California Dreaming The Bailout of C al i fo r n i a's Nuclear Industry

California Dreaming

The Bailout of C al i fo r n i a’s

Nuclear Industry

Jim Riccio Auke Piersma

Critical Mass Energy Project October I998

California Dreaming

The Bailout of California’s

Nuclear Industry

Jim RiccIo Auke Piersrna

Critical Mass Energy Project October I998

© 1998 by Public Citizen. All rights reserved. N o part of this document may be reproduced or utilized in any form or by any means electronic or mechanical, including photography, recording. or by information storage and retrieval system, without written permission from the authors.

Public Citizen is a nonprofit membership organization in Washington, D.C., dedicated to advancing consumer rights through lobbying, litigation, research, publications, and information services. Since its founding by Ralph Nader in 1971, Public Citizen has fought for consumer rights in the marketplace, for safe and secure health care, for fair trade, for clean and safe energy sources, and for corporate and government accountability.

For additional copies of this report, for copies of any of the reports lisied below, or for a complete list of Public Citizen publications, contact Member Services at the address below or call (202) 288-1000.

Public Citizen 1600 20th Street N.W.

Washington, D.C. 20909- 1001

Other titles by Critical Mass Energy Project

Nuclear Lemons (1996) Power for the People (1996)

Civilian High-Level Radioactive Waste (1997) Consumers and Businesses: Now and Future Victims of Greedy Energy Utilities (1997)

A Federal Agenda for Electric-Industry Restructuring (1997) The Real Costs of On-Site Storage of Highly Irradiated Nuclear Fuel (1997)

Questioning the Authority (1998)

TABLE OF CONTENTS Introduction

PART 1: Don’t You Let That Deal Go Down!

1

2

The Bailout of California’s Reactors 4

Curtailed Support for Renewable Energy & Energy Efficiency 10

PART 2: California’s Nuclear Power Plants: Getting It Backward From the Start 13

Diablo Canyon Cost Overruns: It’s Not Just Hosgri’s Fault 14

San Onofre Gets It Backwards 15

PART 3: Performance of California’s Nuclear Reactors 16

Scrams 17

Safety System Actuations 21

Safety System Failures 23

Significant Events 30

Enforcement Discretion 32

Capacity Factors 34

Blowing the Whistle At Diablo Canyon And San Onofre 35

The Nexus Between Economics and Safety 36

PART 4: Findings and Conclusions 37

Endnotes 39

INTRODUCTION

Assembly bill 1890 passed the California legislature unanimously in August of 1996. The bill, which received the blessing of some environmental groups, essentially provides a bailout of every nuclear reactor in the state of California. Nuclear utility executives some how got the idea that California consumers should bail out their bad investments in nuclear power. They must be California Dreaming!

On Election Day, California voters will have an opportunity to overturn this unprecedented corporate giveaway. Proposition 9, the Utility Rate Reduction and Reform Act, would overturn those provisions of AB 1890 that obligate the California consumer to pay for bad utility investments in non-competitive nuclear reactors. This represents roughly half of the $28 billion dollar bailout foisted upon California consumers by AB 1890.

1

Despite the nuclear industry’s attempts to “greenwash” this bailout, paying off and then subsidizing the operation of the state’s remaining nuclear reactors makes no sense for California’s consumers. TURN; The Utility Reform Network, which had originally joined with NRDC and EDF in supporting AB 1890, is now a major proponent of Proposition 9. According to TURN’S executive director, Nettie Hoge, “We realized we had no market, no real rate reduction, and the utilities were making money hand over fist.” Hoge told the National Journal that, “then Pacific Gas & Electric came to the regulators with a $700 million rate increase request for electric base rates. We decided this is a really bad deal for consumers.”

“California screwed it up, there’s no question about that,” said Michael J, Travieso, director of Maryland’s Office of the People’s Council, which represents Maryland’s ratepayers. “What it says to me is, you can make a big mistake if you do it the wrong way and you won’t have competition,” Travieso told the Washington Times.6

According to the Washington Times, the best indication that the process hasn’t worked is reflected in the number of consumers that have actually switched companies to take advantage of the “competition.” The Washington Times reports that “in a state with 9.9 million electricity consumers, only about 66,000 or less than 1 percent, have switched their business away from the three dominant utilities.”’

3

THE BAILOUT OF CALIFORNIA’S REACTORS

Nuclear Operating Subsidy Total Nuclear Stranded Costs

The $28 billion bailout of the investor-owned utilities in California is a complex scheme seemingly designed to provide maximum benefit to the utilities and maximum confusion for their consumers. The utilities nabbed their bailout in a number ways that in the end, added up to a terrible deal for consumers. The bailout sets the stage for a handful of incumbent utilities and their subsidiaries to dominate the electricity market, preventing competition and adversely affecting environmental quality through bad investment decisions at home and abroad. The bailout provides the incumbent utilities with a mountain of cash that they can use to fund mergers, acquisitions and new power projects. As San Diego Gas & Electric president Don Felsinger acknowledged, “We are going to have a lot of free cash from stranded-asset recovery.. .in the billion dollar range.”’ Public Citizen will reveal the extent of the bailout and its impact on the average consumer’s electric utility bill.

$2.2 billion $14 billion

Big Cash for Bad Reactors

The utilities seized the $28 billion bailout under the guise of stranded cost recovery. Stranded costs are those utility investments approved for recovery under the traditional regulatory scheme that are no longer recoverable at competitive market prices due to the transition to a restructured electricity market.’ Approximately 50% of the bailout, or $14 billion, is attributed to the nuclear power plants owned by the California utilities. The other $14 billion covers a broad range of concerns, including power purchase agreements, qualifying facilities contracts, and worker transition costs. 10

THE BAILOUT

Nuclear Sunk Costs I $1 1.7 billion

I Other Stranded Costs 1 $14 billion I I $28 billion

Sources:

Sunk Costs as Stranded Costs: Beginning of the Bailout

The sunk costs of nuclear power plants are the largest portion of the nuclear related stranded costs. For nuclear power, sunk costs reflect the enormous construction costs that were funded with utility debt. The total sunk costs for California, established by California Public Utilities Commission settlements, are placed at $7.3 billion. However,

4

to ensure full recovery, consumers will forfeit a total of $1 1.7 billion to the utilities. The 60% increase pays off the taxes owed on the $7.3 billion windfall.”

Reactor

SUNK COSTS: THE BEGINNING I Initial Total Revenue Stranded Cost Requirement (at 60%) (d)

Diablo Canyon (a)

San Onofre (b)

Palo Verde (c)

$3.3 billion $5.3 billion



Total $7.3 billion $11.7 billion I Sources: a: CPUC Decision N. 97-05-088 b: CPUC Decision N. 96-01-01 I and 96-04-059 c: CPUC Decision 96- 12-083 d: Bob Kinosian Office of Ratepayer Advocates. CPUC.

Securitization: Maximizing Potential Profits

AB 1890 provides for the securitization of utility debt to manufacture the 10% rate reduction. (Please note that this 10% rate reduction is not equivalent to a 10% total energy bill reduction.) This mechanism allows the utilities to refinance a portion of their debt. Under securitization the utility’s stranded costs will be partially paid off by the issuance of bonds. To receive better interest rates on the bonds, temporary property transfers back the bonds as a form of collateral. The better interest rates reflect the savings derived from refinancing the debt and provide the rate reduction.

However, the benefits of securitization are worth considerably more to the utilities than to the consumer. The utilities have received nearly $7.3 billion in cash. (Please note that the equivalent $7.3 billion totals for nuclear stranded.costs and securitization handouts are a coincidence.) This influx of cash provides previously unavailable capital to the utilities with no strings attached. This new found capital is typically being invested in projects that are environmentally suspect. Any profits from these projects will not be used mitigate the size of the bailout. Finally, California consumers have to pay off the principle and interest on these securitized bonds for the next ten years through a charge on their bill called the “Trust Transfer Amount” (see below).

5

Pacific Gas Southern California San Diego & Electric Edison Gas & Electric

$3.5 billion $3.0 billion $0.8 billion

Operating Subsidies: Ensuring the Dangers of Nuclear Power Will Continue

Total

$7.3 billion

The passage of AB 1890 includes guarantees for both the Diablo Canyon and San Onofre nuclear power plants. These guarantees assure that each nuclear power plant can sell its electricity into the power pool at a designated price. These guarantees, in effect through 2001 for Diablo Canyon and 2003 for San Onofre, are a direct operating subsidy. By comparing these guaranteed prices to those received for other sources for electricity (2.5 cents/kwh), Public Citizen calculates that Diablo Canyon and San Onofre will receive almost $2.2 billion in operating subsidies.

6

THE OPERATING SUBSIDIES FOR CALIFORNIA REACTORS

1997 Generation (MWh) Unit 1 Unit 2 Total

Year Guaranteed Price PX Price Subsidy Total Subsidy (cents/kW h) (cents/kWh) (cents/kWh)

Total I

At the Consumer Level

$l,451,238,120

It is imperative that consumers understand just how much they are being asked to contribute to the nuclear power plants owned by California utilities. The $28 billion dollar bailout outlined above, half of which rcpresents bad utility investments in nuclear power plants, is so colossal that it is difficult for anyone paying their electricity bill to understand what they receive in return.

7

The Consumer’s Bill: Understanding How Bad It Really Is

Public Citizen uses a typical California electric bill to demonstrate the impact on the individual consumer. Shown below is the sample bill from the California Energy Commission (CEC) website.’*

Using this average residential consumer bill as a guide, Public Citizen will decipher the terminology of the California electricity bill. The Total CTC Charges (line 4) is the cost to the consumer for the $28 billion bailout, here set at $17.62.13 This will be

8

charged for approximately the first four years of deregulation. As previously noted, half of this charge will pay off the nuclear power debt of the California utilities.

The Trust Transfer Amount (line 10) is the cost of the securitization, here set at $1 1.97. Customers will be charged the trust transfer amount for the next ten years to pay off the principle and interest of the $7.3 billion of securitized bonds that were issued to provide for the purported 10% rate cut. Note that the trust transfer amount charge of $1 1.97 is larger than the “10% reduction’’ of $9.22 (line 1).

The Nuclear Portion of the Average Consumer’s Electricity Bill

In the table below, the direct consumer contribution to the nuclear bailout is revealed. The CEC’s average consumer electric bill shows a total charge of $92.21 for 739kWh of electricity. From this $92.21 total, the cost of California’s nuclear power is computed. The actual market value of nuclear generated electricity is calculated for each utility. Next, the subsidies given to the nuclear power plants are calculated. Finally, adding the market price of the nuclear electricity to the subsidies provides the total cost that the average consumer pays for nuclear power. The last row concludes that at least 20% of the customer’s bill goes to subsidize the California nuclear power plants. In comparison, nuclear power accounts for only 14.7 % of the power generated in California. 14

9

CURTAILED SUPPORT FOR RENEWABLE ENERGY AND ENERGY EFFICIENCY

Program Description

New In-state Renewables Production incentive of up to 1 .5$/kWh

Consumer rebates for purchase of Emerging In-state Renewables renewable energy system

Renewable energy and energy efficiency are unquestionably the best means to reduce the environmental destruction from energy consumption. Unfortunately, support for both renewable energy and energy efficiency has suffered considerably under AB 1890.

Funding Available

$162 million

$54 million

Renewable Energy Hacked

Customer credits up to !.5$/kWh for the purchase of renewable power

The “deal” that was struck for passage of AB 1890 was contingent upon support of renewable energy and other public benefits. Unfortunately, in a comparison of the subsidies, it is clear that the amount of nuclear subsidies dwarfs the amount secured for renewable energy. The result is a policy that encourages expensive and dangerous nuclear power over more affordable, sustainable technologies that would guide us toward a sustainable energy future.

I I $75.6 million

AB 1890 created a public benefits fund that draws in almost $2 billion in 4 years. This fund will provide for low income, research and development, energy efficiency and renewable energy programs. Out of this fund, $540 million will benefit renewable energy technologies. This only amounts to 0.7% of the consumers total electric bill?

Total $540 million

Existing In-state Renewables

Price supports that average from 0.13$/kWh to 0.73ekWh

$243 million

Customer Credits

Customer Education Educational campaign for customer- driven market of renewables

$5.4 million I I

Energy Efficiency Diminished

Pacific Gas & Electric

Southern California Edison

The energy efficiency provisions of AB 1890 are a step in the wrong direction. After bailing out bad utility investments in nuclear power and then providing a subsidy for the continued operation of these nuclear reactors, the support in AB 1890 for energy efficiency has been cut back to half the level budgeted in 1994.16 Even these reduced levels of funding are eliminated after four years.

$185,000,000 $81,123,000 $103,877,000

$13 1,361,000 $53,574,000 $77,787,000

Reductions in energy efficiency funding are bad for the environment and costly to consumers. A report compiled by the Environmental Working Group and the World Wildlife Fund found that “Between 1993 and 1997, U.S. utilities cut their combined investments in energy saving programs by 45 percent, or $736 million, largely in response to industry deregulation.”’~ PG&E, Southern California Edison and San Diego Gas and Electric have all cut their spending on energy efficiency.

UTILITY PROJECTED ACTUAL (MWh) I (MWh)

Pacific Gas 8z Electric 94 1,000 412,593 Southern California Edison 1,170,000 477,028 San Diego Gas & Electric NA NA

i REDUCTIONS IN ENERGY EFFICIENCY SPENDING FOR 1997

COST to CONSUMER $52,000,000 $7 0,000,000 NA

UTILITY I PROJECTED I ACTUAL I DIFFERENCE

I San Diego Gas & Electric I $43,537,000 I $24,330,000 I $19,207,000 -1 Source: John Coequyt and Richard Wiles, “Unplugged: How Power Companies Have Abandoned Energy Efficiency Programs,” Environmental Working Group & the World Wildlife Fund, October 1998, p.2.

According to the Environmental Working Group report, these reductions in energy efficiency spending by California’s utilities have hurt their customers. By comparing the projected energy efficiency savings to those actually achieved under the reduced funding, the report calculated that the cuts in energy efficiency cost California consumers millions of dollars.

While it is widely accepted that energy efficiency is our cheapest, cleanest and safest source of energy, energy efficiency and deregulation don't necessarily mix. Absent strong support for energy efficiency programs, utilities will once again have every incentive to encourage consumption. To make matters even worse, energy efficiency funds will be placed in the control of the utilities rather than an independent administrator creating the potential for cross - subsidization of other utility projects and a potential for a misuse of the funds slated for energy efficiency programs.'*

12

- PART 2 =

CALIFORNIA’S NUCLEAR POWER PLANTS: GETTING IT BACKWARD FROM THE START

I CALIFORNIA’S OPERATING NUCLEAR REACTORS I Reactor Owner/Operator San Onofre Unit 2 Southern California Edison

Diablo Canyon Unit 2 I Pacific Gas and Electric Source:

Design Began End CE 1983 2013

CE 1984 2013

W 1985 2021

U.S. Nuclear Regulatory Commission, Information Digest, Nureg 1350, Vol. 9, May 1997, Appendix A, pp. 89 & 96. Note: CE = Combustion Engineering, W = Westinghouse

So what have Californians been asked to bailout and then subsidize? California’s nuclear reactors have a reputation for being some of the better nuclear power plants in the industry. In fact, Diablo Canyon has made the NRC’s best plant lists 5 times. However, “better” is a relative term. We are, after all, talking about the nuclear industry. The industry that Forbes magazine declared “as the largest managerial disaster in business history, a disaster on a monumental scale.””

The four remaining nuclear reactors in California began splitting atoms between 1983 and 1986 after years of controversial and problem-plagued construction. A review of the recent operating history of both these nuclear power plants reveals that their reputation has not been based on problem-free performance.

13

DIABLO CANYON COST OVERRUNS: ITS NOT JUST HOSGRI’S FAULT

In 1963, Pacific Gas and Electric decided to build Diablo Canyon Units 1 & 2 on the California coastline near San Luis Obispo. The two Westinghouse-designed pressurized water reactors were originally slated to cost $319.7 million and were scheduled to go into operation in 1972 and 1974. After a troubled and controversial construction, Diablo Canyon Unit 1 began splitting atoms on May 7, 1985; Unit 2 didn’t begin commercial operation until March 13, 1986. By the time they began operation the total cost for the two units had ballooned to $5.5 billion - an increase of 1,620%. So much for “energy too cheap to meter!”20

The Diablo Canyon construction project was beset by many of the same factors that assailed the rest of the nuclear industry. Accidents at Browns Ferry in 1975 and at Three Mile Island in 1979 revealed major lapses in safety regulations and resulted in new safety requirements for nuclear power plants. However, Diablo Canyon’s construction also faced problems of its own. In 1969, geologists discovered earthquake fault lines running approximately 2 to 4 miles off the coast of Diablo Canyon. The discovery of this fault line, named the Hosgri Fault, called into question the seismic design of the reactors. The re-working of Diablo Canyon seismic design wasn’t completed until 1981. 2 1

PG&E’s construction of Diablo Canyon also faced problems of its own making. In September 198 1, a week after NRC had issued Unit 1 a low-power operating license and in the face of an attempted occupation of the plant site by thousands of protesters, a PG&E engineer discovered that seismic pipe restraints had been installed backward!22

This discovery provided undeniable proof of a serious breakdown in the quality assurance program at Diablo Canyon, confirming allegations raised by San Luis Obispo’s Mothers for Peace, which had intervened in the licensing of the reactor. 23

In 1984, when PG&E again attempted to get its low-power license for Diablo Canyon Unit 1, a flood of whistleblower allegations confronted NRC. As PG&E struggled with the seismic design deficiencies, over a thousand more allegations of quality assurance problems were documented and filed with NRC by the intervenors. Former Diablo workers alleged a widespread quality assurance breakdown in the seismic design for the reactor. While acknowledging the problem, NRC still issued the low-power license and said the problems could be addressed during operation.24

When the NRC moved to give a full-power license to Diablo Canyon, Commissioner James Asselstine dissented, stating that, “I am not yet satisfied that the Commission has the informatior. needed to conclude, with a high degree of confidence, that all significant seismic design issues have been identified and corrected.” Asselstine would later comment at a congressional hearing on the licensing of Diablo Canyon that, “the Commission is losing sight of what its regulatory mission really is. Our job is to protect the public health and safety. Our job is not just to issue licenses.” 25

14

SAN ONOFRE GETS IT BACKWARD! Unfortunately, Diablo Canyon wasn’t the only nuclear utility to get things

backward. In November 1977, Southern California Edison (SCE) was in the process of constructing San Onofre Units 2 and 3, at the time the largest construction effort in the history of San Diego County.26 The previous April SCE had installed the reactor vessel in Unit 2. SCE was preparing to do the same in Unit 3 when it discovered that the 420-ton Unit 2 reactor vessel had been installed backward!27

When the mistake was discovered, nuclear engineer Dale Bridenbaugh, a member of MHB Technical Associates, called the mistake inconceivable. “If they can install a 420 ton reactor vessel 180 degrees out of phase, what does that say about their quality assurance program?” Bridenbaugh wondered to the San Diego Blade Tribune. “What other things have they screwed up on?” *’

Californians were soon to learn of other problems that plagued the $2.4 billion construction effort at San Onofre, including several caverns beneath the reactors’ foundation and an improperly manufactured pressurizer. The 1 00-ton pressurizer maintains the pressure of the reactor’s coolant. According to Southern California Edison’s project director, “The pressurizer problem is not a reactor vessel-type problem.. .It’s a quote ‘normal’ type of mistake one encounters in a construction project and we have many, many of these things.”29

Unfortunately, the Southern California Edison project director was correct. There were “many, many of these things.” Further inspections revealed enough of these problems for the NRC to conclude that “a significant breakdown in a limited portion of the quality assurance program” had occurred at San Onofre Units 2 & 3.30

= PART 3 - PERFORMANCE OF CALIFORNIA’S REACTORS

In the year prior to the 1986 Chernobyl disaster, the U.S. Nuclear Regulatory Commission testified before Congress that there was a 45% chance of a meltdown in the United States in the next 20 years.31 The bailout of the nuclear reactors owned by Pacific Gas & Electric, Southern California Edison and San Diego Gas & Electric, foisted upon California consumers by AB 1890, will ensure that California’s nuclear reactors continue to split atoms and pose a threat to the people of California.

In the 1990s. California’s nuclear reactors have garnered little attention from the Nuclear Regulatory Commission. Diablo Canyon and San Onofre have been subject to escalated enforcement (a violation plus a fine) a total of only five times since 1990.32

Diablo Canyon received a NRC violation and was fined $50,000 in 1990 for deficiencies in a containment re-circulation pump. In 1996, Diablo Canyon was again fined $50,000 by the NRC due to a breakdown in the utility’s program to adequately control grounding devices at the plant. Diablo Canyon received a third violation and was fined $1 10,000 for a breach in plant security that resulted from granting unescorted access to an individual that plant contractors had asked not be allowed on the site.33

San Onofre Units 2 & 3 were each fined $75,000 in 1991. San Onofre Unit 2 received a violation and was fined due to the in-operability of an auxiliary feed water pump. San Onofre Unit 3 received a violation and was fined due to the inadvertent opening of an emergency sump isolation valve.34

According to NRC’s Systematic Assessment of Licensee Performance (SALP), the Nuclear Regulatory Commission’s reactor report card, Diablo Canyon and San Onofre nuclear power plants are among the better performers in the nuclear industry. Both Diablo Canyon and San Onofre SALP scores have resulted in less NRC inspection of these facilities.

However, a review of the recent operating history of California’s nuclear reactors reveals that both Diablo Canyon and San Onofre have had numerous problems that have had potential safety significance. These “events” have included Scrams, Safety System Actuations, Safety System Failures and Significant Events. Each of the events is tabulated below and the descriptions, excerpted directly from the NRC’s performance indicator reports, are included. Note that the data for 1997 only includes events through the 3rd quarter of 1997, the latest data available. Other indicators of reactor performance are also incorporated, including capacity factors, notices of enforcement discretion and whistleblower allegations.

16

SCRAMS - EMERGENCY PLANT SHUTDOWNS

When a nuclear plant shuts down under normal conditions, the power level is decreased slowly by the gradual insertion of "control rods" into the reactor core. The control rods stop the fission process by absorbing the neutrons that maintain the nuclear chain reaction.

Sometimes, however, the reactor must be shut down immediately. To do this, the control rods are inserted rapidly into the core, a practice called a "scram." Scramming a reactor is like suddenly slamming on the brakes in a car -- it is a sudden, violent shutdown of a nuclear reactor.

Source: Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part II Office for Analysis and Evaluation of Operational Data. 199 I - 1997.

2/1/91

4/23/9 1

Scrams at Diablo Canyon35:

Unit 1 SCRAM

Personnel error resulted in an instrument air valve being closed. Air was lost to feed control valves causing them to clnse. The reactor tripped on low steam generator level.

Unit 1 SCRAM

A high SG (steam generator) level resulted when an operation amplifier failed on a MFW pump track and hold circuit board causing the MFW pumps speed to increase. The reactor tripped after the turbine tripped from high SG level.

17

.

5/17/91

3/6/92

Unit 1 SCRAM

Cognitive personnel error during APRM testing resulted in a high flux at high power reactor trip signal.

Unit 1 SCRAM

A reactor scram occurred due to low steam generator level. The failure of an inverter power supply to the mfp (main feed water pump) speed controller had caused an over speed trip of the mfw pump. The cause was poor manufacturing and design of the inverter.

4/25/92 Unit I SCRAM

A turbine trip occurred on low condenser vacuum causing a reactor trip. While performing repairs the condenser vacuum was lost and could not be restored due to leakage through the condenser vacuum suction check valve.

1/30/93 Unit 2 SCRAM

The reactor scrammed due to a turbine trip which occurred during turbine functional testing. The cause of the trip is believed to be either personnel error or lube oil contamination.

12/26/93 Unit 1 SCRAM

A reactor trip occurred when the main generator output breakers opened due to large power oscillations on the off site power grid.

12/ 14/94 Units 1 & 2 SCRAM

A dual unit reactor trip resulted from a major western grid disturbance.

9/6/95 Unit 1 SCRAM

A reactor trip occurred as the result of a turbine trip. P, failed solenoid valve in the turbine auto stop oil system caused the turbine trip.

8/ 10/96 Units 1 & 2 SCRAM

A reactor trip occurred when tow of the four RCP breakers opened during a major western grid disturbance.

18

1 1/22/96 Unit 1 SCRAM

3/29/97

3/ 1019 1

31 1519 1

4/24/92

5/ 15/92

713 1/92

Reactor trip occurred on a turbine trip following an electrical fault in a 12 KV bus. The fault resulted from a failure of PVC insulating material.

Unit 2 SCRAM

Reactor trip occurred on low SG (steam generator) level when a MFP (main feed water pump) failed. A valve in the control oil supply to the MFP turbine governor valve bound from corrosion product build up, which resulted in the governor valve drifting shut.

Scrams at San Onofre36

Unit 2 SCRAM

Control element drive mechanism control system mg set # 2 opened due to equipment failure, causing the CEDMCS bus to de energize and the reactor to trip. CEDMCS mg set # 1 was out of service for maintenance.

Unit 3 SCRAM

The failure of a non 1 E 120 vac un-interruptible power supply caused a turbine trip. A reactor trip followed due to loss of turbine load.

Unit 2 SCRAM

A reactor trip followed a turbine trip due to high moisture seperator reheater drain tank level. A transformer failure caused a main feed water pump trip, and a reduction in power, to which the MSR drain tank level did not respond properly.

Unit 3 SCRAM

The #3 RCP (reactor coolant pump) tripped on an over current ground causing a reactor trip on a low DNBR signal.

Unit 2 SCRAM

During a surveillance test a reactor coolant pump bus switch gear door was opened. This resulted in a loss of two reactor coolant pumps and a reactor scram on low DNBR.

19

1/16/93

7/5/93

Unit 3 SCRAM

A reactor scram occurred on turbine/generator trip that resulted for flooding of the turbine building from torrential rains.

Unit 3 SCRAM

A reactor scram occurred following a turbine trip that resulted when an instrument air tubing supply air to main turbine gland seal system failed.

20

SAFETY SYSTEM ACTUATIONS

Safety System Actuations are manual or automatic activations of specified components of reactor emergency core cooling systems (ECCS) or emergency power system^.^' The ECCS is the main safety back-up system in a reactor. It is intended to provide emergency cooling of the reactor's core should the reactor experience a loss of coolant accident.

This indicator is similar to one employed by the Institute of Nuclear Power Operations (JNPO), Unplanned Safety Systems Actuations. According to INPO, "fewer actuations indicate greater care in plant operation, which contributes to a higher margin of safety.

In 1992, the NRC eliminated reporting requirements for certain safety system actuations. NRC regulations require that nuclear power plant licensees report any event or condition that involves the actuation of any engineered safety feature (ESF). ESF actuations account for approximately 40% of Licensee Event Reports (LERs). The NRC's deregulatory effort is expected to reduce the number of events reported by 5 to 10 %."Therefore, reductions in the number of safety system actuations do not indicate an increase in safety but rather a decrease in regulation by the NRC.

SAFETY SYSTEM ACTUATIONS

Source: Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part 11, Office for Analysis and Evaluation of Operational Data. 199 1 - 1997.

3/23/9 1

Safety System Actuations at Diablo

Unit I SAFETY SYSTEM ACTUATION

The wrong push button was pressed during SSPS slave relay testing causing the EDG to start and several safety injection valves to reposition to their safety injection positions.

21

5/17/91 Unit 1 SAFETY SYSTEM ACTUATION

Following a scram, excessive cooldown due to stuck open steam dump valve resulted in a safety injection actuation. Approximately 6000 gallons was injected.

10/6/9 1 Unit 2 SAFETY SYSTEM ACTUATION

Personnel error caused a safety injection signal to occur. No ECCS pumps started. All other actuations occurred as designed.


An emergency diesel generator auto started and loaded its associated vital bus. The auto start was caused by a blown fuse.

41 1 1/94 Unit 1 SAFETY SYSTEM ACTUATION

An EDG (emergency diesel generator) auto started and loaded its associated vital bus when a potential transformer sensing circuit fuse opened during testing.


An EDG (emergency diesel generator) started and loaded a 4.16 KV bus. when a lead from the bus undervoltage was removed during a maintenance activity. The cause was inadequate electrical clearance to cover the scope of the work.

Safety System Actuations at. San Onofre 40


A train “A” SIAS was generated, involving loss of power to ESFAS train “A” valve relay groups, when the DC power supply breaker was inadvertently bumped open. Train “A” EDG started and Train “A” control room isolation system actuated.

22

SAFETY SYSTEM FAILURES

Safety systems function to prevent or mitigate accidents that would otherwise seriously damage the reactor and result in catastrophic releases of radiation into the environment. The failure of these systems is an important indicator of nuclear reactor safety.

Safety System Failures include events or conditions that could prevent the successful functioning of safety structures or system^.^' Among the twenty-six safety systems, subsystems, and components monitored for this indicator are: reactor trip systems and associated instrumentation, radiation monitoring instrumentation, coolant systems, accident monitoring instrumentation, safety valves, feedwater systems, on-site emergency AC and DC power supplies, essential or emergency service water supplies, containment coolant systems, fire detection and suppression systems, and residual heat removal systems.42

The NRC specifies that for systems consisting of "multiple redundant subsystems or trains, failure of all trains constitutes a safety failure." Conversely, the failure of some, but not all, of a set of redundant trains is not counted as a safety system failure.~~

I SAFETY SYSTEM FAILURE^ 1

Source: Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors. Part 11, Office for Analysis and Evaluation of Operational Data. 1991-1997.

One disturbing trend identified in both San Onofre and Diablo Canyon safety system failures is the number of problems that have existed since initial operation. These problems and the fact that they've existed since the reactors were licensed raises concerns echoed by intervenors and whistleblowers about the quality assurance built into these nuclear reactors.

23

1/3/9 1

9/1/9 1

Safety System Failures at Diablo Canyon 44

Unit 1 SAFETY SYSTEM FAILURE

Both RHR (residual heat removal) pumps were inoperable simultaneously for one minute. One pump as inoperable for surveillance testing while the other pumps emergency power supply was secured for maintenance.


DC control power for both containment spray pumps was de-energized through personnel error, rendering both pumps inoperable. This occurred due to not properly following procedures.

1 11’2 1/91 Units 1 & 2 SAFETY SYSTEM FAILURE

Design problems in the CR ventilation system could allow unfiltered air to be drawn in through the re-circulation flow path if a booster fan or its damper failed. This condition existed in all modes up to 100% power since initial operation.

121 19/9 1

2/ 14/92

6/22/92

Units 1 & 2 SAFETY SYSTEM FAILURE

Under certain component cooing water system alignments, the heat load during post LOCA cold leg re-circulation may cause CCW temperature to rise above design limits. This condition existed in all modes up to 100% power since initial operation.


Both EDGs (emergency diesel generators) did not meet Appendix R requirements due to lack of fire protection for the field circuits. This condition existed in all modes up to 100% power since initial operation.


Diaphragm valve CVCS- 1-547 was leaking which could have resulted in the control room 10 CFR 100 dose limits being exceeded during a design basis LOCA.

24

8/8/92

91 1 5/92

9/25/92


Both fuel handling building ventilation trains could have been lost on a loss of 125 v dc power to one train. This was caused by a design deficiency. This condition existed in all modes up to 100% power since initial operation.


Leakage through safety injection valves may result in inadequate cold leg injection and pump run out. This condition existed in all modes up to 100% power since initial operation.


The containment fan cooler units were inoperable due to numerous cracks found in the back draft damper blades. The cracking was caused by high cycle fatigue. Condition existed for an indeterminate period of time.

11/7/92 Unit 1 SAFETY SYSTEM FAILURE

The automatic isolation capability of containment vent piping was inadvertently by passed during a containment vent to reduce pressure.

1/8/93 Units 1 & 2 SAFETY SYSTEM FAILURE

A non-conservative set point analysis rendered the low temperature over pressurization protection system incapable of performing its design function in certain situations. Condition existed for an indeterminate period of time.

1/13/93

3/ 12/93

31 17/93

Units 1& 2 SAFETY SYSTEM FAILURE

A design review found that under certain conditions the component cooling water design basis temperature may be exceeded. This condition existed in all modes up to 100% power since initial operation.

Unit 2 SAFETY SYSTEM FALURE

Containment was not properly established during core alterations. Equipment hatch door would not completely seal.


A fuel handling building door was propped open while fuel was being moved. The building negative pressure requirement was not maintained.

25

11/19/93 Units 1 & 2 SAFETY SYSTEM FAILURE

6/24/94

8/3 1/94

2/ 1 /95

8/1 1/95

1 0/6/9 5

All five containment fan cooling units have been inoperable in mode 4 (hot shutdown) since initial operation due to inadequate design of system and operating configurations. This condition has existed in hot shutdown since initial operation.

Unit 1& 2 SAFETY SYSTEM FAILURE

Component cooling water flow to the charging pumps sub components was insufficient to meet specified flow rates due to throttled cooling water valves. This condition existed in all modes up to 100% power since initial operation.


Defects in printed circuit boards could have prevented the battery charger from maintaining battery voltage during seismic events. Condition existed for an indeterminate period of time.


A single HELB (high energy line break) event could have rendered both solid state protection systems of the ESFAS initiation inoperable. The cause was inadequate separation of electrical circuits. This condition existed in all modes up to 100% power since initial operation.


Control room GDC 19 limits could have been exceeded during maintenance on the control room HEPA filter and charcoal absorber system. The system was not adequately isolated which could have permitted unfiltered air to enter the control room. This condition occurred during refueling in 1986 and 1989.


Crane operations with loads over the spent fuel pool were commence with the fuel handling building ventilation system inoperable due to a lack of an emergency power source.

26

10/ 10/95 Units 1 & 2 SAFETY SYSTEM FAILURE

2/ 1/96

2/1 3/96

4/20/96

6/6/96

In the event of a design basis accident the component cooling water system maximum temperature may have exceeded the FSAR limits. The system analysis may contain a non-conservative design figure.


The charging pumps could have been damaged by dead heading if an ECCS actuation occurred while the charging pump recirculation line valves were closed for testing. The cause was inadequate plant design allow for system testing.


Containment fan cooler systems could have been rendered inoperable during a LOCA while the 230 KV system was degraded.


The fuel handling system ventilation system was rendered inoperable when one train was removed from service for maintenance. The other train did not have a source of emergency power available.


One train of the P-4 reactor interlock was inoperable between 6/6/96 and 8/2/96 due to a lead being lifted on a turbine trip solenoid. The other train was inoperable for brief periods during surveillance testing.

Safety System Failures at San Onofre~~

1/25/9 1

2/4/9 1


The post accident clean up unit (PACU) inlet duct heater was found off when it was required to be on. Consequently, the PACU operability requirements were not satisfied when irradiated fuel was moved in the spent fuel pool 1/19/91 - 1/22/91.


The set point for steam generator low level trip had been incorrectly calculated and was non-conservative. Condition existed in all modes up to 100% power since initial operation.

27

0/15/91

1/27/92

3/ 13/92

5 /27/9 3

8/ 10/93

8/26/95


Several Foxboro instrument modules (accident monitoring instrumentation) were inoperable because they did not conform to the vendors generic seismic design requirements.


Both trains of AFW (auxiliary feed water) along with AFW transmitters for post accident monitoring, and two SG blowdown CIVS (containment isolation valves) could be render inoperable if the TDAFW pump steam lines broke. Some components were not environmentally qualified. Condition existed in all modes up to 100% power since initial operation.


Failure of Minimum flow valves in the HPSI (high pressure safety injection) and containment spray systems could result in leakage path from containment under accident conditions. The valves could not produce enough thrust to fully close under accident conditions. Condition existed in all modes up to 100% power since initial operation.


Motor operated switch settings on two component cooling water containment isolation valves and one pressurizer steam sample valve were insufficient to ensure valve closure. Condition existed in all modes up to 100% power since initial operation.


A management walk down identified that some retaining bolts of the MSIV (main steam isolation valve) enclosure blowout panels were either missing, broken or improperly engaged. Condition existed for an indeterminate period of time.


Both EDGs (emergency diesel generators) were inoperable. One EDG was inadvertently rendered inoperable during testing when technicians failed to install a jumper. The opposite train EDC was out of service for maintenance.

28

8/2 7/9 5

11/27/95

1 2/ 10/96

8/ 14/97


Containment integrity was violated with core alterations in progress. Several AFW (auxiliary feed water) vent and drain valves were open providing a path from containment atmosphere to the outside atmosphere.


Steam from a postulated HELB (high energy line break) could travel through the ventilation ductwork and render the ECCS (emergency core cooling system) and other safe shutdown systems inoperable. The original design analysis did not identify this potential event. Condition existed in all modes up to 100% power since initial operation.


Containment integrity was breached during core alterations when an escape hatch pressure equalizing valve was left open, providing access from the containment atmosphere to the outside atmosphere.

Unit 2 & 3 SAFETY SYSTEM FAILURE

Both trains of the backup nitrogen system to the component cooling water surge tanks were declared inoperable because there was insufficient nitrogen to ensure that the tanks remain pressurized for the required seven days. The cause was inadequate design.

29

SIGNIFICANT EVENTS

.3

Significant Events are events occurring at operating reactors that, in the judgment of the NRC, presented an actual or potential threat to the health or safety of the The initial screening process includes the daily review of all reported operating reactor events, as well as additional operational data such as tests and construction activities.47

.3 .2 . I <.I NA

Among the criteria the NRC employs to determine which occurrences should be classified as significant events include:

0

0

0

0

0

0

degradation of important safety equipment a major transient or an unexpected plant response to a transient degradation of fuel integrity, the primary pressure boundary, or important

associated structures a reactor trip with complications an unplanned release of radiation exceeding plant technical specifications

(TS) or regulations operation outside of the TS limits other events that are considered significant4’

SIGNIFICANT EVENTS

I Diablo Canyon Unit 2

San Onofre Unit 3 I Industry Average:

1991 1

0 0

1 .3

1992 I 1993 I 1994 I 1995 I 1996 I 1997 I I I I

0

Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Oueratin Commercial Nuclear Tower Reactors: Part Office for Analysis and Evaluation of Operational Data,

Source:

While neither San Onofre nor Diablo Canyon’s record is particularly egregious as to the number of significant events, the fact is that significant events have and will continu: to occur at these nuclear reactors. The question posed by Proposition 9 to California voters is whether they will bailout and then subsidize these nuclear reactors that continue to threaten their health and safety.

30

3/7/9 1

Significant Events at Diablo Canyon49

Unit 1 SIGNIFICANT EVENT

With the start up transformer out of service for maintenance, a mobile crane boom came within 3 feet of a 500 KV line back-feeding power to aux loads. A flash over resulted, causing a total loss of off-site power.

Significant Events at San Onofre50

2/26/93 Unit 2 & 3 SIGNIFICANT EVENT

Because of a power distribution modeling error, DNB ratios calculated by the core protection calculator were non-conservative over several fuel cycles. This error would have prevented the actuation of a DNBR trip signal at the desired set point. Condition existed for several fuel cycles.

2/ 16/95 Unit 2 SIGNIFICANT EVENT

With Unit 2 shutdown in mid-loop operation and one of the two EDGs out of service for maintenance, the licensee did not provide adequate control of switchyard operations.

31

ENFORCEMENT DISCRETION

For the last decade, the U.S. Nuclear Regulatory Commission has allowed nuclear reactor operators to violate NRC regulations at nuclear power plants across the country. As early as 1985, members of the NRC staff recognized that regional administrators were allowing nuclear reactors to violate the terms of their licenses without following the procedures for granting license amendments established by the Atomic Energy Act." Rather than requiring that reactors follow the law, the Commission created a policy to incorporate the non-enforcement of regulations. The NRC called this practice a Temporary Waiver of Compliance.

Although the NRC has been using this policy for the last decade, the Commission has never been quite comfortable with its legality. In February 1992, the Commission received SECY-92-043, "Exercise Of Discretion Not To Enforce Compliance With License Conditions" from NRC General Counsel, William Parler. The document raised legal questions about the NRC's ability to temporarily waive safety regulations. Public Citizen obtained the document through the Freedom Of Information Act but large portions have been deleted. The resuIt of the document was to change the NRC practice of temporarily waiving compliance with regulations. Instead, the Commission will merely choose not to enforce its regulations by issuing a notice of enforcement discretion. Whether the NRC "waives" the conditions of a license or merely chooses not to enforce them, the result is the - same. Nuclear power plants continue to spit atoms when their technical specifications require that they be shut down. The NRC knowingly allows nuclear reactors to operate in violation of the terms of their licenses.

To her credit, NRC Chairman Shirley Jackson has severely limited the use of enforcement discretion; only seven requests were granted in 1996.s2 However, there is very little difference between non-enforcement and deregulation. Rather than not enforcing regulations, Jackson's NRC is busy wiping them out. The new standard technical specifications currently being adopted by reactors results in a 40% reduction in the limiting conditions for operation.53 Nuclear reactors will no longer need to request enforcement discretion because the regulation requiring that the reactor be shut down has been eliminated. California's reactors are already taking advantage of NRC's deregulatory effort. San Onofre adopted the less stringent technical specifications in August of 1996. Diablo Canyon will do the same in July of 1999.s4

The NRC claims that enforcement discretion is used to promote the safest course of action by the licensee. Public Citizen is unconvinced. Allowing a nuclear reactor to split atoms can not pose less risk io the public health and safety than keeping the reactor shut down until it meets regulations.

32

Reactor Diablo Canyon Unit 1 Diablo Canyon Unit 2

1991 1992 1993 1994 1995 1996 1997 0 0 1 0 0 0 0 0 0 1 2 1 0 0

~ ~~~~ ~ ~~

Source: Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part 11, Office for Analysis and Evaluation of Operational Data. 1991-1997.

San Onofre Unit 2 San Onofre Unit 3

Unfortunately, it appears that after a short hiatus NRC has once again found i t easier to waive regulations than enforce them. San Onofre hasn’t lost any time in taking advantage of NRC’s loophole. While only seven notices of enforcement discretion were granted in 1996, the NRC issued 19 in 1997. San Onofre has requested enforcement discretion three times in 1997, more than any other nuclear plant in the nation.

2 2 I 0 0 0 0 1 1 0 0 0 0 3

33

CAPACITY FACTORS

The capacity factor of a nuclear power reactor is a measure of its reliability. Specifically, it measures the amount of energy produced by a reactor over a given time period as a percentage of what the reactor was designed to produce. For example, if a reactor designed to produce 1,000 megawatts of electricity functioned at full power for only half a year, and was shut down for the other half of the year, it would have a fifty percent capacity factor. The same reactor, operating at half power (500 megawatts) for the full year would also have a 50% capacity factor. There are several slightly different means of measuring capacity factors used by industry and government; Public Citizen employs one of the most common of such measures, maximum dependable capacity.55

Low capacity factors drive up the cost of electricity to the consumer in two ways. First, when nuclear reactors do not operate consumers must pay for both the cost of maintenance and the cost of replacement power. Second, unreliable reactors create a need for larger reserve margins, thereby forcing utilities to provide back up power that would not be necessary if more reliable sources of electricity were used.

I CAPACITY FACTORS

I Reactor I 1991 I 1992 I 1993 I 1994 I 1995 I 1996 I 1997* I I I I I I I

Diablo Canyon Unit I I 78.3 I 79 I 96 I NA I Diablo Canyon Unit 2 1 81 I 96.9 I 81.8 I 82.9 I 92.6 I 83.1 I NA

I I I I 1 I I

San Onofre Unit 2 1 NA I I I I I I I

San Onofre Unit 3 7 2 I 75.2 I 97.0 I 79.3 1 93.2 I NA Source: Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Ouerating Commercial Nuclear Power Reactors: Part 11, Office for Analysis and Evaluation of Operational Data, 1991-1997.

Note: *The NRC has changed the reporting requirements on nuclear power plants and as a result capacity factors are no longer reported in the reactor’s monthly operating report.

Some of the capacity factors cited above are impressive, especially for the nuclear industry. Unfortunately, capacity factors don’t tell the whole story. One must question whether the reactors are operating more efficiently or whether the NRC is just regulating less. Through the use of enforcement discretion and the rewriting of technical specifications, NRC has allowed reactors to operate when previously regulations would have required that they shut down. Capacity factors may rise, but at the. expense of safety.

34

BLOWING THE WHISTLE AT DIABLO CANYON AND SAN ONOFRE

Diablo Canyon

Whistleblowers are a fact of life in the nuclear industry. Unfortunately, NRC and the nuclear industry have done their best to silence these nuclear safety advocates. NRC’s record for protecting whistleblowers is abysmal. Public Citizen’s Critical Mass Energy Project cannot in good conscience tell nuclear workers that they will be protected if they bring their safety concerns to NRC. Regardless of this fact, there has been an alarming increase in the number of allegations filed by whistleblowers at both San Onofre and Diablo Canyon.

Year 1992 1993 1994 1995 1996 Received/S ubs tan tiated 5/3 13/2 9/3 18/11 23/5

WHISTLEBLOWER ALLEGATIONS

Open Harassment & Intimidation

0 0 0 2 10 2 2 2 2 4

S an Onofre

Received/Substantiated 6/ 1 12/0 14/2 28/14 32/10

Open 0 0 1 2 10

Harassment & Intimidation 2 3 6 3 2

While not every whistleblower allegation to NRC is significant, the fact that these workers feel they must go to ;URC rather than the utility is. That increasing numbers of whistleblowers are coming to NRC, shows a lack of faith among workers that the safety issues raised within the corporation are being addressed. It is interesting to note that while NRC performance indicators would suggest that the reactor operations are improving, the marked increase in the number of allegations forwarded to NRC suggest that the indicators aren’t telling the whole story.

As exemplified by the regulatory debacle and two-year shut down of Northeast Utilities Millstone nuclear power plants, an increasing number of whistleblower allegations can signify trouble down the road. One reason for the increase in whistleblowers coming to NRC could be the mounting pressures placed upon nuclear utilities in the face of pending competition.

35

THE NEXUS BETWEEN ECONOMICS AND SAFETY

As early as 1994, then-NRC Chairman Ivan Selin acknowledged that economic pressure was providing utilities with an “incentive to cut has acknowledged that “electricity deregulation is posing a potent challenge to the nuclear industry, which is struggling to make its costs competitive without compromising safety.”~’ The nexus between nuclear economics and nuclear safety has already resulted in the recent closures of the Big Rock Point, Haddam Neck, Maine Yankee, Millstone Unit 1 and Zion nuclear reactors.

The Wall Street Journal

The Arthur Andersen consulting firm has suggested that NRC develop an indicator that will show the economic stress upon its licensees. The Arthur Andersen report stressed the importance of such an indicator because, “the threat exists that nuclear utilities in their desire to cut costs and increase competitiveness will be forced to impair their operational safety and increase risk.”s8 According to California’s nuclear whistleblowers this is already occurring.s9

If the Diablo Canyon and San Onofre nuclear reactors can not compete in a competitive electricity marketplace they should not be coddled with operating subsidies and supported by stranded cost bail outs. If the Diablo Canyon and San Onofre nuclear reactors cannot compete they should be retired and decommissioned.

36

- PART - 4 FINDINGS AND CONCLUSIONS

FINDINGS

The $14 billion bailout of California’s nuclear reactors dwarfs the amount secured for renewable energy and energy efficiency under AB 1890.

The total nuclear subsidy for the Diablo Canyon and San Onofre nuclear power plants represents at least 20% of the residential consumer’s bill.

Operating subsidies totaling $2.2 billion insulate California’s nuclear reactors from competition ensuring that these non-competitive sources of electricity will continue to split atoms and endanger the public health and safety.

Despite their reputation, California’s nuclear reactors continue to experience performance problems that potentially threaten the public health and safety.

Many of the safety problems at Diablo Canyon and San Onofre have existed since the reactors were initially licensed; lending support to intervenor and whistleblower allegations of quality assurance problems in their construction.

There has been an alarming increase in the number of whistleblower allegations filed with the Nuclear Regulatory Commission at both Diablo Canyon and San Onofre nuclear power plants. This shows a lack of faith among nuclear power plant workers that safety issues raised with utility will be addressed.

31

CONCLUSIONS

Californians are getting a second chance! Proposition 9 reverses the most egregious aspects of AB 1890 by banning the bailout of California’s nuclear reactors.

While being admittedly “comatose” when the deal to bailout California’s nuclear reactors was cut, Californians have an opportunity to wake up on Election Day and reverse the obscene bailout and subsidization of the Diablo Canyon and San Onofre nuclear power plants.

Regardless of the work done and hours spent crafting AB 1890, it is a raw deal for California consumers. Californians never wanted these nuclear reactors precariously perched along the quaking California coastline and they should not have to bail out the utility companies that made these bad investments.

This deal is even less palatable when you realize that not only are Californians expected to pay off the bad investment in nuclear power but then they are expected to subsidize the continued operation of these reactors. This subsidization will allow these reactors to continue to split atoms, threatening the health and safety of California families and communities.

If the Diablo Canyon and San Onofre nuclear power plants cannot compete in a newly competitive electricity market without bailouts and subsidies, they should be shut down and decommissioned.

38

END NOTES

Robert A. Jones, Los Angeles Times, June 14, 1998, pp. B-1 & B-5. I

2 Joint Statement of the Natural Resources Defense Council and the Environmental Defense Fund On the California Initiative Regarding Electric Utilities, May 22, 1998.

Robert A. Jones, Los Angeles Times, June 14, 1998, pp. B-1 & B-5.

“California’s Diablo Canyon Nuclear Power Plant May Close,” Telegram-Tribune, San Luis Obispo, Calif. Oct. 9.

Margaret Kriz, “Deregulation Shorts Out,” National Journal, August 8, 1998, p. 1862.

Peter Kaplan, “California ‘fiasco’ worries regulators,” Washington Times, August 3, 1998, p. D 12.

Peter Kaplan, “California ‘fiasco’ worries regulators,” Washington Times, August 3, 7

1998, p. D 12.

8 Energy News Data Corp., California Energy Markets, March 14, 1997, p. 9.

9 Moody’s Investors Service, “Stranded Costs Will Threaten Credit Quality of U.S. Electrics,” August 1995, p. 1.

10 Energy Information Administration, The Changing Structure of the Electric Power Industry: Selected Issues, 1998, July 1998, p. 147.

1 Bob Kinosian, Personal Communication, California Public Utilities Commission, Office of Ratepayer Advocates.

1 http://energy.ca.gov/homeprofiler/your_electricity_bill. html.

13 The Total CTC Charge does not cover the entire $28 billion bailout as part of the bailout is shifted to the Trust Transfer Amount. See CAPUC Decisions 97-05-006,97-05- 0 18. and 97-05-022.

14 California Energy Commission. Calculated from data at http://energy.ca.gov/reports/stats/table33 .html.

15 Nancy Rader, Summary of California’s AB 1830 Renewable Energy Fund, January 1998.

16Californians against Uti!ity Taxes, Analysis of the Energy and Environmental Impact of the Utility Rate Reduction and Reform Act, June 25, 1998, pp. 5 - 6.

39

http://energy.ca.gov/homeprofiler/your_electricity_bill

http://energy.ca.gov/reports/stats/table33

”John Coequyt and Richard Wiles, Unplugged: How Power Companies Have Abandoned Energy Efficiency Programs, Environmental Working Group & the World Wildlife Fund, October 1998, p.1.

Californians against Utility Taxes, Analysis of the Energy and Environmental Impact 18

of the Utility Rate Reduction and Reform Act, June 25, 1998, pp. 5 - 6.

James Cook, “Nuclear Follies,” Forbes, February 11, 1985, p. 83. 19

Group, Inc., Statement of Diablo Canyon Nuclear Power Plant Sunk Costs and Independent Auditors Report, Appendix C, July 15, 1998, pp. C-1, C-2.

21Id. at pp. C- 1.

22 Union of Concerned Scientists, Safety Second, February i985, pp. 202 - 205.

23Id. at pp. 202 - 205.

24Id at p. 204.

25Id. at pp. 206 & 207.

26 Gil Davis, “Nuclear Reactor Backwards,” San Diego Blade - Tribune, November 22, 1977.

27 Gil Davis, “Nuclear Reactor Backwards,” San Diego Blade - Tribune, November 22, 1977.

28 Gil Davis, “Nuclear Mistake ‘Inconceivable’,” San Diego Blade - Tribune, November 23, 1977.

29 Gil Davis, “Key Nuclear Part Incorrect,” San Diego Blade - Tribune, December 1, 1977.

Gil Davis, “Many Problems Revealed At Nuclear Plant,” San Diego Blade - Tribune, December 14, 1977, pp. 1 - 2.

31 James K. Asselstine, U.S. Nuclear Regulatory Commission, Testimony before the Energy Conservation Subcommittee, House Committee on Energy and Commerce, May 22. 1986.

32 U.S. Nuclear Regulatory Commission, Enforcement Action Tracking System, received through Freedom of Information Act request 98-248. See also http://www , nrc .gov/OE/rpr/rx. html.

33 Id. at pp. 49 - 50.

34 Id. at pp. 59 -60.

40

http://www

Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 199 1 - 1997.

35

Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for 36

Operating Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 199 1 - 1997.

U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Data through September 1995, Part II, Office for Analysis and Evaluation of Operational Data, , p. 2.

37.

James Taylor, Executive Director for Operations, U.S. Nuclear Regulatory Commission, 38.

Regulatory Review, SECY-92-141, April 17, 1992, Appendix B, Issue 3.


Operating; Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 199 1 - 1997.


Operating Commercial Nuclear Power Reactors: Part 11, Office for Analysis and Evaluation of Operational Data, 199 1 - 1997.

U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial 41.

Nuclear Power Reactors: Data through September 1995, Part II, p. 4.

42.~d. at pp. 4 - 5.

Id. at p. 4. 43.


Operating Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 1991-1997.

45 Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part 11, Office for Analysis and Evaluation of Operational Data, 1991-1997.

U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial 46.

Nuclear Power Reactors, Data through September 1995, Part II, p. 3.

47 Id. at p. 3

48 U.S. Nuclear Regulatory Commission, Office of Analysis and Evaluation of Operational Data, Annual Report 1993, NUREG-1272, Vol. 8, No. 1, November 1994 p.

41

49 Compiled from U.S. Nuclear Regulatory Commission, Performance Indicators for Operating Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 1991-1997.


Operating Commercial Nuclear Power Reactors: Part II, Office for Analysis and Evaluation of Operational Data, 199 1- 1997.

” Memo From: Harold R. Denton, Director, Office of Nuclear Reactor Regulation and James M. Taylor, Director Office of Inspection and Enforcement, To: Regional Administrators T.E. Murley, J.N. Grace, J.G. Keppler, R.D. Martin, J.B. Martin, RE: Relief form Technical Specification LCO’s, July 15, 1985, p.1.

U.S. Nuclear Regulatory Commission, NRC Administrative Letter 95-05: Revisions to 52

Staff Guidance for Implementing NRC Policy on Notices of Enforcement Discretion, November 7, 1995.

U.S. Nuclear Regulatory Commission, Regulatory Information Conference, Break out 53

session on New Standard Technical Specification, April 10 & 11, 1996.

54 U.S. Nuclear Regulatory Commission, Standard Technical Specifications Conversion Schedules, http://www.nrc.gov/NRR/sts/convert 1 .html.

55U.S. Nuclear Regulatory Commission, Licensed Operating Reactors: Status Summary Report, NUREG-0020.

Matt Wald, “Regulator Says Economics Could Lead Nuclear Plants to Scrimp,” New York 56

Times, September 9, 1994, p. A-19.

Ross Kerber, “Nuclear Industry Faces Charges of Cutting Comers: Electricity 57

Deregulation Brings Pressures on Costs and on Safety Budgets,” Wall Street Journal, February 1, 1996.

Arthur Andersen, Recommendations to Improve the Senior Management Meeting, 58

Process, December 30 1996, p. 30.

59Neil J. Aiken, “Going Critical: A Commeniary on the Nuclear Industry as observed at Diablo Canyon Power Plant,’’ April 15, 1998.

42

http://www.nrc.gov/NRR/sts/convert

$40.00

California Dreaming The Bailout of C al i fo r n i a's Nuclear Industry

Documents

Transcript of California Dreaming The Bailout of C al i fo r n i a's Nuclear Industry