Southern California Edison (SCE) has served a formal Notice of Dispute on Mitsubishi Heavy Industries, Ltd., and Mitsubishi Nuclear Energy Systems (together, “Mitsubishi”) which seeks to hold Mitsubishi accountable for designing and manufacturing defective Replacement Steam Generators (RSGs) at the San Onofre Nuclear Generating Station (SONGS). “Our action is about making sure that Mitsubishi takes responsibility for providing the defective steam generators that led to the closing of SONGS,” said Ron Litzinger, president of SCE. Although Mitsubishi warranted the generators would operate reliably for 20 years, SCE was required to take SONGS offline in January 2012 when one of the Mitsubishi RSGs experienced a radioactive coolant leak after less than a year of operation. Although its contract with SCE required Mitsubishi to repair the RSGs “with due diligence and dispatch,” SCE’s Notice of Dispute alleges that Mitsubishi failed to do so. Facing continued uncertainty about restoring SONGS to service at any level of power, SCE permanently retired the plant as of June 2013. SCE alleges that Mitsubishi, as designer and manufacturer of the faulty RSGs, is responsible for the enormous harm its failures have caused to California ratepayers, SCE, and the other SONGS owners. When SCE contracted with Mitsubishi to replace the SONGS steam generators, it did so to extend the life of SONGS so that the plant could continue to provide safe, reliable and affordable power to over 1.4 million homes in Southern California. However, SCE’s Notice of Dispute claims that Mitsubishi seriously breached the Contract, totally and fundamentally failing to deliver what it promised. SCE alleges that Mitsubishi grossly failed to appropriately model the thermal hydraulic conditions in the RSGs, including the relative wetness of the steam/water mix in the RSGs (“void fraction”) and the speed of the steam/water flow within the RSGs (“fluid velocity”).