In December 2007, SCE filed an application for ratepayers to fund an in house study of license renewal for San Onofre. Less than one month from filing the application and SCE's testifying that everything is operating to the highest NRC standards things began to fall apart at San Onofre. The Nuclear Regulatory Commission issued a report finding that "Fire Watch Certification Sheets were falsified to indicate that hourly fire watch rounds had been completed when they had not been completed" and that the investigation "…indicated that this individual had falsified fire watch records in this manner from April 2001 to December 2006." At first glance the NRC report might indicate that proper oversight was in place, yet this falsification had gone on for over five years and the NRC had still given SCE its highest rating during that period. SCE should not be allowed to use ratepayer funding for a license renewal study until this issue is resolved.

Another example of the oversight and media misunderstanding or misrepresenting the impacts of San Onofre operations are the recent articles touting 127-acre artificial reef to be completed this summer to offset the loss of kelp, algae and animals caused by the San Onofre nuclear power plant, company officials announced Friday. Yet, the 2nd Circuit Court of Appeals has ruled that mitigation such as the artificial reef at San Onofre should be for past damage only and that damage from once-through-cooling must not continue. This ruling is actively being addressed in California and across the nation at all generation facilities that result in loss of aquatic and marine life. SCE should not be allowed to use ratepayer funding for a license renewal study until this issue is resolved.

However the most compelling reason to disallow SCE's request for ratepayer funding of an in house feasibility study is the NRC process itself. In September 2007, the Inspector General (IG) of the NRC issued a report expressing concerns that "In the 13 relicensing cases it [the IG] examined, the office found little evidence that NRC staff had confirmed the integrity of aging safety systems they approved. For example: 98 percent of 458 passages in audit, inspection, and safety evaluation reports failed to adequately document or support NRC conclusions.

Problems fell into two categories: "red" cases, where no specific support was found, and "yellow" cases, where support was often provided by the companies whose plants were being relicensed. In those latter cases, the report found that NRC safety evaluation language was often "identical or nearly identical" to the information that the companies had provided in the license renewal application. Even more serious, he says, in 35 percent of "red" cases there was "no mention of review methodology or no specific support" at all for NRC staff findings that the 13 plants had successfully met safety requirements.” [1]

As of mid-February 2008, eight organizations and three states have petitioned the NRC to stay any license approvals that have been granted and freeze any application proceedings until resolution of this issue. Again, SCE should not be allowed to use ratepayer funding for a license renewal study until this issue is resolved.

A copy of this article in letter format to the CPUC can be copied and sent to President Peevey, CPUC, 505 Van Ness, San Francisco, CA 94102 or emailed http://www.cpuc.ca.gov/PUC/aboutus/Commissioners/01Peevey/contact.htm

In addition you can place your objections to this ratepayer funded study at the CPUC at four public participation hearings:

April 14, 2008 - 6:00pm - PALM SPRINGS
Palm Springs City Hall Council Chamber
3200 Tahquitz Canyon Way, Palm Springs, CA

April 15, 2008 - 6:00pm - VISALIA
Visalia Convention Center - Sequoia B Room
303 E. Acequiz Avenue, Visalia, CA

April 28, 2008 - 6:00pm - LONG BEACH
Long Beach Public Library - Main Library Auditorium
101 Pacific Avenue, Long Beach, CA

April 29, 2008 - 12:00noon - SANTA ANA
Santa Ana City Council Chambers
22 Civic Center Plaza, Santa Ana, CA

April 30, 2008 - 6:00pm - SAN BERNARDINO
San Bernardino Library - Bing Wong
555 West 6th Street, San Bernardino, CA

And finally, it is premature for ratepayers to fund SCE’s study of license renewal until the California Energy Commission has completed, adopted and implemented the results of its cradle-to-grave cost, benefit and risk analysis of the economic impacts of continuing to operate nuclear reactors. These reactors were designed in the 1960’s and there is no permanent repository for safely storing hundreds of tons of highly radioactive waste that have already been produced and are being stored on California’s fragile and seismically active coast.

[1] February 08,2008 edition - http://www.csmonitor.com/2008/0208/p02s01-usgn.html

Rochelle Becker, Vice-President SC Radiation Committee
Executive Director Alliance for Nuclear Responsibility