ML20012B625
| ML20012B625 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/05/1990 |
| From: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AGM-NUC-90-047, AGM-NUC-90-47, NUDOCS 9003150430 | |
| Download: ML20012B625 (3) | |
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SACRAMENTO MUNICIPAL UTILITY DISTRICT D 6201 S Street. P.o. Box 15830, Sacramento CA 958521830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA' I, I @-
LAGM/NUC 90-047 March 5, 1990' p g 3;
U..S. Nuclear Regulatory Commission Attn:
Document-Control Desk
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- Hashington, DC-20555
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.a Docket No. 50-312
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. Rancho Seco Nuclear Generating Station License No. DPR ONSITE PROPERTY DAMAGC INSURANCE EXEMPTION REQUEST, 10 CFR 50.54 (w)(1)
Attentioni : George Knighton
-The District hereby requests'an exemption from the requirements of 10 CFR 50.54-(w)(1), which requires onsite property damage insurance for a minimum-coverage'l.imit for the' reactor station site of $1.06 billion.
The District is currently maintaining-onsite property insurance which meets this requirement.
The: purpose of the' insurance-is to ensure that following an accident.--the reactor can be placed in.a safe and stable condition-and can be maintained in that condition-so as.to prevent-any significant risk to the public health and
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safety. "In addition to stabilization, the regulation further requires
. insurance funding-be adequate to allow the resumption of operation 08-decommissioning.
Considering Rancho Seco's present and future status, the District is requesting an' exemption fron the full amount specified in 10:CFR'50.54 (w) to-an appropriately reduced amount of $210 million commensurate with the second
'j' option, decommissioning..As recognized by the NRC in:its letter of 1
January. 18,.1990,~from Dr. Thoma: E.-Murley to Mr. David.A. Boggs, this j
exemption. request is based on the following:
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-1.
Rancho Seco is defueled with all fuel in the spent fuel pool 2
building.
.2' The District does not intend to resume power operations at Rancho 1
'Seco.
j 3.
Design basis accidents for a nuclear facility in a defueled j
condition are all associated with loss of fuel pool water inventory or with fuel. handling.
- 9003150430 900305 9
PDR-ADOCK-05000312 N
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n 1 RANCHO SECO NUCLEAR GENERATING STATION D 1444o Twin Cities Road, Herald. CA 95638 9799;(209) 333-2935 i
l George Knighton-AGM/NUC 90-047 The District'is requesting that an exemption be granted which would reduce the amount of required onsite property damage insurance from $1.06 tillion to $210 million.
This reduced value is based on 10 CFR 50.75, which establishes reasonable assurance of funds for decommissioning.
For a 3400 MHt PHR, which is larger than Rancho Seco's 2772 MHt rating, $105 million (in 1986 dollars) in decommissioning funding is required.
By using twice this value, the property damage insurance has a margin which exceeds approximately 80% of the
_ reasonable assurance of funds required for decommissioning by 10 CFR 50.75.
An exemption from the property insurance requirements is appropriate under 10 CFR 50.12.
The rule uses a two tier test to determine if a licensee's request for an exemption should be granted.
First, the regulation specifies that the'NRC may grant exemptions which are:
(1)
" Authorized by law, will not present an undue risk to the public
-l health and safety, and are consistent with common defense and security."
While this exemption would represent a reduction from the full scope of 10 CFR 50.54 (w) as applied to nuclear power plants with operating licenses, it still provides for the adequate protection of the public health and safety and is
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consistent _with the potential safety hazards associated with a defueled reactor.
Second, the regulation provides that an exemption request will not.be considered unless one or more of six special circumstances are present w
[10 CFR 50.12 (a)(2)(i)-(vi)). Specifically, special circumstances are present whenever:
(1)
Application of.the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; or (ii)
Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule; or (iii) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation pas adopted, or that are significantly in excess of those incurred by other similarly situated; or (iv)
The exemption would result in benefit to the public health and 1
safety that compensates for any decrease that may result from the grant of the exemption; or (v)
The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made_ good faith efforts to comply with the regulation; or L
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George Knighton AGM/NUC 90-047 i
(vi)
There is present any other material circumstance not considered i -
when the regulation was adopted for which it would be in the
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public interest to grant an exemption.
I-Clearly, considerations (ii), (iii) and (vi) apply to the circumstances at Rancho Seco. As previously discussed, the intent of the regulation was to allow adequate funding for resumption of power or decommissioning following some reactor accident which resulted in significant onsite contamination.
In the defueled mode, the fundamental premise of a reactor ar
,ent is not an applicable circumstance.
By allowing for insurance exceecng what is considered adequate funding for decommissioning, the intent of the regulation is served.
Likewise, an annual insurance premium savings of approximately
$1.7 million.can be realized if the lower amount of $210 million coverage is allowed. ~The NRC has allowed a comparable reduction to other utilities in similar circumstances (i.e., PG&E's Humbolt Bay and LILCO's Shoreham, etc.).
Circumstance (vi) would subsequently be served by providing the ratepayers/
owners annual savings in insurance premiums which is in the public interest.
Members of your staff with questions requiring additional information or clarification may contact Ms. Rita Bowser at (209) 333-2935, extension 4S22.
State of California l
SS County of Sacramento Dan R. Keuter, being first duey sworn, deposes and says:
that he is Assistant General Manager, Nuclear of Sacramento Municipal Utility District (SHUD), the licensee herein; that he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute this document on behalf of said licensee.
Dan R. Keuter Assistant General Manager Nuclear Subscribed and affirmed to before me on this day of
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, 1990, tv
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'Th/11aByrne Notary Public cc:
J. B. Martin, NRC, Halnut Creek A. D'Angelo, NRC, Rancho Seco OrFICl4.g nu-
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