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

• How Activists Decommissioned San Onofre Nukes
• How David Slew a Nuclear Goliath
• Sad Saga of San Onofre Nuclear Is Good News for Renewables

NRC: The Good, The Bad and the Ugly

NRC: The Good, The Bad and the Ugly

... and why it is unsafe To restart San Onofre

A GOOD NRC enforcement example:

Davis-Besse Nuclear Power Station is a nuclear power plant in Oak Harbor, Ohio. On March 5, 2002, maintenance workers discovered that corrosion had eaten a football-sized hole into the reactor vessel head of the Davis-Besse plant. Corrosion had been clogging the plant’s filters for months, requiring repeated filter replacement, but the cause was not investigated until after a worker leaned against a control rod drive mechanism, and it toppled over. Although the corrosion did not lead to an accident, this was considered to be a serious nuclear safety incident. Some observers have criticized the NRC’s Commission work as an example of regulatory capture [See Note 1] and the NRC has been accused of doing an inadequate job by the Union of Concerned Scientists.  The Nuclear Regulatory Commission kept Davis-Besse shut down until March 2004, so that FirstEnergy was able to perform all the necessary maintenance for safe operations. The NRC imposed its largest fine ever—more than $5 million—against FirstEnergy for the actions that led to the corrosion. The company paid an additional $28 million in fines under a settlement with the U.S. Department of Justice. The NRC closely monitored FENOC’s response and concluded in September 2009 that FENOC met the conditions of the 2004 order. From 2004 through 2009 the NRC reviewed 20 independent assessments conducted at the plant and verified the independent assessors’ credentials. The agency also conducted its own inspections and reviewed FENOC’s reactor vessel inspections conducted in early 2005. NRC inspectors paid particular attention to the order’s focus on safety culture and safety conscious work environment to ensure there were no new signs of weakness. The NRC task force concluded that the corrosion, occurred for several reasons:

·    NRC, Davis-Besse and the nuclear industry failed to adequately review, assess, and follow up on relevant operating experience at other nuclear power plants;

·    Davis-Besse failed to ensure that plant safety issues received appropriate attention; and

·    NRC failed to integrate available information in assessing Davis-Besse’s safety performance.

A BAD NRC enforcement example:

At San Onofre by Region IV and the NRC: The papers shown below have been obtained from Public Domain written by Dr. Joram Hopenfeld and a former SONGS Employee based on his investigation of the steam generator issues, review of the plant data and discussions with several Key SONGS Insiders. These papers confirm that Southern California Edison wants to restart unsafe Unit 2 nuclear reactor at 70% power under false pretenses, just for profits, and as an unapproved risky experiment by subverting the NRC and Federal regulatory process.  The true Root Cause (See Note 2) of the unprecedented tube-to-tube wear in Unit 3 has NOT been officially established, as required by NRC Confirmatory Letter Action 1 for restarting the defectively designed and degraded Unit 2.  NRC has not even completed their review of Unit 2 Return to Service Reports, nor have they finished Special Unit 2 Tube Inspections, nor have they (publicly?) reviewed SCE’s Response to NRC’s Requests for Additional Information (RAIs).
NOTE: NO FINES ARE MENTIONED - WHY?

An UGLY NRC enforcement example?:

Now, SCE wants the NRC to approve a new shady License Amendment, undermining public safety and they want it done without the involvement of Public Safety Experts, Attorneys and/or Citizens/Ratepayers.  After the review of the Mitsubishi Root Cause Evaluation and the Draft SCE License Amendment, it is crystal clear that the NRC needs to follow the example of their own enforcement at David Besse together with the lessons learned from Fukushima, when it comes to NOT approving this new Shady License Amendment for restarting San Onofre Unit 2’s defectively designed and degraded replacement steam generators.  In light of the unanticipated/unprecedented tube leakage at San Onofre Unit 3, the health and safety, along with the economic concerns/objections of 8.4 million Southern Californians’ MUST OVERRIDE and PREVENT the restarting of Unit 2 at ANY power level.  In a Democratic Society, truth must prevail over profit motivations, misleading propaganda of electricity service disruption and/or projected probabilistic temporary inconveniences to the public based on phony data, because America cannot afford a trillion dollar nuclear eco-disaster!

Our Safety must override SCE's profits and prevent them from restarting Unit 2.

Notes:

1: Regulatory capture occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or special concerns of interest groups that dominate the industry or sector it is charged with regulating.  Regulatory capture is a form of government failure, as it can act as an encouragement for firms to produce negative externalities. The agencies are called "captured agencies".

2. Human performance errors resulting from the negative safety culture of production (profits) goals overriding public safety obligations.


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Additional Information:

The full DAB Safety Team's Media Alert 5 Parts:

https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=15V8BD4YK0MjwUV6gPZt6ILS_lP7CpClzgnZentLfx8U

The complete five (5) part presentation, see the eight (8) titles listed below:

Part 1, First Part  https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1GcDuO0NvUdBBRVqCinM3Gr9bhmsJDCIbOg65rwdtjBY

Part 1, Second Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1v_UcRLUlwmhtVDbftGcROPkF-cujiGa_-qjUJ7i2WIM

Part 1, Third Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=1yCOQ_diw8Qix1qG3j7MC6F2VfcqMoFOidxjJdIBpba0

Part 1, Fourth Part https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1

Part 2 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?
pli=1&docId=1wkyTGWUy0pIXjBXc91JWr6_ACB3d-AIQbuVVZtDRZvI

Part 3 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=16VmGtq9oYGS2-bpR4nBt9d-YB21E2xrjFpIJoxFJ4s4

Part 4 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFMC1BNlpMeDQyM2M

Part 5 https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=0BweZ3c0aFXcFX2gxRDFCRW9CVzg

San Onofre Unit 2 Retainer Bars Could Cause Massive ☢ Leakage

In an accident like a main steam line break at San Onofre, the badly designed retainers bars in Unit 2 could actually make things much worse by causing more damage to any of the 9,727 already fatigued tubes in each of its steam generators which could lead to additional leakage of highly radioactive reactor core coolant and/or cause a nuclear incident or worse a nuclear accident like Fukushima!

Radioactive Leaks and ruptures can happen without notice:

Allegation/Violations

The NRC has decided in AIT follow-up report dated 11/09/2012, “Item 3. “(Closed) Unresolved Item 05000362/2012007-03, ‘Evaluation of Retainer Bars Vibration during the Original Design of the Replacement Steam Generators” as a non-cited violation in accordance with Section 2.3.2 of the NRC’s Enforcement Policy.”  However, as shown below, SCE/MHI’s failure to verify the adequacy of the retainer bar design as required by SCE/MHI’s procedures have resulted in plugging of several hundred tubes in the brand new replacement generators. This has resulted in these violations:

1. Failure to meet NRC Chairman Standards on Nuclear Safety by SCE,
2. Failure to meet Senator Boxer’s Committee on Environment and Public Works
(EPW) Standards on Nuclear Safety by SCE,
3. Failure to enforce SCE Edison Contract Document instructions to MHI by SCE,
4. Failure to meet SONGS Technical Specifications by SCE,
5. Failure to meet general design criteria (GDC) in Appendix A, “General Design
Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic
Licensing of Production and Utilization Facilities GDC 14, “Reactor
Coolant Pressure Boundary” by SCE/MHI,
6. Failure to demonstrate that Unit 2 retainer bars will maintain tube bundle
geometry at 70% power due to fluid elastic instability during a main line
steam break (MSLB) design basis event, and
7. SCE/MHI took shortcuts by avoiding the 10 CFR 50.90 License Amendment
Process under the false pretense of “like for a like” replacement steam
generator.  SCE added 377 more tubes, increased the average length of the
heated tubes and changed the thermal-hydraulic operation of the RSGs without

proper safety analysis and inadequate 10CFR 50.59 Evaluation.

This intentional action to produce more thermal megawatts out of the

RSGs compromised safety at SONGS Unit 2 due to the failure of 90

percent through wall thickness of a tube by the inadequate design of the

r

etainer bar.

Recommended Actions:

NRC San Onofre Special Panel is requested to resolve the above listed Allegations and/or Violations within 30 days of receipt of this email and prior to granting SCE’s permission to do any restart "testing" of Unit 2. Answer all allegations factually, don't just void them.
 
See Full Document: Media Alert: San Onofre Retainer Bar Problems

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 Reports Incomplete, Inconclusive, Inconsistent and Unacceptable

The REAL CAUSE of San Onofre's Unit 3 massively expensive failure...

It appears that a complacent SCE and the inexperienced Mitsubishi engineers did not perform proper academic research and industry comparisons about the potential adverse consequences of the reducing the pressures in the original steam generators. Lowering the pressures were the primary cause of shortening the life of the Original Generators due to increased tube wear and plugging caused by random vibrations and also caused the destruction of the new Unit 3 Replacement Steam Generators due to the same thing. 

In addition, Edison engineers prepared a defective NRC report and design specifications, which were not challenged by Mitsubishi, the manufacturer, and/or adequately reviewed by NRC Region IV. Mitsubishi then at the direction of SCE engineers made numerous untested and unanalyzed design changes to the steam generators under the pretense of “like for like”, exchange and even NRC Region IV Director Elmo Collins said, “The guts of the machinery look …. Different.”

So based on a review of the AIT Report and some of the World’s Experts, the three potential causes, which were significant contributors to the “fatigue damage” in San Onofre Unit 3 and the tube-to-tube wear resulting in the tube leak are as follows:

A. Insufficient internal supports and differences in manufacturing or fabrication of the tubes and other components between Units 2 & 3.

B. Due to modeling errors, the SONGS replacement generators were not designed with adequate thermal hydraulic margin to preclude the onset of fluid-elastic instability.

C. Differences between Unit 2 and Unit 3’s Operational Factors


CONCLUSIONS: Until the NRC can determine that San Onofre is 100% safe to operate at its approved rated power, granting any Unit 2 Restart testing is unacceptable, because if a nuclear accident occurred during testing who would be held liable, the Nuclear Utilities, the Insurance Carriers, the Federal Government, the State of California, the CPUC, the NRC Commissioners, NRC Region IV, EIX/SCE Shareholders & Employees or just the millions of affected southern Californians?  The DAB Safety Team believes that once the true amount of existing tube fatigue and all other associated damage is KNOWN, anything short of a total steam generator rebuild and/or replacement will be unacceptable prior to any restart being authorized by the NRC.

2013 is the year to Decommission San Onofre

For much more on this read:

Allegation – NRC AIT Report Incomplete, Inconclusive, Inconsistent and Unacceptable