ML20058B630
| ML20058B630 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/22/1990 |
| From: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20058B634 | List: |
| References | |
| AGM-NUC-90-271, NUDOCS 9010300357 | |
| Download: ML20058B630 (4) | |
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beSMUD ss SACRAMENTO MUNICIPAL UTIUTY DISTRICT O 6201 S Street, P.O. Box 15830. Sacramento CA 958521830,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA AGM/NUC 90-271 October 22, 1990 U.S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 Docket No.
50-312 Rancho Seco Nuclear Generation Station License No DPR-54 ONSITE PROPERTY DAMAGE AND DECONTAMINATION INSURANCE EXEMPTION REQUEST, (Rev. 1), 10 CFR 50. 54 (w) (1)
Reference:
- 1. John Larkins (NRC) to Dan Keuter (SMUD),
letter dated May 16, 1990, " EXEMPTION RELATED TO 10 CFR PART 55 - REQUIREMENTS FOR A SIMULATION FACILITY AND SIMULATOR TRAINING (TAC NO. 75520)" AND ATTACHMENTS.
2.
Dan Keuter (SMUD) to George Knighton (NRC), letter AGM/NUC 90-047 dated March 5,
- 1990, "ONSITE PROPERTY DAMAGE INSURANCE EXEMPTION REQUEST, 10 CFR 50,54 (w) (1).
Attention:
Seymour Weiss Pursuant to 10 CFR 50.12 " Specific Exemptions," the District hereby amends its previous request for an exemption from the requirements of 10 CFR 50.54 (w) (1). The regulation requires licensees to obtain and maintain a minimum of $1.06 billion of onsite decontamination insurance-coverage for radiological accidents at the reactor station site.
Current District coverage for onsite property insurance meets this requirement.
However, requirements for this coverage were predicated on accident conditions that could exist at an operating facility.
Because Rancho Seco is permanently shut down and completely defueled, credible accidents during power operations are not possible in the defueled condition (Reference 1).
As cited by Part 50, Statements of Consideration, the regulations:
require licensees to maintain substantial amounts of onsite property insurance to provide financial security for stabilizing and decontaminating or decommissioning their licensed reactors in the event of an accident.
Although 10 CFR 50.54 (w),_ and Statements of Consideration do not specify what' types of accidents to consider, the District evaluated various crediblo, scenarios and determined that Rancho Seco in the defueled c6nd{t'.Lon-could not have an accident that would pose any significant risk to the public health and safety.
9010300357 901022
}DR ADOCK 05000312
[$0 PDC ii 8
RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road. Herald, CA 95638 9799;(209) 333 2935
4 Seymour Weiss AGM/NUC 90-271 Because there are no credible accidents that would require coverage at the $1.06 billion regulatory amount, the District amends its original request (Reference 2) to reduce coverage to $30 million coverage required for a radiological accident.
presents the District's conservative analysis for the postulated worst case radiological accident of a maximum dollar amount of $28 million.
Attachment 1,
provides the-District's justification for the requested exemption, and Attachment 2 presents the District's
" Property Loss Study."
i Members of your staff requiring additional clarification or justification may contact Jerry Delezenski (209) 333-2935, extension 4914.
i Sincerely, m
_ :_$ w Dan R.
Keuter Assistant General Mar.ager, Nuclear l
]
cc:
J.B. Martin, NRC, Walnut Creek C. Myers, NRC, Rancho Seco l
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ATTACHMENT 1 JUSTIFICATION FOR EXEMPTION FROM 10 CFR 50.54 (w) (1)
EXEMPTION CRITERIA 10 CFR 50.12 " Specific Exemptions" describes the criteria for exemptions from the requirements of 10 CPR 50.
The NRC may grant exemptions from Part 50 regulations if special circumstances are present-and an undue risk will not be presented to the public health and safety.
In the discussion below, the District will address the following exemption criteria of -10 CFR 50.12 (a) (2):
(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; (iii)
Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the rule was adopted...;
RaAls for Exemption Because of a public vote on June 6,
1989, the District shutdown Rancho Seco Nuclear Generating Station and completed defueling operations on December 8, 1989.
As discussed in the granting of partial exemption from 10 CFR 55 (Reference 1), there are no longer any: credible design basis accidents except loss of offsite power and a fuel' handling-accident.
The permanently defueled condition combined with administrative controls result in minimal fuel movement-further reducing the possibility of an accident.
Moreover, the NRC has issued a confirmatory order; modifying-the Rancho Seco license to prohibit:the movement of fuel from the Spent-Fuel Pool' into the Reactor Building without prior Commission approval.
The requirements for 10 CFR. 50.54 (w) (1) = were predicated.on the need-to ensure that property damage and decontamination coverage from a severe accident from power operations wouldl ensure stabilization,.
-decontamination, or decommissioning as a result of an accident and would not endanger public health and safety.-
Compared to the design basis accidents of an operating facility, Rancho Seco is no longer' capable of an accident ~ that would result' in significant costs exceeding the requested $30 million onsite' decontamination
-insurance ' coverage,. ' and thereby would not serve the. underlying purpose of the rule when the rule was promulgated (10 CFR 50.12 (a) (2) (ii) ).
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. Because the amount of coverage required by the regulation for stabilization, decontamination, or decommissioning is based upon
' an operating facility, the District believes that the amount of coverage required for a facility permanently shutdown, defueled, and not capable of severe accidents requiring significant cleanup are significantly less than those considered when the rule was contemplated and subsequently amended.
Literal compliance with the requirements for $1.06 billion in-property coverage would result in undue hardship and costs on the ratepayers of the District and costs to maintain onsite decontamination coverage are significantly in excess of those contemplated when the rule was adopted (10 CFR 50.12 (a) (2) (iii)).
1 Therefore, the District has determined that the requirements to maintain coverage of $1.06 billion is excessive, and is requesting an exemption from the full amount specified by 50.54 (w) (1) to an amount of $30 million.
This coverage is commensurate with:
o the reactor defuoled to the Spent Fuel Pool, o
plant closure and layup activities, o
an NRC issued license condition which prevents the movement of fuel into the reactor building without prior NRC approval, o
a pending Possession only License, o
minimal potential consequences for accidents considered credible in the defueled condition, o
the District's intent to decommission Rancho Seco, o
- Attachment 2, Property Loss Study For Rancho Seco Nuclear Generating Station in The Long Term Defueled Mode, and o
previously granted exemptions.for facilities with similar circumstances (i.e.,
PG&E's-Humbolt Bay and LILCO's Shoreham).
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