The $742 Million Question:

The $742 Million Question

Who should pay for the extra Decommissioning money, not yet collected?

Since the operators of San Onofre made the financial decision to shut it down prematurely, all decommissioning fees not already collected for Units 2 and 3 by 01/31/12, should be paid by the operators of San Onofre, not ratepayers!


Also the California Public Utilities Commission should required SCE put the Decommissioning of San Onofre out for public bid, instead of just giving the mega billion dollar job to SCE. California ratepayers cannot afford a sole source bid when so many International Companies with nuclear expertise are looking for work.


A public bidding process will save California ratepayers huge amounts of money, money which should not end up in SCE's shareholders pockets. This single project has the potential to jump start our economy, we cannot allow the CPUC to short circuit our states bidding process by not putting this job out for bid!

Decommissioning Costs as of 1/1/2012	SONGS 1     $ Million	SONGS 2 $ Million	SONGS 3 $ Million
Radiological Costs	183.3	1,273.6	1,262.4
Site Restoration	10.7	417.0	535.5
Fuel Storage (Including ISFSI Decommissioning)	11.2	385.3	368.3
Estimated Total Budget 2009 (See Note 2)	N/A	1,791	1,868
Total Collected 10/31/12  (See Note 1)	291.4	1,638.1	1,865.4
Total Projection 1/1/2012	205.2	2,079.5	2,166.2
Estimated Loss Due To Poor RSG Design/Operation	86.2   Previously   Overbilled	441.4           Shortfall	300.8              Shortfall

1. SCE  Letter to NRC (2012) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFNHF2ZDVncy1GM0U
2. SCE Testimony to CPUC (2009) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFYlhqWHVQbEYyVkU

Background

The purpose of the Nuclear Decommissioning Trust Funds is to mitigate for ratepayers the high cost of decommissioning nuclear power plants at the end of their lives by collecting reasonable fees over a long period of time. The CPUC directs the investor owned utilities to collect a regular Decommissioning fee on customers’ monthly electric bills for Edison and SDG&E’s San Onofre Plant (30 years old) and PG&E’s Diablo Canyon Plant (28 years old). The expected life of a nuclear power plant is 40 years.

$5.2 billion of ratepayer collection is currently invested with the Trust Funds.

At current liquidation value, combined Decommissioning Trust Funds are ~90% funded. The Trust Funds are currently invested in equities (60%) and investment grade fixed income securities (40%). D.87-05-062 established nuclear decommissioning trusts for funding future decommissioning of the utilities’ nuclear units. Each nuclear plant has decommissioning trusts and a committee that oversees the trust fund; Under Public Utilities Code § 8326, SCE is required to provide a decommissioning cost estimate that includes, among other things,

an estimate of the costs of decommissioning, and

a description of changes in regulation, technology, and economics affecting the estimate of costs.

As SCE explains, and as TURN’s witness Lacy acknowledges, the costs to decommission a nuclear facility include the costs to

store the spent fuel onsite or offsite until it is removed by the DOE;

remove residual radioactivity from the site, including from the spent fuel storage facility, to levels required to terminate the NRC license and to release the site for unrestricted use; and

remove non-radiological structures, systems, and components as required to leave the site in a safe condition, or as otherwise mandated by the state or the site owner.

The Utilities project that they will perform the actual decommissioning in three phases.

During Phase I, the Utilities will decontaminate, dismantle, and dispose of the units and the site common facilities. The Utilities will also continue to maintain the integrity and safety of the spent fuel while it remains on the SONGS site. The Utilities will maintain spent fuel in wet storage in spent fuel pools until it can be safely transferred to the SONGS 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) or removed from the site by the U.S. Department of Energy (DOE). To safely store fuel in wet storage, the Utilities must maintain each plant system required for spent fuel pool operation until the fuel is removed. The Utilities will drain, de-energize, and secure all other plant systems. After the SONGS 2 & 3 spent fuel pools are empty, the Utilities will decommission the pools and their associated support structures and systems. The Utilities assume that by the time the SONGS 2 & 3 fuel has cooled sufficiently to be removed from the spent fuel pools, the DOE will have removed enough SONGS 2 & 3 fuel from the SONGS site that it will not be necessary to further expand the ISFSI pads or to construct additional Advanced Horizontal Storage Modules (ASHM) to accommodate that fuel.

During Phase II, the Utilities will monitor the ISFSI until the DOE removes the last spent fuel from the site, which is assumed to occur by 2051 based on studies developed from the DOE Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567), dated July 2004.

During Phase III, the Utilities will dismantle and dispose of the ISFSI, all remaining site common facilities, and the remaining structural foundations; terminate the NRC licenses; and complete the final site restoration work.

Note: The Utilities do not own the site upon which the SONGS facility is located. Instead, they are authorized to use the site under several lease contracts and grants of easement from the U.S. Department of the Navy and the California State Lands Commission. To terminate these agreements, the Utilities are required to remove all improvements they installed or constructed on the site, except as agreed by the lessors/grantors, return the site to a condition satisfactory to the grantor, and return the site to the lessors/grantors.

Related articles

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San Onofre Legacy (SOL Part 1, 2 and 3)

The DAB Safety Team released three Media Alerts today!

Together they describe (in technical detail) the current situation at San Onofre, along with what SCE, their experts and other public nuclear watchdogs are now saying about all the NRC RESTART QUESTIONS they have been told to answer:

1. SONGS Unit 2 Fluid Elastic Instability, Thermal-Hydraulic Modeling, Enlightening Dr. Pettigrew, Concerned/Frustrated NRC Commissioners and Main Steam Break (28 Pages)

snip:

The following paper shows that the entire NRC Regulatory Process is underfunded, broken and needs additional funding, oversight and extensive overhaul to ensure public safety.

2. SCE’s Dismal and Unconvincing Performance before NRC Commissioners (13 Pages)

snip:

The presentation by SCE, Mitsubishi and other experts to the NRC was very disappointing and disturbing to 8.4 million Southern Californians.  The presentation did not address U.S. Sen. Barbara Boxer and Congressman Edward J. Markey’s concerns expressed on February 6, 2013 in her letter to NRC Chairman McFarlane, “Southern California Edison was aware of problems with replacement steam generators at its San Onofre nuclear power plant but chose not to make fixes.

3. Unit 2 Retainer Bars Integrity Unproven and Unsafe During a MSLB  (12 Pages)

snip:

The structural integrity of SONGS degraded retainer bar system to withstand combined loads that result from postulated accident conditions events has not been demonstrated.

NRC Violating Presidential Directive and the Public Trust

SCE’s PR Machine Is Capable Of Overcoming ALL Hurdles,

Except Good Science And Safety

Albert Einstein also described INSANITY as

Doing the same thing over and over again and expecting different results. 

The DAB Safety Team has challenged previously in their published DAB Safety Team Documents, that Southern California Edison’s controversial plan to restart San Onofre Unit 2 as a “Bogus and dangerous SCE experiment.”  

According to SONGS Anonymous Insiders, SCE’s Engineers were under the false impression that Unit 3 Anti-vibration Structure was built better than Unit 2.  Therefore, SCE Engineers were operating Unit 3 at lower steam pressures than Unit 2 in a test mode to generate more thermal megawatts and thereby generate more electricity.

 To add to Arnie Gundersen’s and John Large’s Technical Affidavits, DAB Safety Team’s investigation reveals that in the process of this “money-hungry experiment”, lower steam pressures in combination with other unapproved and unanalyzed design changes destroyed Unit 3 due to Fluid Elasticity Instability (FEI). SCE and NRC AIT Team both blamed Unit 3 FEI on botched up MHI Computer Modeling and insufficient tube-to-AVB gaps. AREVA, Westinghouse, John Large and the DAB Safety Team findings dispute these statements. The NRC Augmented Inspection Team and the NRR Panel have swept the DAB Safety Team Findings consistently under the rug, in what must be now labeled as a Gov’t cover-up!

The NRC keeps issuing both controversial and conflicting press statements that a decision to allow the restart of Unit 2 could come as early as March 2013.  According to SONGS anonymous insiders, Edison officials have announced in internal SONGS Staff Meetings that a restart decision is imminent in March despite the huge public outcry about safety problems by SCE.  Press reports as of January 14, 2013 state, “Small steps are being taken to prepare for possibly restarting the troubled San Onofre nuclear power plant, even as its future remains clouded with uncertainty, officials said Monday. Nuclear Regulatory Commission senior inspector Greg Warnick said Monday that the agency is beginning to prepare a detailed plan of what would need to be done to bring the plant safely back to service.” (SOURCE: CBS Los Angeles, Associated Press)

NRC’s enforcement history, drama and pre-rehearsed tough questions, press reports, casual relationship and/or protection of SCE officials and utility biased public meetings are just old and cheap regulatory tricks that are now being used to protect the NRC’s own public image and to fool the public into believing that the NRC is really concerned about public safety regarding SCE’s Restart Plan.  The Justice Department & NRR Officials need to set up a legal/technical taskforce to publically question Edison’s design and MHI Engineer’s listed below under oath regarding their:

1. Understanding of their legal obligations under the 10 CFR 50.59 Process,
2. Understanding of problems with the original steam generators,
3. Critical questioning and professional/investigative skills,
4. Efforts made in industry and academic benchmarking to identify and resolve problems with the original steam generators
5. What part did they play in the preparation of design specifications, fabrication, computer modeling, mock-up testing, anti-vibration bar structure, and research required to prevent the adverse effects of fluid elasticity and flow-induced random vibrations in these unique San Onofre Combustion Engineering replacement generators.

Any NRC decision to grant a restart of Unit 2 without a formal 50.90 licensing review along with public participation will be seen as an invitation to risk a Fukushima-type disaster happening in Southern California. 

Read More:  Allegation - NRC Violating President’s Directive And the Public Trust is posted on the web at this link: DAB Safety Team Documents.

Copyright January 17, 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team’s Attorney

SCE Violated Federal Reg.’s And the Public Trust

Nuclear Experts Agree, San Onofre’s Replacement Steam Generators Are Unsafe

Summation: Based upon our ongoing review of evaluations, engineering analyses, inspections, technical and operational assessment reports prepared by the NRC’s Augmented Inspection Team, MHI, SCE, Westinghouse, AREVA, Professor Daniel Hirsch, industry experts and knowledgeable whistle blowers, along with the recent affidavits prepared by Arnie Gundersen and John Large, we reaffirm the following statements which have been previously substantiated in numerous DAB Safety Team Documents:

1. The DAB Safety Team has been saying for months for a long time that SCE and MHI Engineers did a very poor job in their review of Academic Research Papers and Industry Comparisons about how to prevent the adverse effects of fluid elastic instability in the design of San Onofre's replacement steam generators because the original Combustion Engineering designed steam generators did not experience the adverse effects of fluid elastic instability. Nuclear Expert, John Large statesA, “I have little confidence in the outcome of AREVA’s projection of the time period through which the U2 nuclear plant could be reliably expected to operate without incurring a tube failure or running at a greater risk of a tube failure occurring. ... In my opinion, simply sweeping the fluid elastic instability issue under the carpet on the basis ... it will not reoccur at 70% power is not only disingenuous but foolhardy.” TheNRC chairman has publicly stated, “SCE is responsible for the work of its vendor and its contractor.” DAB Safety Team alleges that SCE actions are in violation of the Federal Regulations, its CPUC Charter, the NRC Chairman Standards and even its own advertised charter of “Overriding Obligations to Shareholders and Public Safety.”


2. Accidents involving steam generator depressurization (main steam line break), station blackout and other anticipated transient events causing steam generators over-pressurization can occur at any time over the full range of normal operating conditions up to Reactor Thermal Power (3438 MWs). Therefore BY DESIGN, these replacement steam generators are NOT capable of protecting their already worn and cracked tubes from radioactive leakages and/or ruptures caused by the above.

3. In Unit 2, these already fatigued, cracked, and heavily degraded tubes can snap, leak and/or rupture at the tube sheet, tube support plate or the unsupported anti-vibration bars mid and free spans during these postulated adverse accident conditions. John Large statesA, “For the MSLB event very high, two-phase fluid cross-flow velocities would be expected to instantaneously develop in the U-bend region, triggering vigorous FEI that could, particularly if the AVB restraints are ineffective, promote violent tube to tube clashing and the potential for a multiple tube failure event.”

4. It is ABSOLUTELY CLEAR, that San Onofre Unit 2 replacement steam generators will likely experience single to multiple tube-to-tube failures (e.g., San Onofre Unit 3, Mihama Unit 2, North Anna, Indian Point 2 and Craus, France, etc.) during these postulated adverse licensed conditions at any power level up to 100% Power (Licensed Reactor Thermal Power of 3438 MWTs).


5. The proposed Defense-in-Depth instrumentation, along with unreliable and unproven operator actions to detect multiple tube leaks/ruptures and/or to re-pressurize the steam generators during these postulated adverse licensed conditions as claimed by Edison are not practical to stop a major nuclear accident from progressing and causing a Unit 2 meltdown.

6. There are conflicting, contradicting, ambiguous and confusing findings between the experts in the Unit 2 Operational Assessments: Such conflicting disagreements over the cause of Tube To Tube Wear reflects poorly on the depth of understanding of this crucially important FEI issue by SCE, each of these SCE consultants and the designer/manufacturer of the Replacement steam generators. The DAB Safety Team’s findings contradict the SCE and all the three NEI qualified, “US Nuclear Plant Designers” findings about Unit 2 FEI (See, Overview – Consequences of a Main Steam Line Break).

7. The DAB Safety Team Comments about SCE 10 CFR 50.59 Safety Evaluation for RSGs: The Big Number 1 Attachment Notes shows the comparison between San Onofre and Palo Verde's Replacement Steam Generator design parameters. Palo Verde has the largest CE RSGs in the world (~ 800 Tons each) and SONGS Replacement Steam Generators are the second largest CE Replacement Steam Generators in the world (~ 620 Tons each). John Large statesA, “In my opinion, the changes, tests and experiments (CTE) inherent in the SCE proposal to restart Unit 2: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; (b) create the possibility of a new or different kind of accident previously evaluated; and (c) involve a significant reduction in a margin of safety. Arnie Gundersen statesB, “It is my professional opinion that Edison should have applied for the 50.59 process so that the FSAR license amendment evaluation and public hearings would have occurred six years ago, prior to creating an accident scenario and facing losses that by the end of this process will easily total more than $1 Billion.” Therefore, the DAB Safety Team concludes that SCE claims as stated are not factual. SCE did not meet the 10CFR50, Appendix B, Quality assurance Standards and has violated the NRC 10 CFR 50.90 Regulations.

8. The Public expects that the Offices of Nuclear Reactor Regulation (NRR) comply with President Barack Obama, Senator Barbara Boxer and NRC Chairman’s Open Government Initiative. Under no circumstances should the NRR permit SCE to restart unit 2 without replacing the defective replacement steam generators, a full NRC 50.90 Licensing Amendment and transparent trial-like public hearings.
A http://libcloud.s3.amazonaws.com/93/80/a/2680/R3218-Large-AF2-redacted_proprietary.pdf
B http://libcloud.s3.amazonaws.com/93/b5/f/2677/2013_1_11_FOE_Gundersen_Affidavit_reEdisonSanOnofreRSG.pdf

Full Media Alert 13-01-15 Allegation - SCE Violated Federal Reg's And The Public Trust is posted on the web at this link: DAB SafetyTeam Documents.

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The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous. These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports. We continue to work together as a Safety Team to prepare additional: DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings. For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Copyright January 14, 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team’s Attorney

TEN Unresolved Items, Requires NRR Investigate The NRC

The Unsatisfactory Status Of The NRC Region IV Augmented Inspection Team Report Which Contains TEN Unresolved Items, Requires Additional NRR Investigation And Resolution.

The DAB Safety Team has transmitted the following to the Chairman of the NRC, Offices of Nuclear Regulator Regulations (NRR), Atomic Safety Licensing Board and NRC AIT Chief.

The NRC AIT Report (ADAMS Accession Number ML2012007) identified ten unresolved items in July 2012 that warranted additional follow-up:

1. Adequacy of the post trip/transient procedure;
2. Evaluation and disposition of the Unit 3 loose parts monitor alarms; 
3. Design of retainer bar;
4. Control of original design dimensions;
5. Evaluation of and controls for divider plate repair;
6. Atmospheric controls of Unit 3 steam generators during shipment;
7. No tube bundle support used during shipping;
8. Evaluation and disposition of accelerometer readings during shipping;
9. Adequacy of Mitsubishi’s thermal-hydraulic model;
10. Change of methodologies associated with 10 CFR 50.59 review.

Consistent with existing NRC inspection processes, these unresolved issues will be inspected and dispositioned during follow-up inspection efforts to determine if there are any violations of regulatory requirements.

DAB SAFETY Team Comments. re: NRC AIT Report : It has been almost six months since the issuance of the original report and since that time the NRC AIT Team has completed several follow-up inspections at SONGS.  However, the NRC AIT Team has not publically updated its report on the results of follow-up inspections to resolve the above items and determination of violations of regulatory requirements by SCE. These concerns were expressed to the NRC Region IV Staff and AIT Team at the November 30, 2012 Public Meeting.  Several Environmental, Public and even Pro-Nuclear Groups have repeatedly and publicly stated to the NRC, Atomic Licensing Board and Office of Nuclear Reactor Regulations (NRR): “When it comes to SCE’s mistakes and public policy, NRC Region IV is asleep at the wheel.”  The NRC Chairman has stressed the need for “Independent Regulators” during her recent Fukushima trip. Therefore, these items should be added to the NRR list for resolution.  Especially, items (2), (3), (9) and (10) should be resolved as soon as possible.  In addition, the NRR should made public SCE’s FSAR analysis showing the effect of a Main Steam Line Break for Unit 2 operation up to Reactor Thermal Power on Steam Generator Tube Ruptures (for one (1), four (4), eight (8) or an ever increasing number (a cascade aka Hopenfeld Effect) of tube rupture/failures) in accordance with President Barack Obama, Senator Barbara Boxer and the NRC Chairman’s Open Government Initiative, as these documents directly affect public safety, they must no longer be considered SCE’s “privileged documents” after their SONGS Replacement Generators $680 Million Debacle.

Please see the DAB Safety Team’s Press Release + 12-12-28 Thirty Alarms Demonstrates SONGS Unsafe for details item (2).

This press release will be posted on the web at this link: DAB Safety Team Documents.

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The DAB Safety Team: Don, Ace and a BATTERY of safety-conscious San Onofre insiders plus industry experts from around the world who wish to remain anonymous.  These volunteers assist the DAB Safety Team by sharing knowledge, opinions and insight but are not responsible for the contents of the DAB Safety Team's reports.  We continue to work together as a Safety Team to prepare additional : DAB Safety Team Documents, which explain in detail why a SONGS restart is unsafe at any power level without a Full/Thorough/Transparent NRC 50.90 License Amendment and Evidentiary Public Hearings.  For more information from The DAB Safety Team, please visit the link above.

Our Mission: To prevent a Trillion Dollar Eco-Disaster like Fukushima, from happening in the USA.

Press Release

The DAB Safety Team: January 10, 2013

Media Contact: Don Leichtling (619) 296-9928 or Ace Hoffman (760) 720-7261 

Copyright January 2, 2013 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and/or the DAB Safety Team’s Attorney

SCE's News Years Resolution 2013: Decommission SONGS ASAP

NRR RAI Answers Will Prevent Any SCE Restart At San Onofre

The NRC Office of Nuclear Reactor Regulation has requested from Edison in a letter dated December 26, 2012, the following additional information (RAI #32): “Please clarify how the information submitted by SCE demonstrates: NRRRAI#32(1) that the structural integrity performance criterion in TS 5.5.2.11.b.1 is met for operation within current licensed limits up to the licensed Rated Thermal Power (RTP or 100% Power), or NRRRAI#32(2) provide an operational assessment that includes an evaluation of steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP.”

The DAB Safety Team’s Response: 

Answer to NRRRAI#32(1): As shown in the linked Response to NRR RAI#32  - Technical, by operating the “Defectively Designed and Degraded” Unit 2 Replacement Steam Generators (RSGs), SCE CANNOT DEMONSTRATE [with all the World’s Expert’s Assistance - emphasis added] that ALL in-service RSGs tubes would retain structural integrity over the full range of normal operating conditions (including startup, operation in the power range, hot standby, cool down and all anticipated transients included in the design specification) and design basis accidents in accordance with SONGS Unit 2 Technical Specifications structural integrity performance criterion in TS 5.5.2.11.b.1.

Answer to NRRRAI#32(2): As shown in the linked Response to NRR RAI#32  - Technical, SCE CANNOT PROVIDE AN ACCEPTABLE OPERATIONAL  ASSESSMENT  TO  THE  NRR, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, “Reactor Coolant Pressure Boundary—shall have “an extremely low probability of abnormal leakage…and gross rupture.” 

Southern California’s future is now in the hands of the NRR: As shown in this section, the SONGS RSG’s U-Tube bundle and Anti-vibration Bar Structures are not designed like Palo Verde RSGs to handle high steam flows, high velocities and to prevent the formation of highly localized steam dry-outs and TTW (FEI) for operation up to the RTP.  The “defectively designed and degraded” Unit 2 RSGs, if operated, will suffer additional radioactive tube leaks like SONGS Unit 3, Mihama Unit 2, North Ana, Indian Point 2 and Craus.  Therefore, SCE  CANNOT  PROVIDE AN  ACCEPTABLE  OPERATIONAL  ASSESSMENT  TO  THE  NRR, which demonstrates that steam generator Tube-to-Tube Wear (TTW) for operation up to the RTP would not cause a tube leak in order to comply with the  Code of Federal Regulations, 10 CFR Part 50 Appendix A, General Design Criteria 14, “Reactor Coolant Pressure Boundary—shall have “an extremely low probability of abnormal leakage…and gross rupture.” 

...

The DAB Safety Team’s CONCLUSIONS

1. Based on an in-depth review of the above listed documentation and direct observation of Plant Operators and SONGS Emergency Response Organization Performance, the DAB Safety Team agrees with Dr. Johan Hopenfeld’s published concerns and concludes that Operator Action is not feasible to stop a major nuclear accident in Unit 2 in the first 15 minutes of a MSLB, stuck open SG safety valve, Earthquake, cascading SG tube ruptures and or any other combination of Un-anticipated operational transients, during the proposed 5-month trial period of the already heavily damaged Unit 2 RSG’s at any power setting.

2. The Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation must now formally address Dr. Johan Hopenfeld’s published concerns, as mentioned in Response to NRR RAI#32  - Technical  in light of the eight RSG tube failures at SONGS at main steam line break testing conditions, and the cascading effect that these failures prove is a very serious safety issue, that reactor operators do not currently have the ability to control. which might result in significant risk impacts such as a nuclear meltdown.

Full Press Release + 12-12-31 NRR RAI #32 Request

Copyright December 31, 2012 by The DAB Safety Team. All rights reserved. This material may not be published, broadcast or redistributed without crediting the DAB Safety Team. The contents cannot be altered without the Written Permission of the DAB Safety Team Leader and or the DAB Safety Team’s Attorneys.