ML20054J981
| ML20054J981 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/28/1982 |
| From: | YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20054J977 | List: |
| References | |
| NUDOCS 8206300261 | |
| Download: ML20054J981 (4) | |
Text
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g-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In The Matter of Docket No. 50-29 cense No. DPR - 3 YANKEE ATOMIC ELECTRIC COMPANY (Yankee Plant)
APPLICATION FOR EXEMPTION Pursuant to 10 CFR 50.12 (a), Yankee Atomic Electric Company
(" Yankee") hereby applies for exemption from the requirements of Section 50.54 (w) (1) (ii) of the Commission's Rules and Regulations (10 CFR ss 50.55(w)) as they apply to the Yankee Plant.
SUPPORTING STATEMENT In support of the foregoing application Yankee submits the following:
1.
Yankee is a Massachusetts corporation organized in 1954 and is an " electric utility" as defined in 10 CFR 2.4 (s).
Yankee is the holder of NRC License No. DPR-3, dated July 19, 1960.
2.
The Yankee Plant consists of a pressurized water reactor and associated steam electric generating equipment which was 8206300261 820628 PDR ADOCK 05000029
m o
S placed in commercial operation on July 1, 1961.
3.
The Yankee Plant was constructed for an original capital cost of $39,160,389.
As of May 31, 1982, Yankee's electric plant in service, which includes all the Yankee Plant with capital additions since 1961, had a depreciated book value of approximately $15,561,146, which is in order of magnitude below the value of current plants.
4.
The insurable actual cash value of the Yankee Plant in place is approximately $69,000,000 as of 12/31/81, includ-ing fuel.
5.
Yankee has no outstanding Mortgage Indenture which constitutes a lien against its property.
The Yankee bonds which financed in.part the original construction of the Yankee Plant were paid in 1974 and the Indenture was terminated.
There is no Indenture Trustee or any other lien creditor with a prior claim to any proceeds of insurance carried by Yankee.
6.
Yankee has completed an evaluation of the costs of decontamination and clean-up in the event of a TMI-type accident at the Yankee Plant.
Such costs are estimated to aggregate approximately $350,000,000 in 1982 dollars.
7.
As of the date hereof, Yankee has in effect property insurance coverage, issued by American Nuclear Insurers and Mutual Atomic Energy Reinsurance Pool, in the amount of
$375,000,000. and has arranged to increase that coverage, effective June 29, 1982, to an aggregate of $460,000,000, the maximum basic coverage currently available from such insurers, as required by the provisions of 10 CFR S 50. 54 (w) (i).
Such insurance proceeds would be available for decontamination and clean-up costs.
8.
Notwithstanding the foregoing, Section 50.54(w) of the Commission's regulations would require Yankee to procure for the Yankee Plant not only the maximum available property damage insurance of the primary layer of coverage (as described in paragraph 7) but also the maximum available excess coverage for damages exceeding $500,000,000, namely:
the excess coverage of
$67,000,000 excess of $500,000,000 offered by ANI/MAERP.
The cost per thousand dollars of this excess coverage is more that double that of the basic coverage.
9.
It is very significant that the Yankee Plant is quite different from most plants operating or being built today, and coverage that is appropriate for a modern plant is not appropriate for Yankee:
a.
Yankee is only 175 MW compared to 1,800 MW at TMI and 3,700 MW at Palo Verde.
b.
It cost only $40 million to build Yankee compared to $4000 million being spent on plants today.
c.
The face amount of property damage insurance carried i
by Yankee exceeds the estimated costs of decontamination and clean-up of the plant by $110,000,000 or 31%.
d.
There is absolutely no likelihood that Yankee would ever be restored to service following a serious (TMI-type) incident.
Therefore, all insurance proceeds would be available for clean-up..
~.
s 10.
Therefore, Yankee submits that the $460,000,000 insurance coverage to be maintained by Yankee effective June 29, 1982 constitutes a " reasonable amount of insurance for decontamination expense" which adequately meets the
" Commission's only concern [which is] from the point of view of protecting public health and safety".
47 F.R.
13752 (March 31, 1982).
Because that insurance is more than sufficient to cover the costs of decontamination and cleanup of the small Yankee Plant, there is no justification for imposing upon ankee a requirement to carry additional insurance coverage.
CONCLUSION Based upon the foregoing, Yankee respectfully requests that it be granted an exemption from the requirements of 10 CFR ss
- 50. 54 (w) (1) (ii).
Respectfully submitted, YANKEE ATOMIC ELECTRIC COMPANY By:
,. /
s e
s COMMONWEALTH OF MASSACHUSETTS)
)ss MIDDLESEX COUNTY
)
Then personally appeared before me, Armand R.
Soucy, who, being duly sworn, did state that he is Treasurer of Yankee Atomic Electric Company, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.
i WH Rdbert H. Groce Notary Public My Commission Expires September 14, 1984
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