- Prepared Direct Testimony of Donna Gilmore, July 15, 2015
(see other major sections below for opening testimony containing cost analysis, evidentiary hearings and Judge Maribeth Bushey decision.)- Prepared Direct Testimony of Donna Gilmore, July 15, 2015
- Table of Contents, Attachment and Footnote Index
- Attachment 1 – Statement of Witness Qualifications
- Attachment 2 – SCE Response to Data Request Gilmore-SCE 047
- Attachment 3 – List of Approved Spent Fuel Storage Casks: Holtec International Notice of Final Rule HI-STORM Underground Maximum Capacity [UMAX] Canister Storage System, Certificate of Compliance No. 1040, Federal Register Volume 80, Number 44, March 6, 2015, Pages 12073-12078
- Attachment 4 – NRC Safety Evaluation Report, HI-STORM UMAX Canister System, April 6, 2015, Docket No. 72-1040, pp 2 – 7 ML15093A510
- Attachment 5 – HI-STORM FW FSAR Non-Proprietary, Revision 2, February 18, 2014, Page 3-39 (ML14052A369)
- Attachment 6 – HI-STORM UMAX Canister Storage System (MPC-37, MPC-89), Preliminary SER, Certificate of Compliance No. 1040, Proposed Rule Supporting Information (CoC, Tech Specs, SER) (72-1040) (TAC No. L24664). 9/4/2014, page 6 ML14122A441
- Attachment 7 – San Onofre Nuclear Generating Station, Units 1, 2, 3 and Independent Spent Fuel Storage Installation (ISFSI) Inspection Report, 05000361/2014007, 05000362/2014007, and 07200041/2014001, NRC, February 13, 2014 (ML14045A317)
- Attachment 8 – SCE Response to Gilmore-SCE Question 48
- Attachment 9 – List of Approved Spent Fuel Storage Casks: Holtec International HI–STORM UMAX Canister Storage System, Certificate of Compliance No. 1040, Amendment No. 1, Federal Register, pp 35829- 35833, Vol. 80, No. 120, June 23, 2015
- Attachment 10 – Aging Management Program Example for Stress Corrosion Cracking, Dunn Darrell S. Dunn, Meeting to Obtain Stakeholder Input on Potential Changes to Guidance for Renewal of Spent Fuel Dry Cask Storage System Licenses and Certificates of Compliance, July 14, 2014 , slides 2, 15 ML14192A702
- Attachment 11 – Input to SNL Report on the Composition of Available Data for Used Nuclear Fuel Storage and Transportation Analysis, M. Sutton, J. Wen, Lawrence Livermore National Laboratory, LLNL-TR-659020, August 19, 2014, PP 3-5
- Attachment 12 – NUREG-1927, Rev 1 – Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel, revised 6/29/2015 ML15180A011
- Attachment 13 – Material Diagnostic of the Pressure Equipment in the Aspects of the New Prescriptions, Ewa Hajewska, et. al, IAE Annual Report 1999, page 32
- Attachment 14 – Declaration of Donna Gilmore – Singh comments at CEP meeting
- Attachment 15 – Understanding the Environment on the Surface of Spent Nuclear Fuel Containers, Charles R. Bryan and David G. Enos, Sandia National Laboratories, June 2014
- Attachment 16 – Data Report on Corrosion Testing of Stainless Steel SNF Storage Canisters, Sandia Lab, September 30, 2013, page V
- Attachment 17 – Cracked: The Secrets of Stress Corrosion Cracking, Hira Ahluwalia, President of Material Selection Resources Inc. (MSR) Page 3
- Attachment 18 – The Pacific Energy Center’s Guide to California Climate Zones, October 2006, Zone 7 pp. 1 – 4
- Attachment 19 – NRC Information Notice 2012-20: Potential Chloride-Induced Stress Corrosion Cracking of Austenitic Stainless Steel and Maintenance of Dry Cask Storage System Canisters, November 14, 2012 , Page 1 and 2 ML12319A440
- Attachment 20 – FY14 DOE R&D in Support of the High Burnup Dry Storage Cask R&D Project, William Boyle, DOE, NWTRB Meeting, August 6, 2014 (slide 12)
- Attachment 21 – Update on In-Service Inspections of Stainless Steel Dry Storage Canisters, EPRI, Keith Waldrop, Senior Project Manager, Presented by John Kessler, Program Manager, NEI-NRC Meeting on Spent Fuel Dry Storage Cask Material Degradation, January 28, 2014 (Diablo slides 17-19) ML14052A430
- Attachment 22 – Chloride-Induced Stress Corrosion Cracking Tests and Example Aging Management Program, Darrell S. Dunn, August 5, 2014, Slide 9
- Attachment 23 – NRC Meeting Summary of August 5, 2014, Public Meeting with the Nuclear Energy Institute on Chloride Induced Stress Corrosion Cracking Regulatory Issue Resolution Protocol ML14258A081
- Attachment 24 – Environmentally induced transgranular stress-corrosion cracking of 304L stainless steel components at Koeberg, Basson, J.P. (Eskom, Koeberg Nuclear Power Station, Melkbosstrand, Cape Town (South Africa)); Wicker, C. (TSI, Koeberg Nuclear Power Station, Melkbosstrand, Cape Town (South Africa))
- Attachment 25 – SCE Response to data request Gilmore-SCE 119
- Attachment 26 – Official Transcript of Proceedings, NUCLEAR REGULATORY COMMISSION, Expert Panel Workshop on Degradation of Concrete in Spent Nuclear Fuel Dry Cask Storage Systems, February 24, 2015, Pages 335-351
- Attachment 27 – NRC Generic Concrete Aging Management Program, Ricardo D. Torres, July 14, 2014, Slide 3 ML14227A364
- Attachment 28 – Available Methods for Functional Monitoring of Dry Cask Storage Systems, Xihua He, et.al., Executive Summary, page ix L14323A067
- Attachment 29 – Rancho Seco NRC Inspection Report, August 31, 1999, page 11
- Attachment 30 – ML032260147 – Rancho Seco Post Shutdown Decommissioning Activities Report, Amendment 4, 7/31/2003, Page 3
- Attachment 31 – NRC Inspection Report 05000312/2013007 and 07200011/2013001, August 22, 2013, Attachment 2 Loaded Canisters at Rancho Seco ISFSI ML13235A252
- Attachment 32 – Unit 2 San Onofre Reactor Data (DOE Form GC-859 Schedule C)
- Attachment 32A – Unit 3 San Onofre Reactor Data (DOE Form GC-859 Schedule C)
- Attachment 33 – Conceptual Project Assessment, Spent Fuel Pool Island Project, CPA NO. 97-42, October 1997, P. 9
- Attachment 34 – A Project Concept for Nuclear Fuels Storage and Transportation, June 15, 2013, Page 38
- Attachment 35 – From [Florida Public Service] PSC Staff to Commission Docket No. 140113-EI – Petition for approval to construct an independent spent fuel storage installation [at Crystal River] and an accounting order to defer amortization pending recovery from the Department of Energy, by Duke Energy Florida, Inc. , December 4, 2014 Page 4
- Attachment 36 – SCE Response to Gilmore-SCE 079
- Attachment 37 – SCE Response to Gilmore-SCE Question 63
- Attachment 37A – Department of Energy, Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level Radioactive Waste, January 2013, pp. 5-8
- Attachment 37B – H.R. 2028, H.Rept. 114-91 pp 92-95
- Attachment 38 – Civilian Nuclear Waste Disposal, RL33461, Mark Holt, Congressional Research Service, April 24, 2015, Page 30
- Attachment 39 – SCE Response to data Request Gilmore-SCE 109
- Attachment 40 – SCE Response to data request Gilmore-SCE 54
- Attachment 41 – SCE Response to Data Request Gilmore-SCE 070
- Attachment 42 – Email reply from SCE Robert Munger to Energy Solutions Mike S. Williams, January 27, 2014
- Attachment 43 – SCE Response to Gilmore-SCE 139
- Attachment 44 – SCE Response to Gilmore-SCE 140
- Attachment 45 – SCE Response to Gilmore Q. 67
- Evidentiary Hearing Transcripts
- Evidentiary Hearing Gilmore Exhibits
- Gilmore Opening Brief, October 15, 2015 (includes cost analysis)
Alternate link to Gilmore Opening Brief, October 15, 2015
Pursuant to Rule 13.11 of the Commission’s Rules of Practice and Procedure, Donna
Gilmore submits her Opening Brief in proceeding A.14-12-007. For the reasons set forth below, the Commission should: (1) adopt Ms. Gilmore’s proposed modifications to DCE’s cost estimate for the Independent Spent Fuel Storage Installation (ISFSI) to account the system’s uncertain lifespan and the DOE’s uncertain pickup date; (2) deny SCE’s procedural proposal for handling future SONGS decommissioning expenses as it applies to construction projects; and (3) find that the DCE does not provide an adequate basis for authorizing the withdrawal or expenditure of
Decommissioning Trust funds on construction projects.
Donna Gilmore presented testimony and filed briefs on meritorious issues related to nuclear power that were outside the scope of this proceeding.
San Onofre Safety 