ML20004G129
| ML20004G129 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/22/1981 |
| From: | Maneatis G PACIFIC GAS & ELECTRIC CO. |
| To: | Novak T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8106290236 | |
| Download: ML20004G129 (4) | |
Text
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PACIFIC GAS AND E LE C T RI C C O M PANY
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r-June 22, 1981
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m h S-7 JUti 2 6 GS] m,s Mr. Thomas M. Novak 4
~l uma Assistant Director for Operating V
RetiMPa Division of Licensing Office of Nuclear Reactor Regulation cu U.S. Nuclear Regulatory Commiinton n2
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Washington, D.C.
205S5 Re: Docket No. 50-133 License No. DPR-7
Dear Mr. Novak:
On May 26, 1981, Pacific Gas and Electric Company (PGandE) received your letter dated May 22, 1981 requesting PGandE to submit information within 30 days pursuant to 10 G F.r.. 50.54(f) to determine whether the operating authority in L! cense Nc. DPR-7 for the Humboldt Bay Power Plant Unit No. 3 should be revoked. You also noted in the letter PGandE's pending motion before the Atomic Safety and Licensing Board (ASLB) for withdrawal of its request to resume operation at the plant and indicated that this motion raised significant questions tor the staff.
As you know, a provisional license for Humboldt was issued in 1962 and converted to a full-term operating license on January 21, 1969, with an expiration date of November 9, 2000. On May 21, 1976, the Nuclear Regulatory Commission (NRC) issued an Order for Modification of License (Order) for Humboldt which required satisfactory completion of certain requirements listed in the Order prior to return to power operation of the plant following the 1976 refueling outage.
On May 20, 1977, PGandE filed an application for a license amendment with the NRC requesting deletion of subparagraph E of the Commission's Order and seeking authorization to return the unit to power operation on the basis or satisfactory completion of the requirements of the May 21, 1976, Order. On August 5, 1977, the NRC staff informed PGandE that it could not support the Company's application to resume operation based on the information which was currently available concerning the geologic and seismic issues pertaining to the facility.
PGandE then discussed with the NRC staff a program for furthe'.
investigations and retained Woodward-Clyde Consultants to conduct a series of geologic and seismic studies designed to determine if the concerns expressed yL. 200l Ace rey T eway gI P
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Mr. Thomas M. Novak June 22,1981 by the NRC staff were resolvable. The report of Woodward-Clyde Consultants (filed with the ASLB on October 6, 1980)_ concluded that the seismic and geologic issues raised by the NRC staff appear capable of resolution.
During the period of the geologic and seismic studies, the incident at Three Mile Island Unit No. 2 occurred which resulted in extensive and continuing changes by NRC regarding its standards and retrofit requirements for nuclear power plants. Accordingly, PGandE engaged the Bechtel Power Corporation to conduct an evaluation of the current and potential backfit requirements which would be required to allow for the return of the unit to operation. Those results, which showed a high range of backfit costs, were factored into a PGandE econcnic analysis regarding the future commercial potential of Humboldt. That analysis and the Bechtel study were furnished to the ASLB as Attachments I and II to PGandE's motion to withdraw its application to restart Unit 3 filed on December 31, 1980. This economic analysis indicated that due to the current uncertainty regarding NRC backfit requirements for operating plaats. an economic decision on the benefits of returning the Unit to operation could not realistically be made at that time.
Sinco filing the motion to withdraw, PGandE has embarked on a program to.onduct aldicional studies to evaluate the various alte rnative s for the plant. These studies include updating PGandE's analysis of those actions which must be taken in order to resume power operation of the unit.
To this end, PCandE is monitoring the current NRC development of safety goals for nuclear power plants as well as NRC's program for the systematic evaluation of operating reactors. We note, though, that the public hearings which had been scheduled in Mcy and June to consider the development of these proposed safety goals were cartelled but that the House Energy and Commerce Committee has recently reported out a bill (the NRC 1982-1983 Authorization Bill) which would require NRC to cotelete public hearings on a new safety goal by December 31, 1981.
When the results of these alternatives are known and the NRC's position on required backfits is resolved, PGandE will then be in a position to accurately assess the economic justification for retrofitting the plant to permit resumption of power operation. The alternatives to be evaluated include the various decommissioning options discussed in NUREG-0586 (draft Generic Environmental Impact St'atement on Decommissioning of Nuclear Facilities) including placing the unit in the custodial SAFSTOR mode, DECON mode, and ENTOMB mode.
As noted above, until the NRC completes its study of backfit requirements and issues guidance on these requirements PGandE will be unable to assess the costs associated with the various alternatives being evaluated.
Accordingly, PGandE cannot make a definitive economic assessment of the future potential for the Unit at this time.
Furthermore, since the resolution of backfit requirements is a matter which is not under PGandE's control, we cannot provide a definitive estimate of when such a decision can be made.
Although Humboldt Eay Unit No. 3 does not meet the current NRC requirements for power operation, PGandE continually reviews all new requirements for applicability to the plant in its current cold sl.utdown mode.
This review considers the potential fot significant safety problems associated L
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Mr. Thomas M. Nevah June 22, 1981 with the plant and those actions which are necessary to comply with the intent of NRC requirements. Those requirements not acted upon immediately are placed on a list of work items that must be satisfactorily resolved prier to restart of Unit 3.
PGandE wiJl be !n a position to complete its evaluation of the various alternatives and make an informed decision regarding Fumboldt once the aforementioned information is available.
In the meantime PGandE intends to maintain the plant in its current shutdown condition.
In summary, the December 31, 1980, motion to withdraw the application for a license amendment was filed to enable PGandE to evaluate the various alternatives for the Humboldt Bay Unit No. 3.
Consideration of these various alternatives, however, should not be interpreted to mean that PGandE believes the useful life of Unit No. 3 as an operating reactor is at an end.
Since the unit, in its present cold shutdown condition, presents no ris'k to the health and safety of the public, PGandE believes that there is no
- ompelling reason for the Commission to revoke the operating authority for Humboldt Bay Unit No. 3.
We are convinced that it 's beneficial to maintain the plant in an operational status pending a decision on NRC backfit requirements and an assessment of their effect on the economics of returning the Unit to operation.
Finally, in my capacity as Senior Vice President - Facilities Development, I am authorized to make the foregoing statement of position en behalf of the Company.
Very truly yours, f
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a RFL: sis MALCO W H. FURBUSH Subscribed and sw n to before me this PHILIP A. CRANE, JR.
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RICHARD F. LOCKE
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Attorneys for Pacific Gas and Electric Company NOTARY PUBLIC IN. D70R THE CITY AND COUNTY AN FRANCISCO, STATE OF CALIFORNIA 50 :-:-:-:- -:^^-29:02- ~-19: *Lher!}
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RITA J. GREEN NOTARY PL'BUC-CAUFORNIA ij l
CITY AND COUNTY OF
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SAN FRANCISCO My Commission Expires July 16,1983 y
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Mr. 'Ihamas M. Novak June 22, 1981 cc: Mr. Jones Hanchett Public Information Officer Region V -'IE U.S. Nuclear Regulatory Ccunisalon 1990 N. California Boulevard Walnut Creek, CA 94596 Hunboldt County Library 636 F Street Eureka, CA 95501 Michael R. Sherwood, Esq.
Sierra Club Iegal Defense Fund, Inc.
311 California Street, Suite 311 San Francisco, CA 94104 Linda J. Brown, Esq.
Donohew, Jones, Brown & Clifford 100 Van Ness Avenue,19th Floor San Francisco, CA 94102 Dr. Perry Aminoto Department of Conservation Division of Mines & Ceology 1416 9th Street, Roan 1341 Sacramento, CA 95814 Friends of the Earth ATIN: Andrew Baldwin 124 Spear Street San Francisca, CA 94105 Bruce Norton, Erq.
3216 N. 'Ihird St.reet, Suite 202 Phoenix, AZ 85012
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