ML20058H247
| ML20058H247 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 07/28/1982 |
| From: | Maneatis G PACIFIC GAS & ELECTRIC CO. |
| To: | Saltzman J NRC OFFICE OF STATE PROGRAMS (OSP) |
| References | |
| NUDOCS 8208030523 | |
| Download: ML20058H247 (5) | |
Text
s PACIP'IC CrAS AND ELECTR,IC C O M PANY
)bMWIb l
77 BEALE STREET
- SAN F R ANCISCO, C ALIFO R NI A 94106 *(415) 781 4211 0.A.MANEATl3 stmoe vitt ratstoter July 28, 1982 Mr. Jerome Saltzman Assistant Director State and Licensee Relations Office of State Programs U.S. Nuclear Regulatory Commission Washington, DC 20555 Re:
Docket No. 50-133 License No. DPR-7 Humboldt Bay Power Plant
Dear Mr. Saltzman:
Set forth below are our responses to the questions contained in your letter to me dated June 24, 1982.
Question #1 What does PGandE pay for the $100,000,000 on-site coverage currently in effect?
Answer The gross annual premium for approximately
$100,000,000 of on-site coverage at Humboldt Bay Power Plant (HBPP) is approximately $445,000.
This premium is then reduced by approximately
$105,000, due to the fact that Unit #3 is not operating.
Thus, the net annual premium for HBPP is approximately $340,000.
Question #2 Which insurance carriers has PGandE contacted for the additional coverage?
What premiums have the carriers quoted to PGandE for such additional coverage?
If available, give the incremental cost (e.g. rate /$ million of coverage) of additional primary and excess coverage.
l Answer The carriers that were contacted either directly or indirectly through the use of a broker for l
additional nuclear property coverage are shown below:
(
8208030523 820728 pdf PDR ADOCK 05000133 J
Mr. Jerome Saltzman
, July 28, 1982 Page 2 (Answer cont'd)
Nuclear Mutual Limited (NML)
Nuclear Electric Insurance Limited (NEIL)
American Nuclear Insurers
)
)ANI/MAERP Mutual Atomic Energy Reinsurance Pool)
American Insurance Group (AIG)
The estimated annual premiums the carriers are currently quoting to PGandE for the additional coverage is as follows:
ADDITIONAL EST. ADD'L.
RATE /$
LIMITS OF ANNUAL MILLION LAYER INSURANCE PREMIUMS COVERAGE CARRIER Primary
$400,000,000 $490,000
$1,225 NML Excess
$67,000,000
$201,000
$3,000 ANI/MAERP excess of
$500,000,000
$467,000,000 $691,000
$1,480(average)
(
- The current regulations require PGandE to either l
purchase $67 million from ANI/MAERP or $315 million f
l from NEIL 2.
If the regulations allowed PGandE to i
purchase $67 million from NEIL 2, in lieu of $315 l
million, the excess premium could probably be I
reduced from $201,000 to $120,000, plus a potential I
retrospective assessment Question #3 When contacting carriers concerning additional coverage, did PGandE attempt to negotiate premiums no that they would reflect PGandE's perceived risk of potential damage at the Humboldt Bay reactor?
l 1
Mr. Jerome Saltzman July 28, 1982 Page 3 Answer Yes.
PGandE, along with another NML member, requested that the Board of Directors of NML review their rating schedule for coverage in excess of insurable values.
As a result of this review, the Board of Directors, at the June, 1982, Board meeting, revised their rating structure from a flat rate of 18g per hundred of coverage in excess of insurable values to a sliding scale based on the amount of insurance as a % of insurable values.
In addition, NML agreed during negotiations concluded on July 26, 1982, that a shutdown credit of approximately 23% would also be applicable to the premium in effect for the $400,000,000 additional on-site coverage currently required by the NRC.
The net result of both the rate and shutdown negotiations is a reduction of approximately
$300,000 from the annual premium of approxi-mately $1,000,000 shown in our May 28, 1982 request for an exemption.
Question #4 Has PGandE evaluated or attempted to secure equivalent amounts of protection other than insurance as provided by 10 CFR 50.54 (w) ?
Such protection could include secured lines of credit, letters of credit, surety bonds or other instruments.
Answer Yes.
We have evaluated the feasibility of securing equivalent amounts of protection other than insurance as provi ded by 10 CFR 50.54 (w).
The results of these evaluations are shown below:
A.
Lines of Credit:
The estimated cost is approximately 1/2% of the amount of the line of credit required.
Based on a requirement of $467,000,000*, the i
estimated annual cost would be approxi-l mately $2,335,000.
j
- $500,000,000 (primary) and $67,000,000 (excess) less
$100,000,000 (current coverage) i
Mr. Jerome Saltzman July 28, 1982 Page 4 7
(Answer cont'd) l B.
Surety Bonds:
The broker has indicated that it does not believe it is possible to secure a bond in the amount or with the form of protection required by the NRC.
In addition, if bonding companies
- were willing to write this type of bond, our broker indicated that it would probably be necessary for PGandE to provide a letter of credit for the bonding companies rather than an indemnity from PGandE.
- There is not sufficient capacity available from one bonding company to provide the limits required by the NRC ($467,000,000)
Question #5 Has PGandE conducted any studies other than those referenced in the Request for Exemption that analyze the risk and consequences of an accident at the Humboldt Bay reactor in its current state of cold shutdown?
If such studies are available, please indicate the maximum decontamination and cleanup costs that could be predicted.
Answer PGandE has not conducted any additional studies that analyze the risk and consequences of an accident at the Humboldt Bay Plant in its current cold shutdown state because no credible sequence of events can be postulated that would lead to any significant release of radioactive materials.
A study was performed which estimated the costs of decommissioning the nuclear unit with total decontamination and disposal of all
(
materials at $63 million in 1981 dollars.
l Obviously, total decontamination and disposal costs for the unit would far exceed the costs for any cleanup that might be required from an accident with the reactor in its current state.
l I
Mr. Jerome Saltzman July 28, 1982 Page 5 If you need any additional information, please let me know.
Very truly yours, cc:
Mitzi A.
Young