With over $1 billion up for grabs corporate greed need not be concerned with causing a pending nuclear disaster, nor its effect on the homes, businesses, lives, and livelihoods of 8.7million people.
At the Nuclear Regulatory Commission (NRC) public meeting, on October 9, 2012, regarding the re-opening of the San Onofre Nuclear Generating Station (SONGS), evasive answers, vague assurances, and a conspicuous lack of facts were the corporate responses to accurate concerns and hard evidence presented by hundreds of very concerned southern California residents. The efforts by Southern California Edison (Edison), that owns the “San Onofre” plant, and its co-conspirators, the Nuclear Regulatory Commission (NRC), and the California Public Utilities Commission (CPUC), was an ongoing example of their extraordinary greed, corporate control, and disregard for human life.
The 6 P.M. meeting was held at the ultra-posh, Monarch Bay Resort, in Dana point, California. Host, Southern California Edison, held court in the main ballroom. Attending was a more than packed house of nearly 1000. Many had to wait in the large hallways outside due to fire code restrictions.
Taking no chances with opposition forces Edison “bused in” six bus-loads of Edison employees from San Diego ( San Diego Gas & Electric owns 20% of San Onofre) and several more buses from Orange County. Many other local employees drove. Fully five-eighths of the room’s seating for the event was already taken by hundreds of Edison fans in conspicuous lime green, light blue, white, yellow, or orange T-shirts which showcased the various unions they represented as paid Edison employees. Many blocks of twenty to forty colored shirts strategically placed themselves about the ballroom. The plot for the evening thickened when one Edison representative revealed that the bill for the ballroom rental ($24,000) and the busing-in of the many hundreds of employees was being billed to Edison’s customers, the “ratepayers.” Also on the rate-payer tab for the night were the forty plus, khaki uniformed, members of the Orange County Sheriff’s Department and their black Labrador, bomb sniffing, dog. All were busily making their presence felt across the hotel and grounds. A Sheriff’s Department Lieutenant could not confirm the amount of these, excessive, police services, but admitted Edison would be paying for it. Apparently so would he.
THE PANELIST AT THE NRC PUBLIC HEARING
The other three hundred plus citizens jockeyed for the remaining seats. At the front of the room, on a top of a shallow stage, sat a long, white table clothed, table on top of which sat elegantly crafted table tents announcing the pending arrival of the evening’s panelists. One huge projection screen was ready on either side, to provide a better glimpse to the turbulent crowd assembling in front. As the dozen panelists began to near their seats the crowd slowed, for the moment, and took their seats.
The lines for the evening were now drawn. The issue; the likely reopening of San Onofre nuclear reactors number two and number three, which are located between north San Diego County and southern Orange County, California just five miles south from San Clemente. This forty-two year-old power plant, designed to last forty years, was closed this past January when severe malfunctions were detected in one of the recently replaced “steam generators” in one of the two reactors. These four steam generators (two per reactor) had been replaced slightly more than a year before at a cost of $700 million and, despite Edison’s public announcement that these would last another forty years, had already failed. The previous steam generators, removed through the concrete dome of each reactor, had served without a similar malfunction for the previous life of the plant.
The continuous operation of the steam generators is essential in keeping the nuclear reactors cool. Nuclear fission creates massive amounts of heat which is used to create steam which, under massive pressure, is used to create electricity. The steam generators must keep the temperatures to a containable level. Considering NRC’s own damning data, re-starting the two reactors without, again, replacing the four steam generators, puts southern California at extreme risk of its own Fukushima style disaster.(1)
During the meeting the CPUC’s chairman, Ed Randolph, maintained this California State Agency was independent in its over sight of Edison. However, CPUC had previously allowed Edison to back charge its ratepayers for, not only the replacement and repairs, but also the cost of the four new, faulty, steam generators. The CPUC also allowed Edison to continue to charge ratepayers for upkeep, maintenance, and operation costs, as if the power plant was still online and functioning. The track record of CPUC has been, for decades, to rubber stamp any Edison request before it.
“They keep making up the rules as the go along,” said Gene Stone, one of the night’s guest panelists, in a separate interview. Certainly the triumvirate of co-conspirators was up their old tricks, as Stone alleged. A look at the fiasco that once was Unit One and the effort required to shut down this reactor prior to a pending disaster proves him correct.
Initially Edison built two reactors in 1968, Unit One and Unit Two. Unit One only lasted until 1992 and has been closed since. Due to poor construction, multiple safety violations, and failing to build it to earthquake standards Unit One was finally closed. Why the call for closure took more than a decade is a litany of direct examples of the conspiracy between Edison, CPUC and NRC to keep San Onofre open, and running, despite all reason and public scrutiny. The NRC, on multiple occasions failed to enforce its own standards, delayed hearings, allowed for ongoing delays in mandated Federal safety improvements, and consistently adjudicated in favor of Edison, while repeatedly thwarting a law suit filed by consumer activist Ralph Nader.(See Link Here:)
Edison’s motivation, and even larger greed, is in running this plant, for free, to the point of disaster with complete impunity. Thanks to Congress Edison has minimal financial liability for a nuclear disaster of their making.
In 1959, with the American Congress mad over the miracle of nuclear power, The Price-Anderson Act was passed to sweeten the pot. This law provided a statutory maximum total monetary liability of just $12.6 Billion (as of 2006) for the entire nuclear industry. Ray Lutz of, “Citizen’s Oversight.org,” said that the maximum that Edison may be required to pay for causing a disaster is “ about $400 Million” Considering there are hundreds of thousands of businesses and properties, and 8.7 million people, within a 50 mile radius of San Onofre, this incredibly insufficient maximum liability provides, in turn, a minimal reason that Edison should care about public safety.
Tonight’s panel was made up of twelve speakers, six who were ostensibly in favor of re-opening the plant, and six who were not. One of the speakers was Kathy Iwane, a former resident of Japan during the Fukushima nuclear disaster. She reported being witness to the evacuation of the area, the dead zone that now exists for hundreds of square miles, and her subsequent routine use of the Geiger counter when purchasing food. Her caution revealed contaminated fruit and vegetables, as well as contaminated fish at a fish market 365 miles away from Fukushima. Ms. Iwane is now a resident of nearby Solana Beach, California, having abandoned Japan with her two children.
From the southern California safety perspective panelists and citizens opposing the reopening of San Onofre offered a very fair, factual, and two-pronged argument. One, the plant was past its 40 year lifespan, had the worst safety record of any US nuclear plant, the new steam generators were very likely to malfunction again, thereby putting the public at a high risk of a massive radiation leak and potential meltdown. Two, if these citizen’s factual assertions were not true, then the NRC, Edison, and CPUC should prove its case for safety, per NRC rules, in an open public hearing before a judge, with independent experts witnesses, under oath, called an “Adjudicatory Hearing.”
Throughout the night the pro-reopening forces mentioned that they felt this public question-and-answer session would suffice. This was not what the citizens in favor of safety, and closure, had in mind.
COLOR CODED UNION WORKERS
The regulations of the NRC allow for an “Adjudicatory Hearing” and “License Amendment” process which, by NRC definition, mandates testimony by experts not aligned with NRC, the public, Edison, CPUC, and any other interested party. All testimony would be public, under oath, and before an NRC administrative panel of all five, presidentially appointed, NRC commissioners. Why this fair and transparent NRC hearing was not, considering the possibility of a nuclear disaster, being allowed to this affected public was an ominous question, and was the best reason for the public’s demand that there be one.
THE SAN ONOFRE NUCLEAR GENERATING STATION (SONGS)
San Onofre opened on Jan 31, 1968 at a time when the population of the affected area was a very small fraction of today’s. The power plant sits, like Fukushima, on the Pacific coast of the Camp Pendleton Marine base which separates, by a 20 mile gap, southern Orange County and San Diego County. Today, a dense population totaling 8.4 million people, and their homes and businesses, are the landscape both North and South of the military base. After the Fukushima disaster the US government advised a fifty mile radius away from the contamination area for US residents.
From the start the San Onofre plant had major problems. Over the decades it has had literally the worst safety record of all US nuclear power plants. (2) To replace the power output of the closed Unit One, Edison built Unit Three. For the next three plus decades San Onofre was often in the news regarding radiation leaks, worker safety and contamination, leaky fittings, and smaller problems related to poor maintenance. NRC documents show San Onofre has indeed had the worst safety records over the past five years.
As the forty year lifespan expired Edison smelled profit. There was no mandate to decommission either plant. The steam generators, that had lasted forty years would have to be replaced, but all that would be paid by the ratepayers. Thanks to the implicit approval of Edison’s consigliore, the CPUC, San Onofre was set for another four decades of national record safety violations. And free profit. All was going well for Edison until suddenly one of the Steam Generators in Unit three leaked excessive radiation into the air. Suddenly it was revealed that Edison, having provided the designs, had deliberately cheapened the steam generators. Unit Three developed a radiation leak large enough to require a shutdown of the reactor. The subsequent inspection revealed “unprecedented wear” on the cooling tubes leading to the shutdown of both plants and the inspection of the other three steam generators.
Edison’s negligent design of the four steam generators was in complete violation of the NRC’s own regulations, which NRC deliberately ignored. Rule 50.59 of the NRC regulations requires formal review of any change in parts unless that replacement is exactly the same as the previous design. NRC ignored 50.59 allowing Edison to substantially changed the steam generator design without formal review as required. The new faulty design increase the number of tubes, while eliminating the portion of the design that limited vibration and friction on the cooling tubes. This egregious violation is the root of the reason why the new units failed so quickly.
NRC’S ELMO COLLINS
On January 31, 2012 San Onofre was shut down and taken “off-line” due to the inspection of the four steam generators. Inspection showed all four had unprecedented premature wear in less than two years operation. Since there is no test for the steam generators prior to installation to be sure they actually are operational, designers relied on computer models which were, obviously, flawed.
The old San Onofre steam generators were designed to limit vibration and, therefore, wear on the 38,908 cooling tubes. Edison, to cut costs, and increase profit, eliminated this function in their new design in favor of 380 new cooling tubes per steam generator. This allowed Edison to produce twenty percent more power, and free money. The result was friction between each of the tubes with many at risk of breaking or, worse, bursting due to thinning walls of the tubes. According to Ace Hoffman, a local activist who has had his eye on San Onofre for forty years, should one tube burst 15,000 gallons of radioactive water and steam will be released into the atmosphere in the first five minutes. Worse, this single tube burst may lead to many of the other weakened tubes bursting at the same time. Considering each of the four steam generator has almost 10,000 tubes the mathematics of this pending disaster are truly catastrophic.
Another fatal Edison design flaw ensures a disaster. Stupidly, Edison did not put in any valve system that would allow for each steam generator to be shut off if any leak, much less a blown tube, occurs. According to Hoffman, without the ability to shut off the out flowing radioactive water and steam, which is under 2200 psi of pressure, San Onofre’s engineers will be at the mercy of how much time it takes them to stop the reactors from producing heat and steam in the reactor and having the steam generators slowly drop pressure, before radioactivity stops spewing into the atmosphere. The lunacy of this design flaw again highlights Edison’s lack of concern for public safety due to their indemnity form financial disaster.
SCIENTIST DON MOSSIER OF
Edison’s engineering experts have come up with a simple, and cost-effective, fix for the steam generators. If given their way, they would immediately start up the defective steam generators for a five month trial run, operate the plant at 70% capacity, and add new modern monitoring devices so that they can be ready to shut down the plant, double-quick, at the first sign of trouble. Without valves it is unclear how they will do this. According to Ace Hoffman, Edison theorizes that this will cause less vibration and therefore friction on the tubes. Their calculations show it would take eight months for a tube to rupture at full power, so they consider this a safe bet. As for the leaky tubes Edison would merely, “plug” them prior to operation.
The act of “plugging” the leaking tubes belies the true definition. In plugging the tubes Edison is actually by- passing the leaky cooling tube by capping the tube at its inflow on the bottom and at the outflow at the top, thereby sending the steam to the next, possibly weakened, tube.
These profitably cheap fixes are fatally flawed since lowering power may, according to an independent nuclear engineer (3), increase vibrations and, therefore, additional friction, and wear, on the tubes. As such, Edison and its proposed additional monitoring system may get its first safety test immediately prior to a full-scale cooling tube blowout.
When the steam generators on Unit Three were shut down and inspected excessive wear was reported in over 10,000 tubes on Unit Three. Unit Two had almost 5000 overly worn tubes. Even worse Unit Three had over eight hundred tubes that were leaking and needed to be plugged, while Unit Two had five hundred and ten. These two statistics are the worst in US nuclear history by far.(3) Any radioactive leak exceeding eighty-five gallons per day is a cause for a reactor shutdown. Only four other nuclear power plants in the nation have experienced severe problems, or wear, with their steam generator cooling tubes. San Onofre also holds the distinction of having, by far, the most safety complaints over the past five years with one hundred and forty.
Combine these serious flaws with other real safety issues such as, San Onofre’s “30 Foot Tsunami Wall” being only fourteen feet high, that San Onofre sits on one of the most active earthquake faults in America, that the plant has no place to send its spent radioactive fuel and stores it on site, the backup safety systems have not been tested, and that there is no emergency plan in place for a potential evacuation, and it is small wonder that NRC wants to avoid a “License Amendment” and “Evidentiary Hearing”. Presumably, if such a hearing was held, loose assertions, baseless excuses, lack of facts, and the continued request for the public to trust their fraudulent process, would not carry the day, especially if the testimony is under oath.
“Don’t trust these experts until you see the data”, said Del Mar City Councilman, Don Mossier, one of the panelists, who is also a research scientist for the highly regarded Scripps Institute in San Diego. During the evening none of the six panelists in favor of reopening the plant provided any statistics, facts, or evidence. They repeated specious arguments that the public should trust the pending arbitrary decision of the NRC board. NRC Chairman, Elmo Collins, continued to offer that “our job is to make sure it’s safe”. But, despite repeated questioning, Collins would not assure the concerned public that a formal Adjudicated Hearing would be held prior to a NRC decision on re-opening the plant. CPUC director, Ed Randolph, whose stellar policing of Edison has included allowing Edison to back charge ratepayers for all its mistakes and, during his oversight, has never failed to recommend a rate increase for Edison, continued his attempt to mollify the crowd. “We are planning for San Onofre to be off-line for the short term, perhaps the long-term,” he said, but he also evaded the demand for addressing the facts presented at an Adjudicated Hearing. Robert Oglesby, California Energy Commissioner, echoed this evasive logic when he assured “contingency plans assume power [from San Onofre] is not there”.
Several other panelists in favor of opening provided more flippant remarks. Ken Schultz, a retired nuclear engineer, seemed irritated with the whole affair. Showing the distain of an NFL football coach at a press conference after a loss, he grimaced at all who questioned the sanctity of nuclear power. Drawing from his 1950s nuclear training propaganda he audaciously offered NRC jargon about “low doses of radiation being part of our environment” in an effort to excuse away the odd radiation leak. “You get that kind of radiation if you go to the mountains, to Denver, or up in an airplane”, he spat. It was nice of Mr. Shultz to provide levity to the evening, as several journalists smiled shaking their heads in disbelief at his antiquated remarks.
Unwittingly, Mr. Schultz, also proved confirmation of a separate argument against reopening San Onofre via his bombast. “Most of this power will go out on the Western [multi-state] grid”, he offered as a further reason San Onofre was absolutely essential to providing local energy requirements. As Gary Headrick, cofounder of San Clemente Green, pointed out power from San Onofre is not needed, except to be sold to out-of-state power customers of Edison.
Edison wants to restart San Onofre merely for profit, not local demand. And have the ratepayer pay for it. Currently, without San Onofre, California power plants provide more energy than is needed statewide. (4) Nuclear power is less than 10% of the total capacity of the state and, despite a very hot summer, there were no electric blackouts subsequent to the closing San Onofre. California currently produces forty percent more electricity than it needs. Additionally, two gas-fired power plants began operation within the last year in nearby Huntington Beach, just 20 miles away. San Onofre amounts to excess power which Edison will sell, thanks to rate payers, for their profit. Considering the disastrous risks attached to this profit why are the facts being ignored?
“Ratepayers are not paying one penny more,” stated panelist, Rachelle Becker, to the crowd. “We are tired of paying for Edison’s mistakes”. This is certainly true since, thanks to the cooperation of the CPUC, and Mr. Randolph, Edison had already charged their customers, not their shareholders, or bottom-line profit, for the repairs and their deliberately poorly designed steam generators. This amount totals nearly a billion dollars. Randolph’s calm schoolboy demeanor, when challenged by the public, belied his agency’s previous, virtually total, allegiance to Edison influence. Thanks to his help Edison paid nothing. Consequently, his protestations of “safety is our primary concern,” fell on deaf ears. Like his NRC brethren Randolph would provide no assurances of an Adjudicated Hearing prior to re-opening San Onofre.
Opposition is strong and well organized but disinformation, and lack of information, is firmly under corporate control. To date seven local city councils have approved resolutions (5) calling for a permanent shutdown and Adjudicated Hearing. These cities have sent their resolutions to the NRC and CPUC. Additionally, two other cities have sent letters of concern and US Sen., Barbara Boxer, has notified NRC of her concerns as well. Predictably, the local press is not giving much coverage, nor asking tough questions, or providing answers and details. There are only three main newspapers in the affected area. The San Diego Union and The North County Times are owned by conservative developer Doug Manchester. The Orange County Register was sold, in July to “2100 Trust LLC.,” a conservative venture capital corporation acquiring a power base in newspapers after selling off five TV stations (6) Coverage in these papers has been minimal, less than complete, and not balanced with the facts presented by concerned citizens groups. Their coverage, and the occasional spotty TV story, frames the controversy as merely an issue of closure versus reopening of the plant.
Substantive examination on whether San Onofre opens again is needed, as is Edison’s role as negligent contributor to the extent of San Onofre’s current problems. The true facts about the steam generators are conspicuously missing from these papers. In this generation of corporate controlled media, what is left out of a story is the best topic of concern when reading the tea leaves of greed and corruption.
Corporate forces do not like being challenged, and are used to getting their way despite public will. This was evident on the faces of the six panelists aligned with Edison. With the dozen speakers having said their piece the moderator ventured into the crowd, choosing the right side of the room first which, thanks to the color coding of the Edison employees, was staunchly pro-Edison. This provided a nice opportunity for grandstanding by several union reps who skirted the entire issue by extolling the virtues of their hard-working members, and their pride in representing them. Of course the only rational here was their own, current, jobs not a long term nuclear disaster for 8.4 million people, who cannot get insurance coverage. Wild cheers came from the colored shirts as they rose in tribute, collectively missing the point.
After over an hour the mic- wielding moderator allowed questions from the left side of the room. Again, and again, citizens asked about the steam generators, their previous demand for an Adjudicated Hearing, the plant’s horrible safety record, and the lack of local demand for San Onofre power. Most came prepared with facts which came from recent NRC statistics and reports.
Responses from the six, pro-nuclear, panelists relied on vague assurances about their years of experience in the nuclear industry. Despite NRC spokesman Elmo Collins admission that both plants were shut down, “due to significant and unprecedented wear” he and his cadre offered no counter facts to rebut the accusations and questions about the steam generators. “I worked at the plant for 30 years without problems”, stated Dan Dominguez a union leader also missing the point. Edison chief engineer, Pete Dietrich, downplayed factual challenges by repeatedly referring to “his experience” in nuclear plants across California. “Delays are hurting the economy”, lied Richard McPherson, City Councilman from Laguna Beach, who was obviously not representing his constituency, and in reality a mole for the nuclear industry. McPherson is Executive Vice President of DownRange Global Solutions, a corporation which, according to their official website,is heavily involved in the nuclear industry.(7) “Workers would not want to work there if there were more problems,” he continued. McPherson was ignoring NRC evidence that San Onofre has the nation’s worst record for “employee harassment and retaliation” of all US nuclear power plants.(8)
Former San Diego city attorney Mike Aguirre asked Elmo Collins why it seemed “necessary to file a federal lawsuit” in order to get the NRC to provide the Adjudicatory Hearing and public review. Collins assured the crowd that the five appointed NRC commissioners would “make a fair decision”. Perhaps, but already friends of the Earth and the National Resources Defense Council have filed a petition to have this NRC board require the Adjudicated Hearing. The result was that NRC staff recommended denying the petition. For the past three months there has been no response from the NRC board. Considering the obvious bias, lack of specific knowledge, willingness to pontificate without any experience, or blind allegiance to Edison of this evening’s Edison representatives, the fact that the NRC board remains silent is very ominous indeed. Sadly, the silence may predict the outcome. And be the precursor to America’s own Fukushima.
It takes three of the five NRC commissioners to vote in favor of an Adjudicated Hearing. Looking at the track record of three of these commissioner’s efforts to back up nuclear owners at every chance shows the minimal chance the public has of getting the required votes for the, much needed, hearing.
Three of the five commissioners have checkered pasts regarding their willingness to regulate nuclear plants under their watch. William D. Magwood was previously a manager of nuclear programs for Edison, during San Onofre’s many previous problems, before doing a stint with Westinghouse, the company that manufactured the steam generators before its sale to Mitsubishi. He became an NRC Commissioner in 2010 after several more years with two energy producing companies, Advanced Energy Strategies, and Secure Energy Incorporated.
Kristine L. Svinicki was categorized by Speaker of the Senate, Harry Reid, as having “an abysmal record on nuclear safety demonstrating that she puts the interests of the nuclear industry ahead of the safety of American citizens”. Reid, who excoriated Svinicki at her Senate confirmation, was ignored by corporate controlled Senators, who voted for her confirmation as commissioner.
Commissioner William Ostendorff is currently under federal investigation. As reported by Huffington Post, on August 15, 2012, the Inspector General at the NRC has launched an investigation into Ostendorff’s role in attempting to thwart an agency probe into safety concerns at a Michigan plant.
In late May, Gregory Jaczko, then the chairman of the NRC, paid a rare visit to the controversial Palisades Power Plant on Lake Michigan. While Jaczko, who is no longer with NRC, was touring the plant on May 31st, a significant leak of potentially radioactive water was pouring into the control room. Less than two weeks later, the plant was shut down to repair the leak. Yet Jaczko was never made aware of the issue while inspecting the plant. He asked the NRC’s Office of Investigations to look into why the leak was kept from him.
Commissioner William Ostendorff, however, wanted no such investigation to take place. According to witnesses shortly after Jaczko ordered it, Ostendorff shouted at the top agency investigator, Cheryl McCrary, in front of several NRC employees. He told her that the inquiry should be halted and that it was a “waste of agency resources.” To date, despite Senate confirmation of new NRC chairperson, Allison M. MacFarlane, no further actions have taken place against Ostendorff.
NRC allegiance to the public safety will be put to the test in three weeks due to another NRC regulation. In the first week of November San Onofre will have been off-line for nine months. According to Gene Stone, as of this date CPUC must file an “Order Instituting an Investigation.” This would trigger a formal Hearing process somewhat similar to an Adjudicated Hearing with an Administrative Judge and testimony under oath. Considering that this will also require Edison to return the $660 million dollar over-charge to the ratepayers, it is a safe bet that further skullduggery is afoot in a further attempt to violate the NRC’s own laws and screw the public.
The conspiracy to defraud the public of their safety, by NRC, CPUC and Edison collusion would seem unstoppable. So does a nuclear disaster.
After four hours the crowd was about one quarter its original size. The buses had left. Stalwart activists continued to needle Elmo Collins, Randolpf, and Oglesby, who continually deferred to Pete Detrick who differed to his voluminous experience. As it neared10 PM the meeting finally adjourned. All questions had been asked at least twice. There were still very few answers.
In our era of ever increasing corporate dominance over citizens, and governmental agencies, the terrifying saga that is the San Onofre Nuclear Generating Station shows the monstrous lack of concern for public safety, citizen’s rights, and the law. The fight to keep these two reactors shut down will continue at a CPUC meeting on Oct 25, 2012 at Irvine City Hall regarding the Order Instituting an Investigation. Here another public charade of democracy will, likely, occur.
Fortunately, the populous of southern California is slowly waking up to its own risk at the hands of Edison. The opposition to this corporate greed and governmental corruption is committed and organized. This story is likely to get worse. The fight will intensify. America must come together to finally stop this potential disaster. America’s own Fukushima moment seems eminent.
Note: Concerned Citizens are encouraged to contact the five NRC commissioners and demand an Adjudicatory Hearing. Their contact information is below.
Chairman Allison M. Macfarlane: Tel
: 301-415-1750 E-Mail: Chairman@nrc.gov
Commissioner Kristine L. Svinicki: Tel: 301-415-1855 E-Mail:
CMRSVINICKI@nrc.gov (She is on Facebook, too: Kristine Svinicki — you can Message her w/o being Friends.)
Commissioner George Apostolakis: Tel: 301-415-1810 E-Mail: CMRAPOSTOLAKIS@nrc.gov
Commissioner William D. Magwood: Tel: 301-415-8420 E-Mail:
Commissioner William C. Ostendorff: Tel: 301-415-1800 E-Mail:
2) Nuclear Regulatory Commission allegation statistics
4)2/10/12 CA Public Utilities Commision:Administrative Law Judge Ruling Attachment A, pages 17-19
5)Del Mar, Encinitas, Irvine, Laguna Beach, Mission Viejo, Santa Monica, Solana Beach
8) Nuclear Regulatory Commission Discrimination Allegation Statistics