ML20010C594
| ML20010C594 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 08/13/1981 |
| From: | Locke R, Maneatis G PACIFIC GAS & ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8108200223 | |
| Download: ML20010C594 (8) | |
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' CLEAR REGULATORY COMMISSION 4 2
ATOMIC SAFETY AND LICENSING BOARD 3
Before Administrative Judges 4
Robert M.
Lazo, Chairman 5
Gustave A. Linenberger David R.
Schink 6
7
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8 in the Matter of
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Docket Nr. 50-133
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9 PACIFIC GAS AND ELECTRIC COMPANY
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Response of Pacific
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Gas and Electric 10 (Humboldt Bay Power Plant
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Company to Board Order Unit No. 3 - Amendment to Facility) of July 14, 1981 11 Operating License)
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12 13 On July 14, 1981, the Atomic Safety and Licensing 14 Board ordered Pacific Gas and Electric Company ("PGandE") to 15 submit within thirty days a written statement under oath or 16 affirmation setting forth its intentions regarding plant 17 modifications required to bring Humboldt Bay Power Plant, Unit 18 3, into compliance with current NRC requirements.
The Order 19 further required that if PGandE desired to retain its
' 20 operating authority as provided in Facility Operat'ng License 21 No. DPR-7 said statement should include a proposed schedule 22
- or completing required plant modifications.
23 As was stated in the July 14, 1981, Order, a 24 Provicional license for Humboldt was issued in 1962 and
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25 converted to a full-term operating license on January 21, 26
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8108200223 810813' PDR ADOCK 050001' 3 J
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PDR 11
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1969, with an expiration date of November 9, 2000.
On May 21, 2
1976, the Nuclear Regulatory Commission !"NRC") issued an 3
Order for Modification of License (" Order") for Humboldt which 4
required satisfactory completion of certain requirements 5
listed in the Order prior to return to power operation 6
following the 1976 refueling outage.
7 On May 20, 1977, PGandE filed an application for a 8
license amendment with the NRC requesting deletion of 9
subparagraph E of the Order.
On August 5, 1977, the NRC staff 10 informed PGandE that it could not support the Company's 11 application to resume operation based on the information which 12 was currently available concerr.ing the geologic and seismic 13 issues pertaining to the facility..
14 PGandE then discussed with the NRC staff a program 15 for further investigations and retained Woodward-Clyde 16 Consultants to conduct a series of geologic and seismic 17 studies designed to determine if the concerns expressed by the 18 NRC staff were resolvable.
The report of Woodward-Clyde 19 Consultants (filed with the ASLB on October 6, 1980) concluded 20 that the seismic and geologic issues raised by the NRC staff 21 appear capable of resolution.
Based upon the work conducted 22 in 1979 and 1980, WCC advises that they have an increased 23 degree of confidence in a favorable resolution of the geologic 24 and seismic issuet 25
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During the period of the geologic and seismic 2
rtudies, the incident at Three Mile Island Unit No. 2 occurred 3
which prompted NRC to make additional extensive and continuing 4
changes in its standards and retrofit requirements for nuclear 5
power plants.
Accordingly, PGandE retained the Bechtel Power 6
Corporation to conduct an evaluation of the current and 7
potential backfit requirements which would be required to 8
allow for the return of the unit to operation.
Those results, 9
which shcwed a high range of potential backfit costs, were l
10 then considered in PGandE's economic analysis regarding the 11 future commercial potential of Humboldt.
That analysis and 12 the Bechtel study were furnished to the ASLB as Attachments I 13 and II to PGandE's motion to withdraw its application to 14 restart Unit 3 filed on December 31, 1980.
This economic 15 analysis indicated that due to the current uncertainty 16 regarding NRC backfit requirements for operating plants, an 17 economic decision on the benetits of returning the unit to 18 ope'ation could not realistically be made at that time.
19 Since filing the motion to withdraw, PGandE has 20 embarked on a program of additional studies to evaluate the 21 various alternatives for the plant.
Thuse studies include 22 updating PGandE's analysis of those actions which mus'; be 23 caken in order to resuue pcwer operation of the unit and the 24 various decommissioning options discussed in NUREG-0586 (draft 25 Generic Environmental Impact Statement on Decommissioning of 26
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1 Nuclear Facilities) including placing the unit in the 2
custodial SAFSTOR mode, DECON mode, and ENTOMB mode.
These 3
studies should be completed E.,
December 15, 1981.
4 5
To evaluate the alternative of resumption of power 6
operation,.PGandE is monitoring the current NRC development of 7
safety goals for nuclear power plants as well as NRC's program 8
for the systematic evaluation of operating reactors.
We 9
understand legislation currently being considered by Congress 10 (the NRC 1982-1983 Authorization Bill) would require NRC to 11 establish a new safety goal by December 31, 1981.
12 If the NRC meets the December 31, 1981, deadline, 13 determines backfit requirements for older p.'. ants such as 14 Humboldt, and issues guidance on these requirements, PGandE 15 can then reassess the costs associated with the various 16 alternatives being evaluated.
PGandE will then complete a 17 more definitive economic assessment of the future potential 18 for the Unit within six months.
As the foregoing discussion 19 illustrates, it is difficult to directly respond to the 20 Board's reauest that r3andE furnish a definitive schedule for 21 completion of required plant modifications with certain 22 important variables undefined other than as noted above.
23 Although Humboldt Bay Unit No. 3 does not meet the 24 current NRC requirements for power operation, PGandE I
25 continually reviews all new requirements for applicability to i
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the plant in its current cold shutdown mode.
This review 2
considers the potential for significant safety problems 3
associated with the plant and those actions which are 4
necessary to comply with the intent of NRC requirements.
5 Those requirements not acted upon immediately are placed on a 6
list of work items that must be satisfactorily resolved prio-7 to restart of Unit 3.
In the meantime, PGandE plans to 8
maintain the plant in its current shutdown condition.
9 In summary, PGandE's decision to withdraw its 10 application for a license amendment was premised on the 11 unsettle' situation regarding NRC safety goals and backfit 12 requirements and was made to enable PGandE to evaluate the 13 various alternatives for the Humboldt Bay Unit No. 3.
14 Consideration of these various alternatives, however, should 15 not be interpreted to mean that PGandE believes the useful 16 life of Unit No. 3 as an operating reactor is necessarily at 17 an end particularly in view of its location in the relatively 18 isolated Eureka area.
PGandE is extremely reluctant to 19 abandon a proven source of generation in this area because to 20
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do so would increase the area's dependence on lengthy l
2 transmission lines which are vulnerable to the normal, severe 3
winter storms in the area traversed by the lines.
4 Since the unic, in its present cold shutdown 5
condition, presents no risk to the health and safety of the 6
public, PGandE believes that there is no compelling reason for 7
this Board to issue an Order to Show Cause why the operating 8
authority for Humboldt Bay Unit No. 3 should be revoked.
We are convinc'ed that it is beneficial to maintain the plant in 9
10 l an operational status pending a decision on NRC backfit I
11 requirements and an assessment of their effect on the 12 economics of returning the Unit to operation.
Furthermore, we 13 propose to file with the Commission and, if necessary, this 14 Board six-month status reports regarding our plans for 15 Humboldt.
16 I certify that the foregoing statements are true and 17 correct and made in my capacity as Senior Vice President -
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) - ___ _ _________________________ _
1 Jacilities Development.
I further affirm that I am authorized 2
to make the foregoing statement of position on behalf of the 3
Company.
4 5
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GEOtGE A. MANEATIS Senio)r Vice President -
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Facilities Development 9
10 Subscribed and sworn to before me this 13th Day of August 1981.
11 12 13 14 HEODOM COOKE NOTARY PUBLIC IN AND FOR THE CITY AND 15 COUNTY OF SAN FRANCISCO, STATE OF CALIFORNIA 16 My Commission expires January 28, 1985.
17 18 Respectfully submitted, MALCOLM H. FURBUSH 20 PHILIP A. CRANE, JR.
RICHARD F.
LOCKE 21 22 23 by
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~Attern fs % r 24 Pacific Gas and Electric Company 25 26
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UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION 7
In the Matter of=
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PACIFIC GAS AND ELECTRIC COMPA9f
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Docket No. 50-133
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License No. DPR-7 (Humboldt Bay Power Plant, Ur.t No. 3)
)
_I CERTIFICATE OF SERVICE The foregoing document of Pacific Gas and Electric Company has been served today on the following by depoei.t in the United States mail, properly stamped and addressed:
Linda J. Brown, Esq.
Robert M.
Lazo, Esq., Chairnian 100 Van Ness Avenue, 19th Floor Atomic Safety and Licensing
' San Francisco, CA 94102 Board Panel U.S. Nuclear Regulatory Commission Steve Goldberg, Esq.
Washington, D.C.
20555 Office of Executive Legal Director Mr. Gustavo A. Linenberger, Member BETH 042 Atomic Safety and Licensing U.S. Nuclear Regulatory Board Pane!
Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Secretary Dr. David R.
Schink U.S.
Nuclear Regulatory Department of Oceanography Commission Texas A & M University Washington, D.C.
20555 College Station, TX 77840 Attn:
Docketing and Service
.Section Michael R. Sherwcod, Esq.
Gierra Club Legal Defense Fund, Inc.
2044 Fillmore Street San Francisco, CA 94115 Dated:
August 13, 1981 k
' RICHARD F.
LOCKE Attorney Pacific Gas and Electric Company i
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