ML20041C184

Submits Petition for Decommissioning Facility.Plant Poorly & Inadequately Designed & Located within 4,000 Ft of Earthquake Faults.Decommissioning Plan Is Economic Alternative to Reconstruction

ML20041C184
Person / Time
Site:	Humboldt Bay
Issue date:	01/16/1982
From:	Guenther R AFFILIATION NOT ASSIGNED
To:	Harold Denton, Lazo R Atomic Safety and Licensing Board Panel, Office of Nuclear Reactor Regulation
References
NUDOCS 8202260313
Download: ML20041C184 (2)

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Cartifi:d Mail No. P22 9581932 9@\\k'%

Toa Harold Deptond.

January 16, 1982 Director of Nuclear Beactor Regulation U,5. Nuclear Regulatory Commission 29900 Highway 20 Washington, D.C. 20555 Fort Bragg, California 95h37 I Q To: Mr. Robert Iazo, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission PETITION ER DE00MHISSID '

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dgy Public Record - Humboldt Bay Nuclear Power Plant Decommissio Kr. Chairman and Members of the Boards ff This is a petition for the decommissioning of the Humboldt Bay Nuclear Powe 16 17 reasons for petitioning the Board in this matter are as follows:

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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) Wree earthquake faults have been discovered within h,000 feet of the reactc.r, and appropriate J =1gn safety measures were not incorporated into either the reactor's design or construction.

The subject plant does not conform to the Nuclear Regula-tory Commission seismic standards.

7he 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.

1he latest evidence indicates that the utility will continue to operats the subject i

plant in a negligent, irresponsible, and unsafe manner.

b) The utility has failed to comply with an Atomic Safety and Licensing Board order to reveal how the company expgs p bring the subject power plant up to! current Nu-clear Regulatory Commissiongandards. This latest example of the utility's contin-uing reckless disregard for the public health and safety indicates plant decommiss-inning as the only practicable solutien for problems of public protection.

5) 2he subject power plant is one of the oldest comnercial 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.

Deconmissioning at this tine would save future ratepayers substantial expenditures before embrittlement, increased residual radio-activity, and other safety p oblems becore acute, ard crecommissioning costs rise drama tically.

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.

Decommissioning the plant would elininate at least maintenance problens for core Icadings, 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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7) No pernanent facility for safe]y disposing of the nuclear wastes deriving from the operation of the subject plant exists at this tire.

This 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, dcwnwind, and down-current from the site.

8) Human population densities exist only a very short distance from the subject plant j

site. As examples, heavily travelled Highway 101 is only 1,500 feet from the reac-

, tor.

There exists a nearby residential community, beginning only 1/h mile from the plant. In case of accident, release of radioactivity from the plant would seriously endanger human life in the area. Additionally, cumulative losses ef life could j

occur in areas downwind and downcurrent from the ;ubject site.

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

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

Thank you for your consideration.

I request your immediate action on this petition for decommissioning.

~ Ron 6uenther 1

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Fort Bragg, California 95107

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Harold Denton

.I Director of Nuclear Beactor Regulation i-U.S. Nuclear Regulatory Comunission Washington, D.C. 20555

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