of operation, unit size, unit age, etc., that have affected capacity factors of Westinghouse units to date. The 3 percentage point difference between Robinson 3 and the Westinghouse nora is not statistically significant.

The following definitions may be helpful to you in interpreting the variables used in the GE and Westinghouse performance regression equations:

BRUNSWIC = 1 for Brunswick 1 and 2 BFFIRE = 1 for Browns Ferry 1 and 2 in 1975 and 1976 YR7374 = 1 for operation during 1973-74 l

yR7475 = 1 for operation during 1974-75 YR8083 = 1 for operation during 1980-83 POSTTMI = 1 for operation after 1978 GESMALL = 1 for GE units less than 700 NW l

SALT = 1 for saltwater-cooled unita SALTAGE = the variable SALT (above) times the unit's age TOWER = 1 for units with cooling towers POSTSG = 1 for a unit whose steen generator was replaced in a previous year NEWSG = 1 for a unit undergoing steam generator replacement in that year

Komanoff letter to Edelman / 12 March 1984 OLDER 12 = 1 for any unit older than 12 SOL 12 = 1 for a saltwater-cooled unit older than 12 WQUAKE = 1 for five individual Westinghouse unit-years in which capacity factor was significantly reduced due to shutdowns to resolve earthquake concerns DUPE = 1 for a unit built alongside and soon after an identical unit FOURLOOP = 3 for Westinghouse 4-loop plants, except Connecticut Yankee TRILOOP = 1 for Westinghouse 3-loop planta MATURES = Age minus 5, for units less than 5 years old, and equals O otherwise Please feel free to circulate this letter, if you wish.

Don't hesitate to call if any of the points here require further elucidation.

Sincerely, Charles Kossnoff -

OISPLAY? M,S,N 4.

5.

6.

7.

colle BREAKDOWN OF CAPF

)

~~~

ACROSS -

NUMBER

- NUMBER M, S, N 4.

5.

6.

7.

8.

14.

17.

47.952 58.076 59.793 44.235 42.315 62.208 56.667 431.564 464.609 358.758 265.411 338.518 559.870 736.673 9

8 6

6 8

9 13 M,S,N 18.

19.

22.

25.

26.

32.

34.

56.506 50.727 58.914 54.147 56.969 62.482 72.778 678.069 405.815 471.315 433.174 227.874 749.782 873.339 12 8

8 8

4 12 12 M, S, N 35.

41.

43.

44.

45.

50.

51.

58.743 55.352 60.068 60.093 57.923 60.719 57.476 822.395 774.925 540.613 540.835 637.158 667.905 632.233 14 14 9

9 11 11 11

' M, S, N 67.

TOTAL 70.514 58.153 775.655

12386.490 11 213

PRINTOUT OFF

/cinoyte compute b DISPLAY? ?

STATISTICS UNIVARIATE SEPARATE POOLED PAIRED T or ALL.

STATISTICS: Default statistics - T.

UNIVARIATE:

N, mean, standard deviation, standard error.

SEPARATE and POOLED: Independent sample T tests.

PAIRED: Patred sample T test.

T: Ssparate variance or paired sample test as appropriate.

DISPLAY? t GROUP 1: BRUNSWIC EO 1.00 GROUP 2: BRUNSWIC NE 1.00 t

I SEPARATE VARIANCE l

DIFFERENCE l VARI A'2LE MEAN STD ERR T

DF PROB l

CAPF

-16.071-4.237

-3.79 15

.002

DISPLAY?

^PetSc=prnt Alt-T=tran R=reev V= view D= dial E= echo M=mesg'X= exit (Home)= Help GROUP 1: BRUNSWIC EQ 1.00

' GROUP 2: BRUNSWIC NE 1.00

,.. e SALT AGE B STEPS PERFORMED DISPLAY? both DEPENDENT:

CAPF 8 VARIABLES IN.

LAST IN:

BRUNSWIC BFFIRE OLDER 12 YR7475 GESMALL YR8083 SALT AGE MULTIPLE R =

.57245 R SQUARE =

.32769 F=

12.42918 SIGNIF F =

.00000 IN EQUATION VARIABLE B

BETA F

SIGF o

BRUNSWIC

-8.36123

.12901 2.838

.094 BFFIRE

-41.12581

.30175 26.591

.000 OLDER 12

-35.10565

.33095 28.543

.000 YR7475

-7.65593

.15073 6.060

.015 GESMALL 4.71858

.14296 3.723

.055 YR8083

-7.95331

.24384 9.193

.003 SALT

-5.70418

.15157 3.624

.05G AGE 1.27335

.26110 9.144

.003 (CONSTANT) 56.56359 635.728

.000 DISPLAY?

^PetSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Home>= Help 3

.5831

.3400

.3108 11.621

.000

.0017

.917 OUT:

SALT VINTAGE UTIL 3 STEPS PERFORMED DIGPLOY" both DEPENDENT:

CAPF 9 VARIABLES IN.

LAST GUT:

SALT VINTAGE UTIL MULTIPLE R =

.58311 R SQUARE =

.34002 F=

11.62057 SIGNIF F =

.00000

' IN EQUATION VARIABLE B

BETA F

SIGF BRUNSWIC

-9.21222

.14214 4.582

.034 BFFIRE

-42.46769

.31160 27.958

.000 OLDER 12

-33.88527

.31944 26.822

.000 YR7475

-6.98058

.13743 5.011

.026 o

GESMALL 3.42812

.10386 2.139

.145 YR8083

-9.51894

.29184 11.695

.001 AGE 1.68374

.34525 13.837

.000 TOWER 3.82760

.11647 2.858

.092 SALTAGE

.58244

.11186 2.204

.139 (CONSTANT) 53.30557 404.116

.000 DISPLAY? *

^PetSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Home)= Help EQU? remove saltage l BK MULTR RSQ ADJRSQ F

SIGF RSOCH SIGCH DEP:

CAPF 5

.5748

.3304

.3075 14.451

.000

.0027

.368 OUT:

SALTAGE 1 STEPS PERFORMED DISPLAY? both DEPENDENT:

CAPF 7 VARIABLES IN.

LAST OUT:

SALTAGE MULTIPLE R =

.57481 R SQUARE =

.33041 F=

14.45092

N

. tec.<C IN EQUATION VARIABLE B

BETA F

SIGF BRUNSWIC

-11.48932

.17728 7.896

.00S BFFIRE

-44.28510

.32493 30.826

.000 OLDER 12

-34.01965

.32071 27.054

.000 YR7475

-6.59498

.12984 4.500

.035 YR8083

-10.56480

.32391 15.758

.000 AGE 1.71313

.35127 15.995

.000 TOWER 5.09360

.15500 5.678

.018 (CONSTANT) 53.68926 412.691

.000 DISPLAY?

^PrtSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Horce> =Hel p o

VARIABLE GRP N

MEAN STD DEV STD ERR LABEL CAPF 1

14 43.138 15.300 4.089 2

199 59.209 15.654 1.110

~

ts/

3EPENDENT:

CAPF 11 VARIABLES IN.

LAST IN:

POSTSG SOL 12 WOUAKE NEWSG YR7374 DUPE FOURLOOP MATURES POSTTMI TRILOOP SALTAGE MULTIPLE R =

.72805 R SQUARE =

.53005 F=

23.78852 3IGNIF F =

.00000 IN EQUATION VARIABLE B

BETA F

SIGF O

POSTSG 9.38793

.08511 2.561

.111 SOL 12

-47.28585

.32612 32.753

.000 WQUAKE

-31.52799

.24260 27.830

.000 NEWSG

-27.67760

.25094 25.649

.000 YR7374

-7.75978

.11820 5.832

.017 DUPE 6.76703

.16001 11.854

.001 FOURLOOP

-15.44839

.37951 45.865

.000 MATURE 5 2.19555

.17763 9.799

.002 POSTTMI

-5.36992

.14534 6.884

.009 TRILOOP

-11.79779

.29779 27.443

.000 SALTAGE

.77761

.14648 4.965

.027 (CONSTANT) 77.27311 1630.454

.000 1

DISPLAY?

^PrtSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Hcme)= Help 2

.7245

.5249

.5045 25.739

.000

.00S2

.111 OUT:

POSTSG 1 STEPS PERFORMED DISPLAY? both DEPENDENT:

CAPF 10 VARIABLES IN.

LAST OUT:

POSTSG MULTIPLE R =

.72448 R SQUARE =

.52487 F=

25.73974 SIGNIF F =

.00000 IN EQUATION VARIABLE B

BETA F

SIGF SOL 12

-50.92604

.35124 40.838

.000 WQUAKE

-31.88012

.24531 28.304

.000 NEWSG 29.78960

.27009 31.342

.000 YR7374

-7.79396

.11872 5.845

.016 DUPE 6.91996

.16362 12.343

.001 FOURLOOP

-15.83378

.38897 48.400

.000 MATURES 2.13467

.17270 9.229

.003 POSTTMI

-4.81897

.13043 5.668

.018 TRILOOP

-11.50547

.29042 26.098

.000 o

SALTAGE

.53144

.10011 2.859

.092 (CONSTANTi 76.79487 1639.589

.000 DISPLAY?

^PetSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Home>= Help VARIAILE GRP N

MEAN STD DEV STD ERR-LABEL CAPF 1

97 70.438 16.798 1.706 2

147 55.178 16.965 1.399 SEPARATE VARIANCE-

e...

01FFbHENCE VARIABLE MEAN STD ERR T

DF PROB CAPF 15.259 2.206 6.92 207

.000 POOLED VARIANCE DIFFERENCE VARIABLE MEAN STD ERR T

DF PROB CAPF 15.259 2.211 6.90 242

.000 DISPLAY?

^PetSc= pent Alt-T=tran R=reev V= view D= dial E= echo M=mesg X= exit (Home)= Help GROUP 1: TWOLOOP EQ 1.00 GROUP 2: TWOLOOP NE 1.00

, DISPLAY? /sel rnw eq 707 SELECTION OK PROC? univ VAR? wresidi wresida NOTE - SELECTING ON $MW EQ 707.00 DISPLAY? stat VARIABLE N

MEAN STD DEV LABEL WRESID1 12 3.054 13.209 WRESID1 WRESID2 12 2.565 13.359 WPESID2

! TOTAL N = 12

+

2 L(0D m e.

I Reprints of selected chapters of this book are available from CHARLES KOMANOFF has researched and wnsten about Komanoff Energy Associates: Chapters I (Intmduction) and the U.S. electric power industry since 1971, and the nuclear 2 (Summary), together; Chapter 3 (Sources Of Nuclear power industry since 1974. He has authored two previous Regulatory Requirements); Chapters 5 and 6 together (con-books: Power Plant Performance: Nuclear and Coal Copa-ceming future nuclear regulations); Chapter 7 (Regulatory city Factors and Economics (Council on Economic Prior-And Design Changes At Coal-Fired Plants); Appendix I ities,1976) and The Price offower: Electric Utituies and the (Nuclear Data Base); and Appendix 2 (Coal Data Base).

Environment (CEP,1972/MIT Press,1974).

"Ihese other KEA publications may also be of interest:

Komanoff has written widely on energy policy issues such as nuclear plant costs and seliability, pollution controls and KEA-I " Nuclear Plant Performance Update 2." Review costs for coal-fired plants, and the potential for improving the of U.S. reactor capacity factors through 1977, pri-efficiency of energy use. His articles have appeared in Th, mariiy statistical. I I4 pp., bound.

New York Times, Newsday. The New York Review ofBooks, Bulletin ofthe AtomicScientists Journalofthe AirPollution KEA-7 "Doing Without Nuclear Power," cover article Control Association, and Nuclear Safety (fosthcoming),

from The New York Review of Books,19 May among other publications. He is probably the most widely 1979. Explains why considerations of economic quoted critic m the Umted States of nuclear power's eco-and social costs make improved energy efficiency, n 8HC Pedermance rather than nuclear power or synthetic fuels, the I

Komanoff has testified before numerous state regulatory KEA-13 " Power Propaganda." Critique of the Atomic agencies and has presented invited testimony to four Con.

Industrial Forum's nuclear and coal cost surveys, gressional committees. In 1980 he testified on the U.S.

showing how AIF omitted the costliest nuclear nuclear program befose the Select Committee on Energy of P ants and cheapest coal plants to make nuclear l

the House of Commons, U.K.-the only witness from America unaffiliated with the nuclear industry appear cheaper KEA-16 "U.S. Nuclear Plant Performance," from Bulletin Komanoff was energy projects director of the Council on ofthe AtomicScientists, November 1980. Analysis Economic Priorities during 1975-76, and senior quantitative of scactor capacity factors through mid-1980, in-analyst for time New York City Environmental Protection ciuding lifetime listings by reactor, vendor, and Administration during 1972-74. He was gr=A=M from size class.

Harvard College with honors in Applied Mathematics in 1968.

Earlier studies by Charles'Komanoff, inc' uding Power Plant i

l Performance (1976) and its first Update (1977), are available from the Council on Economic Priorities (84 Fifth Avenue, New York, NY 1001I).

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