ML20040D793

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Petition for Decommissioning Facility.Plant Poorly & Inadequately Designed for Safe Operation & Has Long History of Operating & Safety Failures Due to Design Deficiencies
ML20040D793
Person / Time
Site: Humboldt Bay
Issue date: 01/16/1982
From: Guenther R
AFFILIATION NOT ASSIGNED
To: Lazo R
Atomic Safety and Licensing Board Panel
Shared Package
ML20040D789 List:
References
NUDOCS 8202020258
Download: ML20040D793 (2)


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D N TNUMBR PROD.& UTIL FAC.*To- / 5 3 Certified hil No. P22 9581932 January 16, 1982

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29900 Highway 20 Fort Bragg, Califo*MiaJ95Gt P1 :55

'82 3 Mr. Robert Iar.o, Chairman Atomic Safety and Licensing Board bi

[]_g U.S. Nuclear Regulatory Comission PETIT 3DN FOR DE00MG381DNING ii 1 Washington, D.C. 20555 Public Record - Humboldt Bay Nuclear Power Plant Decomissioning Mr. Chairman and Members of the Board:

This is a petition for the decomissioning of the Humboldt Bay Nuclear Power Plant.

My reasons for petitioning the Boad in this matter are as follows :

1) The subject nuclear power plant is poorly and inadequately designed for safe oper-ation, and has a long history of operating and safety failures deriving directly from design deficiencies.
2) Three earthquake faults have been discovered within h,000 feet of the zwactor, and appropriate design safety measures were not incorporated into either the reactor's design or construction.

'!he subject plant does not conform to the Nuclear Regula-tory Comission seismic standards.

The cost of bringing the subject plant into compliance with these standards could exceed $300 million, compared with estimated decommissioning costs of $35 million. Decommissioning is therefore the preferred economic alternative.

3) The subject nuclear power plant's operating record is among the worst in the history of nuclear power. The public has been presented with no convincing evidence that this sorry and irresponsible operating history will, or even can change for the better.

The latest evidence indicates that the utility will continue to operate the subject plant in a negligent, irresponsible, and unsafe manner.

h) The utility has failed to comply with an Atomic Safety and Licensing Board oMer to reveal how the company expgs go bring the subject power plant up to current Nu-clear Begulatory Commissidif)QsfandaMs. This latest example of the utility's contin-uing reckless disregad for the public health and safety indicates plant decomiss-ioning as the only practicable solution for problems of public protection.

5) The subject power plant is one of the oldest commercial nuclear power plants under the Board's jurisdiction.

It went on line in 1963. Approximately 1/2 to 1/3 of the plant's life expectancy has elapsed.

Decommissioning at this time would save future ratepayers substantial expenditures before embrittlement, increased residual radio-activity, and other safety problems become acute, and decommissioning costs rise dramatically.

6) As the utility continues to engage in delaying tactics which prolong the process of solving public protection problems, it continues to maintain, and to protect the sub-ject plant. Since 1976 the costs of maintenance have been approximately $15 million.

l Decommissioning the plant would eliminate at least maintenance problems fer core loadings, and would cut the necessary costs of plant surveillance until the plant could be either dismantled and moved to its final repository, or entombed in situ.

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Certified' Mail No. P22 9581932 7) No permanent facility for safely disposing of the nuclear wastes deriving from the operation of the subject plant exists at th$m tism.

'Ihis would include the approximately 35 tons of high-level waste now being stored at the plant site at substantial risk to the public health and safety in the area, downwind, and down-current from the site.

8) Human population densities exist only a very short distance from the subject plant site. As examples, heavily travelled Highway 101 is only 1,500 feet from the reac-tor.

'Ihere exists a nearby asidential community, beginrdng only 1/h nile from the plant. In case of accident, release of raaicactivity from the plant would seriously endanger human life in the area. Additionally, cumulative losses of life could occur in areas downwind and downcurrent from the subject site.

9) Humboldt Bay is immediately proxfate to the subject nuclear power plant site.

Safety problems inherent in the plant's radioactive discharges on sealife, and on the human feodchain, have not been effectively recognized, evaluated, or dealt with.

Thank you for your consideration.

I request your immediate action on this petition for decommissioning.

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- Ron 6uenther