ML20053E698
| ML20053E698 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 05/28/1982 |
| From: | Maneatis G PACIFIC GAS & ELECTRIC CO. |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20053E693 | List: |
| References | |
| NUDOCS 8206090165 | |
| Download: ML20053E698 (3) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
k e.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
)
In the Matter of
)
)
Pacific Gas and Electric Company
)
Docket 50-133
)
License No. DPR-7 (Humboldt Bay Power Plant,
)
Unit No. 3)
)
)
REQUEST FOR EXEMPTION Pursuant to 10 CFR 50.12 (a) Pacific Gas and Electric Company (PGandE) hereby applies for examption from the provisions of 10 CFR 50.34 (w) insofar as they apply to Unit No. 3 of its Humboldt Bay Power Plant, which is licensed to operate at 63 MWe.
In support of this application PGandE alleges as follows:
l 1.
Humboldt Unit 3 has been shut down since July 1976, is presently in a cold shutdown condition, and is no longer listed in the " Gray Book"- of licensed operating reactors (NUREG 0020).
For all practical purposes the unit should be, considered equivalent to one where fuel is on-site but the reactor is nots yet in operation.
PGandE and the NRC Staff have conducted studies of the plant in its present condition and have concluded that the unit presents no danger to the health and safety of'the public.
This conclusion was accepted by the Atomic Safety and Licensing Board in its order dated February 16, 1982.
Under that same order, within six months after the Commission reaches a final decision on the adoption of a reactor safety policy statement and its associated goals and guidelines, PGandE must report to the Board B206090165 820604 i PDR ADOCK 05000133 l
0 PDR i
'~ ""
'~'
~~______:_.
(a) that-it is ready to take the actions necessary to permit resumption of operation of Unit 3, or (b) that it will then commit to submitting to the Commission a plan to decommission the unit.
2.
PGandE presently maintains all-risk property damage insurance at the Humboldt Bay Power Plant in the amount of approximately $100,000,000.
In PGandE's opinion this is more than enough to cover the very remote possibility of any damage to the unit including any related clean-up and decommissioning costs.
In addition, the company has the assets to self-insure this exposure.
3.
If the proposed regulations apply to the Humboldt site PGandE estimates that by the end of this year it would have to purchase $900,000,000 of additional property damage insurance at an annual cost of approximately $1,000,000.
PGandE submits that in view of the facts outlined above, such needless additional insurance should not be required, and that the annual premium for such insurance would constitute a waste of the ratepayers' money, which is against the public interest.-
Subscribed in San Francisco, California, this 28th day of May, 1982.
Respectfully submitted, Pacific Gas and Electric Company By G.
A.
Maneatis G. A. Maneatis Senior Vice President -
Facilities Development e
Robert Ohlbach Philip A.
Crane, Jr.
Richard F. Locke Post Office Box 7442 San Francisco,.CA 94120 Attorneys for PACIFIC GAS AND ELECTRIC COMPANY By Philip A. Crane, Jr.
Philip A.
Crane, Jr.
Subscribed and sworn to before me this 28th day of May 1982.
Nancy J.
Lemaster SEAL (SEAL)
Nancy J.
Lemaster, Notary Public in and for the City and County of San Francisco, State of California.
My Commission expires April 14, 1986.
O
_ _ _.