ML20246J705
| ML20246J705 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/09/1989 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | Wood R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8907170430 | |
| Download: ML20246J705 (5) | |
Text
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' Pacific Gas and Electric Company 77 Beak Street Fkhatdi Lotfe Sanfrancisco CA Romey at Lu 415'972 6615-finniong 4Jntwa P O Box 7442 San F anteo CA 94120
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June 9, 1989
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Mr. Robert Wood License Relations Analyst
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Office of Nuclear Reactor Regulation Mail Station WFI 12-E-4 United States Nuclear Regulatory Commission Washington, D.C.
20555 Re:
Docket No. 50-133 License No. DPR-7 Humboldt Bay Power Plant
Dear Mr. Wood:
As we discussed last week, enclosed are an origiaal and five conformed copies of an application for exemption from certain insurance requirements of 10 C.F.R. 50.54(W) filed pursuant to 10 C.F.R. 50.12(a).
Kindly acknowledge receipt of this material on the enclosed copy of this letter end return it to me in the enclosed envelope.
Very truly yours,
)Ig$t D
. LOCKE li/L: sis cc:
Mitzi A. Young, Esq., U. S. NRC Document Control Desk, U. S. NRC Llnclosures l
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UNITED-STATES OF AMERICA 1
-NUCLEAR'. REGULATORY; COMMISSION 2
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-In the Matter of-
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Docket No. 50-133 5
- Pacific Gas and Elf;tric Company
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License No. DPR-7 (Humboldt Bay' Power Plant,
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REOUEST FOR EXEMPTION 9
10 Pursuant to 10 C.F.R. 50.12(a), Pacific' Gas and
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-Electric Company ("PG&E") hereby applies'for exemption from 12
.the provisions of 10 C.F.R. 50.54(w) as-they: apply to Unit 13 No. 3 of its Humboldt Bay Power Plant to allow for a 1
14 reduction in on-site property' damage insurance from'the 15 current $100,000,000 to $63,160,000.
In support of this
'16 request, PG&E asserts as follows:
17 (1)
Humboldt Bay Power Plant Unit No. 3 ("Humboldt"),
18 a 63 MWe BWR, shut down in July 1976 for refueling, main-19 tenance, and modifications.
The plant remained in a shut-20 down condition until 1983, when PG&E decided to decommission 21 it.
Subsequently, on July 30, 1984, PG&E submitted'a 22 proposed Decommissioning Plan, proposed Technical Specifica-
.23 tions,-and an Environmental Report in support of these 24 changes.
25 26 v __
_ _ _ _ _________ _ __ ---___________u
a (2)
On July 16, 1985, the NRC issued Amendment No. 19 1
which revised License No. DPR-7 to possess-but.-not-operate 2
status.
3 (3)
On April 29 and May 6, 1987, respectively, the NRC 4
issued a Safety Evaluation Report ("SER") and a Final En-5 vironmental Statement assessing the Decommissioning Plan for 6
Humboldt.
7 (4)
On July 19, 1988, the NRC issued Amendment No. 23 8
to Humboldt License DPR-7 which:
9 (a)
Deleted certain license conditions 10 related to seismic modifications 11 required before the NRC would 12 authorize return to power; (b)
Revised the Technical Specifica-tiont, to reflect the possess-but-not-operate status of the #acility; (c)
Approved the Company's SAFSTOR Plan for decommissioning the plant; and (d)
Extended the License for 15 addi-tional years to November 9,
- 2015, 20 to be consistent with the Decommis-21 l
sioning Plan.
22 In conjunction with the issuance of Amendment 23, the Com-mission issued Supplement 1 to its Safety Evaluation Report.
(5)
All fuel has been removed from the reactor (394 26 L-g.
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l assemblies) and is currently stored in the spent-fuel pool 1
along with 54 in-core fission chambers.
2 (6)
With NRC's approval of PGEE's SAFSTOR Decommis-3 sioning Plan and the-accomplishment of necessary activities 4
to place the plant in a SAFSTOR mode, the unit should be 5
considered for all practical purposes a spent-fuel storage 6
facility which presents no danger to the health and safety 7
of the public.
Moreover, the possibility of a criticality 8
accident in the spent-fuel pool which could affect the fuel 9
handling building or other site property is considered so 10 small that the consequences of such an event do not need to 11 be evaluated (SER at 10-3, April 29, 1987).
12 7.
PG&E presently maintains all-risk property damage insurance for the Humboldt site in the amount of 14
$100,000,000 based upon an exemption granted to PG&E by the NRC on November 3, 1982.
In April 1989 PG&E decided to reduce the amount of. site property damage insurance to
$63,160,000 based in part upon a discussion with Nuclear Mutual Limited that " decommissioned" plants be insured for g
the book value of the plant (which in this case is
$10,294,000) plus the value of the other two fossil units on the site ($52,966,000).
In PG&E's opinion, $63,160,000 is more than enough insurance to cover the extremely remote possibility of any damage to the unit including any related Cleanup and decontamination Costs.
In addition, the Company has the assets to self-insure this exposure. _
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The difference in cost between the present 1
$100,000,000 in insurance versus the requested $63,160,000
-2 is approximately $94,000 per annum.
PGEE su'amits that in l
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view of the facts outlined above, such needless additional 4
insurance should not be required and that the additional 5
annual premium for such insurance would constitute a waste 6
of the ratepayers' money, which is against the public inter-7 est.
8 Subscribed and sworn to by the undersigned in San Francisco, California this day of June 1989.
10 Respectfully submitted, 11 PACIFIC GAS AND ELECTRIC COMPANY 12 13 14 By W
U JAME
. 'SHIFFER 15 Vice esident uclear Power Generation 16 19 HOWARD V. GOLUB Subscribed and swor to 18 RICHARD F. LOCKE before ne this 8 day Attorneys for of June 1989.
19 PACIFIC GAS AND ELECTRIC COMPANY 20 P. O. Box 7442 San F ncisco, CA 94120 By ff (hf ks f /)$N)V$
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