BACKGROUND

The Philadelphia Electric Co. and British Energy have formed a company named Amergen, whose purpose is to buy, at garage sale prices, and operate troubled U.S. nuclear reactors. Already, this company has successfully bid on the Three Mile Island-1 reactor in Pennsylvania; the Nine Mile Point-1 and –2 reactors in New York; the Clinton reactor in Illinois; and the Oyster Creek reactor in New Jersey. Amergen is also considering buying the Vermont Yankee reactor. In each case, Amergen has offered only pennies on the dollar. It’s an approach that’s profitable for the nuclear utilities involved, since they want to get rid of their reactors, but that leaves ratepayers high and dry.

In September 1999, Philadelphia Electric announced that it would merge with the largest and most troubled nuclear utility in the U.S., Unicom of Illinois (formerly Commonwealth Edison). If the merger is approved, this new company would control on its own 14 nuclear reactors and 17% of the nation’s nuclear electricity.

But the new company would still only be equal partners in Amergen with British Energy, which itself controls 11 nuclear reactors and 20% of Great Britain’s electric supply.

An August 1999 report from Britain’s nuclear regulators, the Nuclear Installations Inspectorate (NII), sheds considerable light upon what we can expect from Amergen in the U.S. The report has never officially been made public, but was obtained by Friends of the Earth UK, and made available to Washington’s Nuclear Information and Resource Service (NIRS).

British Energy took over Britain’s previously publicly-owned nuclear plants in 1996. According to the NII report, the new utility immediately began downsizing its nuclear operations, laying-off some 20% of its workforce.

BRITISH ENERGY AND NUCLEAR SAFETY

According to British regulators, British Energy’s downsizing has seriously compromised nuclear safety. In key safety-related areas, including "forensic metallurgy…PWR [pressurized water reactor] materials, irradiation embrittlement, seals, graphite, criticality, fire and radiation chemistry" there is only a single person, utility-wide, expert on these issues. In one critical area, "expertise in severe accidents" the layoffs have left the utility without a single expert to advise reactor operators.

Perhaps even more dangerously, a section of the report never intended for public dissemination indicates that British Energy plans even more layoffs—of some 300 people. According to the NII, "the technical basis for continuing staff reductions was not clear to us but it could be related to the requirement to compete in the commercial market place." The report says that British Energy sees "poor performance" by its contractors not as safety-related issues, but "in commercial terms."

The report says that British Energy, having laid-off much of its workforce, places much reliance on its contractors. But the NII found that at one of the utility’s prime contractor’s, a company called Mott MacDonald, "not all the partnership staff...are fully qualified and experienced to perform the necessary analyses, nor are they fully familiar with the nuclear plants they are expected to undertake work on." And the NII faulted British Energy for not exercising control over its contractors. For example, the report states that "at no level within the company did we find a clear policy on why, when and how to use contractor expertise….Only when this has been defined can the intelligent customer role be fully developed."

The report states that British Energy does not make its employees adequately check contractor work. For example, the utility’s "procedure merely requires its staff to check whether the work done meets the original specifications. Indeed in some areas we found staff checking work without access to the original specifications."

In another critical area, the NII states that British Energy’s "vision to become world class" on radiological protection standards "may be misleading because the dose targets are set for PWRs and are easily attainable by the AGR design." In plain English, this means that the gas reactors British Energy operates produce lower radioactive emissions for plant workers than the single Pressurized Water Reactor the utility runs, and using the higher average dose rate means it is easier to comply with dose targets. Of particular importance to the U.S. is that nearly all of the reactors Amergen wants to purchase are Boiling Water Reactors, which generally produce higher worker radiation exposures than PWRs.

The NII adds that Britain’s reliance on "non-prescriptive regulation" has led British Energy into thinking that it is ok to operate in this fashion. This type of regulation, also called "performance-based" is championed by the current U.S. NRC and its chair, Greta Dicus.

BRITISH ENERGY AND OVERTIME

The NII report found that many, perhaps most, of the utility’s remaining workers are putting in substantial overtime. According to the report, even in "urgent safety situations" workers put in an extra 20% (or one full day per week) of overtime. In some divisions, such as Engineering and Health Safety and Environment, overtime runs at 60%.

The NII found that overtime is substantially underreported, and actual overtime is much higher. Concluded the NII, we "are of the opinion that a long hours cultures exists…especially in areas where work pressures were high. We believe these data are indicative that resource levels have been reduced too far in a variety of areas and this cannot be good for nuclear safety."

COMPETITIVE PRESSURES

The NII report is replete with references that indicate much of the reason British Energy operates the way it does is because of competitive pressures with other energy sources and utilities. But in the United States, under a deregulated and restructured utility environment, competitive pressures will be much higher than in Britain, where only a few companies monopolize electricity production and distribution.

For example, the report states that British Energy sees poor performance by its contractors not as nuclear safety issues, but "in commercial terms." Worker lay-offs are seen by British Energy as necessary for "competitive" reasons.

And the top management of the utility is harshly criticized for not even understanding the difference between normal commercial industries and nuclear power utilities, much less having a clear grasp of nuclear safety issues.

LESSONS FOR THE U.S.

British Energy is placing electric power production above safety—an attitude which in the United States consistently has led reactors to the NRC’s (now-abandoned) problem plants list. This is purely and simply the most unforgivable attitude that can be adopted by nuclear reactor operators.

British Energy is one-half of Amergen, which is seeking to buy up America’s unwanted nuclear reactors. The other half of Amergen is Philadelphia Electric—recipient of one of the highest nuclear-related fines in U.S. history when operators at its Peach Bottom nuclear complex were found sleeping and playing computer games on the job. Philadelphia Electric wants to merge with the troubled Unicom utility, most of whose reactors have been considered "problem plants" for years.

The end result for the U.S.: a multinational utility, with no loyalties to the public, with a demonstrated record of improper nuclear operations, of laying off nuclear workers, of reducing nuclear safety margins—of threatening the public, all for a quick buck, since most of these reactors will operate, at best, for only a few years more.

We can stop them. We can stop these sales, close these unnecessary and dangerous reactors, and make Amergen wish it had never been invented. But we can’t do it alone: we need your help too. For more information, contact the Citizens Awareness Network at 413-339-5781, can@shaysnet.com or Nuclear Information and Resource Service, 202-328-0002, nirsnet@nirs.org. –Michael Mariotte, September 25, 1999.