ML20042A827
| ML20042A827 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 03/19/1982 |
| From: | Jenny Murray NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8203240167 | |
| Download: ML20042A827 (1) | |
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t.a u MEMORANDUM FOR:
Harold R. Denton, Director
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Office of Nuclear Reactor Regula og FROM:
James P. Murray Director and Chief Counsel Rulenaking & Enforcement Division, OELD
SUBJECT:
Petition Requesting Decomissioning of Humboldt Bay Facility Ron Guenther, by petition dated February 20, 1982, has requested that the Ccamissin order the decommissioning at this time of-the Pacific Gas
& Electric Co's Hunboldt Bay facility. Mr. Guenther has set forth several reasons for his request, including the failure of the facility to comply with Comission seismic standards, the poor operating history of the facility, and several types of adverse environmental and safety impacts which would presumably occur if the facility resumed operating.
fir. Guenther's petition was originally submitted to the Atomic Safety &
Licensing Board sitting in the Humboldt Bay case.
In response to a letter from Staff Counsel, Hr. Guenther resubmitted his petition to your office.
This office will work with you and your staff to develop an appropriate response to the petition.
Enclosed for your use are:
1.
A copy of the petition; 2.
A draft letter of acknowledgment; and 3.
A draft Federal Register notice.
Please infonn us who your staff contact on this matter will be.
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s James P. Murray Director and Chief Counsel Rulemaking & Enforcement -
Division Dist.
NRC Cent. 2.206 chron Cunningham
Enclosures:
As stated:
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Cartified Mail No. P22 9381932 Q
To Earold Denton-January 16, 1982
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Director of Nuclear Heactor Hogulation U.S. 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 Comission PETITIDN FOR DECOMMISSID W shington, D.C. 20555 gECE4<20 OJ N,E8 g W
l' Public Record - Humboldt Bay Nuclear Power Plant Decomissio kgganar 2h $
Mr. Chairman and Members of the Boards b
77 mis is a petition for the decommissioning of the Humboldt Bay Nuclear Powe t$
$ reasons for petitioning the hard in this matter are as follows:
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- 1) me 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 reactor, and apprm rb'c doolgn safety measures were not incorporated into either the reactor's
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design or construction.
The subject plant does not conform to the Nuclear Regula-tory Commission 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. Decomissiening is therefore the preferred econctic alternative.
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- 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 arxi irresponsible operating history will, or even can change for the better.
The latest evidence indicates that the utility will continue to operats the subject i
plant in a negligent, irresponsible, and unsafe manner.
h) The utility has failed to comply with an Atomic Safety and Licensing Board order to reveal how the company exgs j+ bring the subject power plant up to current Nu-clear Regulatory ComissiongDndards. This latest example of the utility's contin-ufng reckless disregard for the public health and safety indicates plant decomiss-inning as the only practicable solutien fer problems of public pmtection.
- 5) Ihe subject power plant is one of the oldest commercial nuclear power plants under l
the hard's jurisdiction.
It went on line in 1963. Approximately 1/2 to 1/3 of the plant's life expectancy has elapsed. Decomissioning at this time would save future ratepayers substantial expenditures before embrittlement, increased residual radio-activity, and other safety problems become acute, and d'ecommissioning cos,ts 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.
Decomnissioning the plant would eliminate at least maintenance problens for core icadings, and would cut the necessary costs of plant surveillance until the plant could be either dismantled and coved to its final repository, or entombed in situ.
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- 7) No permanent facility for safely disposing of the nuclear wastes deriving from the operation of the subject plant exists at this ti:ne. 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, 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-
,to r.
There exists a nearby residential corzunity, beginning only 1 h mile from the
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i plant. In case of accident, release of radioactivity 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 proximate to the subject nuclear power plant site.
Safety problems inherent 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.
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~ Ron O' enther.
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(Draft)
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Ron Guenther 29900 Highway 20 Fort Bragg, California 95437
Dear Mr. Guenther:
This is to acknowledge receipt of'your petition, previously submitted to the Atomic Safety & Licensing Board, requesting that the Humboldt Bay facility be decommissioned. Your petition will be treated under 10 CFR 2.206 of the Commission's regulations. Accordingly, appropriate action will be taken on your petition within a reasonable time.
I enclose for your information a copy of the notice that is being filed for publication with the Office of the Federal Register.
Sincerely,,
Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated cc: To licensee
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(Draft) 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
[DocketNo.
]
Pacific Gas & Electric Co.
(Humboldt Bay Power Plant)
Request for Action Under 10 C.F.R. 2.206 Notice is hereby given that by request dated February 20,1982, Mr. Ron Guenther petitioned the Commission to order the decommissioning of Pacific Gas & Electric Company's Humboldt Bay facility. This petition is being treated as a request pursuant to 10 C.F.R. 2.206 of the Commission's regulations, and accordingly action will be taken on the petition w'ithin a reasonable time.
Copies of the petition are available for inspection in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D.C. 20555, and in the local public document room at the Dated at Bethesda, Maryland, this day of March, 1982.
For the Nuclear Regulatory Commission Harold R. Denton, Director Office of Nuclear Reactor Regulation i
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