Commitments And Contingencies | NOTE 13: CONTINGENCIES AND COMMITMENTS PG&E Corporation and the Utility have significant contingencies arising from their operations, including contingencies related to enforcement and litigation matters and environmental remediation. The Utility also has substantial financial commitments in connection with ag reements entered into to support its operating activities. See “Purchase Commitments” below. PG&E Corporation has financial commitments described in “Other Commitments” below. Enforcement and Litigation Matters CPUC Matters Order Instituting an Investigation into Compliance with Ex Parte Communication Rules During 2014 and 2015, the Utility filed several reports to notify the CPUC of communications that the Utility believes may have constituted or described ex parte communications that either should not have been made or that should have been timely reported to the CPUC. Ex parte communications include communications between a decision maker or a Commissioner’s advisor and interested persons concerning substantive issues in certain formal proceedings. Certain communications are prohibited and others are permis sible with proper noticing and reporting. On November 23, 2015, the CPUC issued an OII into whether the Utility should be sanctioned for violating rules pertaining to ex parte communications and Rule 1.1 of the CPUC’s Rules of Practice and Procedure gov erning the conduct of those appearing before the CPUC. The OII cites some of the communications the Utility reported to the CPUC. The OII also cites the ex parte violations alleged in the City of San Bruno’s July 2014 motion, which it filed in the CPUC i nvestigations related to the Utility’s natural gas transmission pipeline operations and practices. A prehearing conference in the OII has been scheduled for March 1, 2016. The CPUC will determine any penalties that might be imposed on the Utility and de termine whether shareholders or ratepayers will bear the costs of the investigation. The CPUC can impose fines up to $50,000 for each violation, per day. The CPUC has wide discretion to determine the amount of penalties based on the totality of the circu mstances, including such factors as how many days each violation continued; the gravity of the violations; the type of harm caused by the violations and the number of persons affected; and the good faith of the entity charged in attempting to achieve compl iance, after notification of a violation. The CPUC is also required to consider the appropriateness of the amount of the penalty to the size of the entity charged. The CPUC has historically exercised this discretion in determining penalties. PG&E Corporation and the Utility believe it is probable that the CPUC will impose penalties on the Utility in the OII but they are unable to reasonably estimate the amount or range of future charges that could be incurred, because it is uncertain how the CPUC w ill calculate the number of violations or the penalty for any violations, and whether the CPUC will consider additional communications in the OII, including those identified in a motion filed on December 1, 2015, by the City of San Bruno in the 2015 GT&S r ate case . It is also uncertain whether the CPUC will take additional action in any of the proceedings in which the Utility has self-reported communications that may have violated the CPUC’s ex parte rules. Finally, the U.S. Attorney’s Office in San Fra ncisco and the California Attorney General’s office also have been investigating matters related to allegedly improper communication between the Utility and CPUC personnel. The Utility is cooperating with the federal and state investigators. It is uncert ain whether any charges will be brought against the Utility . CPUC Investigation Regarding Natural Gas Distribution Facilities Record-Keeping On November 20, 2014, the CPUC began an investigation into whether the Utility violated applicable laws pertaini ng to record-keeping practices with respect to maintaining safe operation of its natural gas distribution service and facilities. The order also requires the Utility to show cause why (1) the CPUC should not find that the Utility violated provisions of th e California Public Utilities Code, CPUC general orders or decisions, other rules, or requirements, and/or engaged in unreasonable and/or imprudent practices related to these matters, and (2) the CPUC should not impose penalties, and/or any other forms of relief, if any violations are found. In particular, the order cites the SED’s investigative reports alleging that the Utility violated rules regarding safety record-keeping in connection with six natural gas distribution incidents, including the natural g as explosion that occurred in Carmel, California on March 3, 2014, for which the CPUC has previously imposed a penalty of $10.85 million. On September 30, 2015, the SED submitted its supplemental testimony, which included incidents allegedly related to record-keeping that had not been identified in the initial order, and also asserted violations related to the Utility’s pre-excavation location and marking practices, causal evaluation practices, and compliance with regulations governing pressure validatio n for certain distribution facilities. Evidentiary hearings were held during January 2016. Opening briefs are due by February 26, 2016 and reply briefs are due by March 31, 2016. The SED has indicated it will seek significant penalties, the amount of wh ich is expected to be disclosed in its brief. PG&E Corporation and the Utility believe it is probable that the CPUC will impose penalties on the Utility in the form of fines or other remedies, including possible future unrecoverable costs to implement ope rational remedies. The Utility is unable to determine the form or amount of penalties or reasonably estimate the amount or range of future charges that could be incurred given the CPUC’s wide discretion (discussed above). Natural Gas Transmission Pipeline Rights-of-Way In 2012, the Utility notified the CPUC and the SED that the Utility planned to complete a system-wide survey of its transmission pipelines in an effort to address a self-reported violation whereby the Utility did not properly identify encroachments (such as building structures and vegetation overgrowth) on the Utility’s pipeline rights-of-way. The Utility also submitted a proposed compliance plan that set forth the scope and timing of remedial work to remove identified encroachments o ver a multi-year period and to pay penalties if the proposed milestones were not met. In March 2014, the Utility informed the SED that the survey has been completed and that remediation work, including removal of the encroachments, is expected to continue for several years. The SED has not addressed the Utility’s proposed compliance plan, and it is reasonably possible that the SED will impose fines on the Utility or take other enforcement action in the future based on the Utility’s failure to continuously survey its system and remove encroachments. The Utility is unable to reasonably estimate the amount or range of future charges that could be incurred given the SED’s wide discretion and the number of factors that can be considered in determining penalties . Potential Safety Citations The SED periodically audits utility operating practices and conducts investigations of potential violations of laws and regulations applicable to the safety of the California utilities’ electric and natural gas facilities and operations. In addition, the California utilities are required to inform the SED of self-identified or self-corrected violations. The CPUC has delegated authority to the SED to issue citations and impose fines for violations identified through audits, inv estigations, or self-reports. The SED can consider the discretionary factors discussed above (see “ Order Instituting an Investigation into Compliance with Ex parte Communication Rules” above) in determining the number of violations and whether to impose d aily fines for continuing violations. The SED is required, however, to impose the maximum statutory penalty of $50,000 for each separate violation. The SED has imposed fines on the Utility ranging from $50,000 to $16.8 million for violations of electric and natural gas laws and regulations. The Utility believes it is probable that the SED will impose fines or take other enforcement action based on some of the Utility’s self-reported non-compliance with laws and regulations or based on allegations of non- compliance with such laws and regulations that are contained in some of the SED’s audits. The Utility is unable to reasonably estimate the amount or range of future charges that could be incurred for fines imposed by the SED with respect to these matters g iven the wide discretion the SED has in determining whether to bring enforcement action and the number of factors that can be considered in determining the amount of fines. Federal Matters Federal Criminal Indictment On July 29, 2014, a federal grand ju ry for the Northern District of California returned a 28-count superseding criminal indictment against the Utility in federal district court that superseded the original indictment that was returned on April 1, 2014. The superseding indictment charges 27 felony counts alleging that the Utility knowingly and willfully violated minimum safety standards under the Natural Gas Pipeline Safety Act relating to record-keeping, pipeline integrity management, and identification of pipeline threats. The superseding indictment also includes one felony count charging that the Utility illegally obstructed the NTSB’s investigation into the cause of the San Bruno accident. On December 23, 2015, the court presiding over the federal criminal proceeding dismissed 15 of the Pipeline Safety Act counts, leaving 13 remaining counts. The maximum statutory fine for each felony count is $500,000, for total potential fines of $6.5 million. On December 8, 2015, the court also issued an order granting, in part, the Utility’s request to dismiss the government’s allegations seeking an alternative fine under the Alternative Fines Act. The Alternative Fines Act states, in part: “If any person derives pecuniary gain from the offense, or if the offense results in pecuniary loss to a person other than the defendant, the defendant may be fined not more than the greater of twice the gross gain or twice the gross loss.” The court dismissed the government’s allegations regarding the amount of losses, but concluded that it required additional in formation about how the government would prove its allegations about the amount of gross gains prior to deciding whether to dismiss those allegations. (Based on the superseding indictment’s allegation that the Utility derived gross gains of approximately $281 million, the potential maximum alternative fine would be approximately $562 million.) After considering the additional information submitted by the government, on February 2, 2016, the court issued an order holding that if the government’s allegation s about the Utility’s gross gains are considered, they would be considered in a second trial phase that would take place after the trial on the criminal charges. The trial on the criminal charges currently is scheduled to begin March 22, 2016. The Utilit y entered a plea of not guilty. The Utility believes that criminal charges and the alternative fine allegations are not merited and that it did not knowingly and willfully violate minimum safety standards under the Natural Gas Pipeline Safety Act or obstr uct the NTSB’s investigation, as alleged in the superseding indictment. PG&E Corporation and the Utility have not accrued any charges for criminal fines in their Consolidated Financial Statements as such amounts are not considered to be probable. Other Federal Matters The Utility was informed that the U.S. Attorney’s Office was investigating a natural gas explosion that occurred in Carmel, California on March 3, 2014. The U.S. Attorney’s Office in San Francisco also continues to investigate matters rel ating to the indicte d case discussed above. It is uncertain whether any additional charges will be brought against the Utility. Capital Expenditures Relating to Pipeline Safety Enhancement Plan At December 31, 2015, approximately $ 664 million of PSEP-related capital costs is recorded in property, plant, and equipment on the Consolidated Balance Sheets. The Utility would be required to record charges to the statement of income in future periods to the extent total fore casted PSEP-related capital costs are higher than currently expected. Penalty Decision Related to the CPUC’s Investigative Enforcement Proceedings Related to Natural Gas Transmission On April 9, 2015, the CPUC approved final decisions in the three investigations that had been brought against the Utility relating to (1) the Utility’s safety record-keeping for its natural gas transmission system, (2) the Utility’s operation of its natural gas transmission pipeline system in or near locations of higher population density, and (3) the Utility’s pipeline installation, integrity management, record-keeping and other operational practices, and other events or courses of conduct, that could have led to or contributed to the natural gas explosion that occurred in the City of San Bruno, California on September 9, 2010. A decision was issued in each investigative proceeding to determine the violations that the Utility committed. The CPUC also approved a fourth decision (the “Penalty Decision”) which imposes pen alties on the Utility totaling $1.6 billion c omprised of: (1) a $300 million fine to be paid to the State General Fund, (2) a one-time $400 million bill credit to the Utility’s natural gas customers, (3) $850 million to fund future pipeline safety projects and programs, and (4) remedial measures that the CPUC estimates will cost the Utility at least $50 million. In August 2015, the Utility paid the $300 million fine. At December 31, 2015, the Consolidated Balance Sheets include $400 million in current regu latory liabilities for the one-time bill credit that will be provided to the Utility’s natural gas customers in 2016. On January 14, 2016, the CPUC issued final decisions to close these investigative proceedings. The Penalty Decision requires that at lea st $689 million of the $850 million disallowance be allocated to capital expenditures, and that the Utility be precluded from including these capital costs in rate base. The CPUC will determine which safety projects and programs will be funded by sharehol ders in the Utility’s pending 2015 GT&S rate case. If the $850 million is not exhausted by designated safety-related projects and programs in the 2015 GT&S proceeding, the CPUC will identify additional projects in future proceedings to ensure that the ful l $850 million is spent. The CPUC is expected to issue a final decision in the Utility’s 2015 GT&S rate case in 2016 to identify safety-related projects and programs that will be subject to the disallowance. It is uncertain how much of the Utility’s costs to perform the safety-related projects and programs the CPUC will identify as counting toward the $850 million shareholder-funded obligation. If the Utility’s actual costs exceed costs that the CPUC counts towards the $850 million maximum, the Utility woul d record additional charges if such costs are not otherwise authorized by the CPUC. As a result, the total shareholder-funded obligation could exceed $850 million. For the year ended December 31, 2015, the Utility recorded additional charges in operati ng and maintenance expenses in the Consolidated Statements of Income of $907 million as a result of the Penalty Decision. The cumulative charges at December 31, 2015, and the additional future charges to reach the $1.6 billion total are shown in the follow ing table: Year Cumulative Future Ended Charges Charges December 31, December 31, and Total (in millions) 2015 2015 Costs Amount Fine payable to the state (1) $ 100 $ 300 $ - $ 300 Customer bill credit 400 400 - 400 Charge for disallowed capital (2) 407 407 282 689 Disallowed revenue for pipeline safety expenses (3) - - 161 161 CPUC estimated cost of other remedies (4) - - - 50 Total Penalty Decision fines and remedies $ 907 $ 1,107 $ 473 $ 1,600 (1) In March 2015, the Utility increased its accrual from $200 million at December 31, 2014 to $300 million. (2) The Penalty Decision prohibits the Utility from recovering certain expenses and capital spending associated with pipeline safety-related projects and programs that the CPUC will identify in the final decision to be issued in the Utility’s 2015 GT&S rate c ase. The Utility estimates that approximately $407 million of capital spending (which include less than $1 million for remedy related capital costs) in the year ended December 31, 2015 is probable of disallowance, subject to adjustment based on the final 2 015 GT&S rate case decision. (3) These costs are being expensed as incurred. Future GT&S revenues will be reduced for these unrecovered expenses. (4) In the Penalty Decision, the CPUC estimated that the Utility would incur $50 million to comply with the remedies specified in the Penalty Decision and does not reflect the Utility’s remedy-related costs already incurred nor the Utility’s estimated future remedy-related costs. These costs are being expensed as incurred . Other Legal and Regulatory Contingencies PG&E Corporation and the Utility are subject to various laws and regulations and , in the normal course of business, are named as parties in a number of claims and lawsuits. In addition, penalties may be incurred for failure to comply with federal, state, or local laws and regulations. A provision for a loss contingency is recorded w hen it is both probable that a loss has been incurred and the amount of the loss can be reasonably estimated. PG&E Corporation and the Utility evaluate the range of reasonably estimated losses and record a provision based on the lower end of the range, un less an amount within the range is a better estimate than any other amount. The assessment of whether a loss is probable or reasonably possible, and whether the loss or a range of loss is estimable, often involves a series of complex judgments about futur e events. Loss contingencies are reviewed quarterly and estimates are adjusted to reflect the impact of all known information, such as negotiations, discovery, settlements and payments, rulings, advice of legal counsel, and other information and events pe rtaining to a particular matter. PG&E Corporation’s and the Utility’s policy is to exclude anticipated legal costs from the provision for loss and expense these costs as incurred. Investigation of the Butte Fire In September 2015, a wildfire (known as the “Butte fire”) ignited and spread in Amador and Calaveras Counties in Northern California. The California Department of Forestry and Fire Protection (“Cal Fire”) is investigating the source of the Butte Fire to determine whether a tree contacted a powe r line operated by the Utility and was the cause of the fire. Cal Fire has reported that as a result of the fire there were two deaths and 965 structures, including 571 houses, were damaged or destroyed. Cal Fire’s investigation is expected to conclude in 2016. Approximately 27 complaints have been filed against the Utility and its vegetation management contractors in the Superior Court of California in both the County of Calaveras and the County of San Francisco, involving more than 600 individual plaintiffs and their insurance companies. Plaintiffs and the Utility filed petitions with the California Judicial Council to coordinate these cases. The petitions were assigned to the Calaveras Superior Court for a recommendation to the Judicial Council. On January 21, 2016, the Calaveras Superior Court issued an order recommending to the Judicial Council that the cases be coordinated in the Superior Court of California, Sacramento County, for all purposes including trial. Among other factors, the Court found that coordination requires a court with a significant number of judges and complex litigation support personnel, neither of which are present in Calaveras County. It is estimated that losses related to structures, contents, other personal property, and fire suppression costs associated with the Butte fire, will range from $350 million to $450 million. This range is based on estimates about the number, size, and type of structures damaged or destroyed, assumptions about the contents of such structur es and other personal property damage, and information about the amount of fire suppression costs associated with prior similar fires. The Utility believes that it is reasonably possible that it would be liable for some or all of these and other costs, su ch as costs associated with tree damage, personal injury, business interruption losses, and other damages. The Utility is unable to reasonably estimate these other costs at this time due to the limited information available. The Utility has insuranc e coverage for these types of claims. If the amount of insurance is insufficient to cover the Utility's liability resulting from the Butte fire, or if insurance is otherwise unavailable, PG&E Corporation’s and the Utility’s financial condition or results o f operations could be materially affected. Rehearing of CPUC Decisions Approving Energy Efficiency Incentive Awards On September 17, 2015, the CPUC issued an order granting TURN’s and the ORA’s long-standing applications for rehearing of the CPUC decisio ns that awarded energy efficiency incentive payments to the California investor-owned utilities for the 2006-2008 energy efficiency program cycle. Under the ratemaking mechanism applicable to the 2006-2008 program cycle, the maximum amount of incentives t hat the Utility could have earned (or the maximum amount that the Utility could have been required to reimburse customers) over the 2006-2008 program cycle was $180 million. The Utility was awarded a total of $104 million for the 2006-2008 program cycle. In the re-opened energy efficiency proceeding, the CPUC will evaluate whether incentives awarded to the California investor-owned utilities were just and reasonable, and whether any refunds are due. The parties are required to submit proposals to resolve the issues in the proceeding by March 18, 2016. Comments on the proposals are due on April 8, 2016 and evidentiary hearings, if needed, would be held in July 2016. It is uncertain when the CPUC will issue a decision and whether the Utility will be requi red to refund amounts or incur other obligations related to the 2006-2008 program cycle. PG&E Corporation and the Utility believe it is reasonably possible that the Utility will be required to refund amounts or incur other obligations related to this matt er, but they are unable to reasonably estimate the amount of such refunds or other obligations. Other Contingencies Accruals for other legal and regulatory contingencies (excluding amounts related to the contingencies discussed above under “Enforcement and Litigation Matters” and “Other Legal and Regulatory Contingencies”) totaled $ 63 million at December 31, 2015, and $55 million at December 31, 2014. These amounts are included in other current liabilities in the Consolidated Balance Sheets. The resolution of these matters is not expected to have a material impact on PG&E Corporation’s and the Utility’s financial condition, results of operations, or cash flows. Environmental Remediation Contingencies Given the complexities of the legal and regulatory environment and the inherent uncertainties involved in the early stages of a remediation project, the process for estimating remediation liabilities is subjective and requires significant judgment. The Utility records an environmental remediation liability when the site assessments indicate that remediation is probable and the Utility can reasonably estimate the los s or a range of probable amounts. The Utility records an environmental remediation liability based on the lower end of the range of estimated probable costs, unless an amount within the range is a better estimate than any other amount. Amounts recorded a re not discounted to their present value. The Utility’s environmental remediation liability is primarily included in non-current liabilities on the Consolidated Balance Sheets and is composed of the following: Balance at (in millions) December 31, 2015 December 31, 2014 Topock natural gas compressor station (1) $ 300 $ 291 Hinkley natural gas compressor station (1) 140 158 Former manufactured gas plant sites owned by the Utility or third parties 271 257 Utility-owned generation facilities (other than fossil fuel-fired), other facilities, and third-party disposal sites 164 150 Fossil fuel-fired generation facilities and sites 94 98 Total environmental remediation liability $ 969 $ 954 (1) See “Natural Gas Compressor Station Sites” below. At December 31, 2015 the Utility expected to recover $ 695 million of its environmental remediation liability through various ratemaking mechanisms authorized by the CPUC. One of these mechanisms allows the Utility rate recovery for 90% of its hazardous substance remediation costs for certain approved sites (inc luding the Topock site) without a reasonableness review. The Utility may incur environmental remediation costs that it does not seek to recover in rates, such as the costs associated with the Hinkley site. Natural Gas Compressor Station Sites The Utilit y is legally responsible for remediating groundwater contamination caused by hexavalent chromium used in the past at the Utility’s natural gas compressor stations. One of these stations is located near Hinkley, California and is referred to below as the “ Hinkley site.” Another station is located near Needles, California and is referred to below as the “Topock site.” The Utility is also required to take measures to abate the effects of the contamination on the environment. Hinkley Site The Utility has b een implementing interim remediation measures at the Hinkley site to reduce the mass of the chromium plume and to monitor and control movement of the plume. The Utility’s remediation and abatement efforts at the Hinkley site are subject to the regulatory authority of the Regional Board. On November 4, 2015, the Regional Board adopted a final clean-up and abatement order to contain and remediate the underground plume of hexavalent chromium and the potential environmental impacts. The final order states th at the Utility must continue and improve its remediation efforts; define the boundaries of the chromium plume, and take other action. Additionally, the final order requires setting plume capture requirements, requires establishing a monitoring and reporti ng program, and finalizes deadlines for the Utility to meet interim cleanup targets. The clean-up and abatement order did not have a material impact on the Utility’s consolidated financial statements. The Utility’s environmental remediation liability at December 31, 2015 reflects the Utility’s best estimate of probable future costs associated with its final remediation plan. Future costs will depend on many factors, including the extent of work to be performed to implement the f inal remediation plan and the Utility’s required time frame for remediation. Future changes in cost estimates and the assumptions on which they are based may have a material impact on future financial condition and cash flows. Topock Site The Utility’s remediation and abatement efforts at the Topock site are subject to the regulatory authority of the California Department of Toxic Substances Control and the U.S. Department of the Interior. In November 2015, the Utility submitted its final remediation design to the agencies for approval. The Utility’s design proposes that the Utility construct an in-situ groundwater treatment system to convert hexavalent chromium into a non-toxic and non-soluble form of chromium. The DTSC is conducting an additional environmental review of the proposed design, and the Utility anticipates that the DTSC’s draft environmental impact report will be issued for public comment in July 2016. After the DTSC considers public comments that may be made, the DTSC is expected to issue a final environmental i mpact report in December 2016. After the Utility modifies its design in response to the final report, the Utility plans to seek approval to begin construction of the new in-situ treatment system in early 2017. The Utility’s environmental remediation li ability at December 31, 2015 reflects its best estimate of probable future costs associated with its final remediation plan. Future costs will depend on many factors, including the extent of work to be performed to implement the final groundwater remedy and the Utility’s required time frame for remediation. Future changes in cost estimates and the assumptions on which they are based may have a material impact on future financial condition and cash flows. Reasonably Possible Envi ronmental Contingencies Although the Utility has provided for known environmental obligations that are probable and reasonably estimable, the Utility’s undiscounted future costs could increase to as much as $ 1.9 billion (including amounts related to the Hinkley and Topock sites described above) if the extent of contamination or necessary remediation is greater than anticipated or if the oth er potentially responsible parties are not financially able to contribute to these costs. The Utility may incur actual costs in the future that are materially different than this estimate and such costs could have a material impact on results of operation s during the period in which they are recorded. Nuclear Insurance The Utility is a member of NEIL, which is a mutual insurer owned by utilities with nuclear facilities. NEIL provides insurance coverage for property damages and business interruption los ses incurred by the Utility if a nuclear event were to occur at the Utility’s two nuclear generating units at Diablo Canyon and the retired Humboldt Bay Unit 3. NEIL provides property damage and business interruption coverage of up to $ 3.5 billion per nuclear incident and $ 2.8 billion per non-nuclear incident for Diablo Canyon. Humboldt Bay Unit 3 has up to $131 million of coverage for nuclear and non-nuclear property damages. If NEIL losses in any policy year exceed accumulated funds, the Utility could be subject to a retrospective assessment. If NEIL were to exercise this assessment, as of December 31, 2015, the current maximum aggregate annual retrospective premium obligation for the Utility is approximately $60 million. NEIL also provides coverage for damages caused by acts of terrorism at nuclear power plants. Certain acts of terrorism may be “certified” by the Secretary of the Treasury. If damages are caused by certified acts of terrorism, NEIL can obtain compensation from the federal government and will provide up to its full policy limit of $3.5 billion for each insured loss. In contrast, NEIL would t reat all non-certified terrorist acts occurring within a 12-month period against one or more commercial nuclear power plants insured by NEIL as one event and the owners of the affected plants would share the $3.5 billion policy limit amount. Under the P rice-Anderson Act, public liability claims that arise from nuclear incidents that occur at Diablo Canyon, and that occur during the transportation of material to and from Diablo Canyon are limited to $13.5 billion. The Utility purchased the maximum available public liability insurance of $375 million for Diablo Canyon. The balance of the $13.5 billion of liability protection is provided under a loss-sharing program among uti lities owning nuclear reactors. The Utility may be assessed up to $255 million per nuclear incident under this program, with payments in each year limited to a maximum of $38 million per incident. Both the maximum assessment and the maximum yearly assess ment are adjusted for inflation at least every five years. The next scheduled adjustment is due on or before September 10, 2018. The Price-Anderson Act does not apply to claims that arise f rom nuclear incidents that occur during shipping of nuclear material from the nuclear fuel enricher to a fuel fabricator or that occur at the fuel fabricator’s facility. The Utility has a separate policy that provides coverage for claims arising from some of these incidents up to a maximum of $375 million per incident. In addition, the Utility has $53 million of liability insurance for Humboldt Bay Unit 3 and has a $500 million indemnification from th |