ML20203L322

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Comments on Des for Decommissioning of Facility.Recommends Complete Decommissioning & Dismantling of Facility for More Realistic Cost Basis
ML20203L322
Person / Time
Site: Humboldt Bay
Issue date: 08/01/1986
From: Barr G
LEAGUE OF WOMEN VOTERS OF HUMBOLDT COUNTY, CA
To: Philips J
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-51FR15853 NUDOCS 8608260056
Download: ML20203L322 (3)


Text

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' August 1, 1986 ,

U.S. Nuclear Regulatory Commission Washington, D. C 20555 ATTN: John Philips, Chief, Rules & Procedures Branch Division of Rules and Records, Office of Administration, 4000MNBB RE: Decommissioning of Humboldt Bay Nuclear Power Plant #3 Eureka, California

Dear Mr. Philips:

Thank you for the opportunity to comment on the Draft Environmental Statement for Decommissioning Humboldt Bay Power Plant, Unit 3#.

We are concerned that the Draft Environmental Statement for decommiasioning Humboldt Bay Nuclear Power Plant has not adenuately addressed the potential significant environmental impacts of long term storage of nuclear waste materials in a seismic-active area.

Since the nuclear power plant lies in close proximity to three potentially capable geologice faults 1) Little Salmon Fault

2) Day Entrance Fault and 3) The Buhne Point Fault, we feel that the two-step operation proposed by the NRC for decommissionine the plant; SAFSTOR (for 30 years) and DECON would be the least desirable solution: we propose immediate dismantling of the plant and removal of all spent radioactive material. In their comments on the DCS, the California Coastal Commission notes that the arguments for SAFSTOR seem to be based on the assumption that no disposal site exists for spent nuclear fuel assemblies and the DES refers only to NRC disposal sites and ignores any othep61ternative site which may be available through the Denartment of Pnergy.

Nuclear waste from the Three Mile Island nuclear plant and Shippingport nuclear power plant, both in Pennsylvania, are beina shipped to the Hanford Reservation in Washington. Also, Hanford has been receiving nuclear material frem the Humboldt Bay nuclear plant for many years.

If in 1983, PG&E concluded it was uneconomical to carry out seismic modifications to continue operation of the .nlant, we feel it is contradictory for the utility ccmpany to conclude that radioactive materials can be stored for 30 years on this same seismically active site. We do not feel that SAFSTOR for 30 years is the " sole viable alternative" and we would like to propose the NRC explore more fully other alternatives. If h bl [) l)l,{,() h D$ f

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ll0 OTTIM CU 0 ll1 0 Ul ENTOM of the radioactive liquid cannot be guaranteed safe in the event of seismic activity, how then.can PG&E guarantee us that SAFSTOR will survive any seismic event? This clearly is a contradiction in reasoning. And, most importantly, where in the DES is the guarantee that in thirty years the radioactive material will be removed from the plant?

The Draft Environmental Statement is vague about the actual costs for the thirty year period of SAFSTOR and DECON. To say that SAFSTOR is the most cost-effective of alternatives without truly delving into actual costs'of all three methods for decommissioning dces. not really answer the question of cost.

Since the Nuclear Energy Industry lacks experience in dis-mantling commercial' nuclear power plants, the Humboldt Bay Plant will most likely set the precedent for the rest of the nation's reactors and we~think it is important to establish a solid cost basis for more accurate estimates of decommissioning costs so that realistic " set aside funding" can be met. A complete decommissioning and dismantling of the Humboldt Bay Nuclear Power ~ Plant would provide a much more realistic cost basis for extrapolation to other plants than currently exists (current estimates are generally based on decommissioning of small experimental units which are not comparable to commercial reactors). Humboldt Bay is a good example of poor planning for decommipsioning funding with an estimated 63 million dollar cost and onp alf million dollars set aside for the process. SAFSTOR will only delay the establishment of the true costs of these undertakings.

Sincerely yours, Q

M. Barr, Natural Resources

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U.S. Nuclear Rr>gulatory Commission Washington, D.C. 20555 ATTN: John Philips, Chief, Rules & Procedures Branch j

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