ML12346A484

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Petitioner'S Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure
ML12346A484
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 12/11/2012
From: Ayres R, Olson J, Gladd K
Ayres Law Group, Friends of the Earth
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23871, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01
Download: ML12346A484 (28)
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Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )

)

(San Onofre Nuclear Generating Station, ) December 11, 2012 Units 2 and 3) )

)

PETITIONERS MOTION TO AMEND THE PROPOSED SCHEDULING ORDER AND CLARIFY SCOPE OF DISCLOSURE Petitioner Friends of the Earth (FoE) moves the Atomic Safety and Licensing Board (Licensing Board or Board) to clarify the scope of disclosure of documents and extend the briefing schedule proposed in the Boards December 7, 2012 Order. Consistent with that Order, Petitioner has attempted to negotiate an agreement among the parties that would (1) identify the proprietary documents the Board has ordered Respondent Southern California Edison Company (SCE) to provide the Board and the other parties; and (2) give a modest amount of time prior to briefing to allow counsel and their expert to review and evaluate the documents to be made available under the Boards Order. Unfortunately, these negotiations have been unsuccessful. In response to a proposal from Petitioner, Respondent has taken a very narrow view of its responsibilities to share proprietary documents and refused to consider any additional time for review of the proprietary documents the Board has ordered released to the Board and the parties.

Counsel for SCE oppose this motion. Counsel for NRC Staff do not oppose the Board ordering SCE to provide the documents requested in this motion, except with respect to the 1

documents related to the Augmented Inspection Team report,1 nor do counsel for NRC Staff oppose a reasonable extension of time for Petitioner to file their initial brief.

BACKGROUND On November 8, 2012, the Nuclear Regulatory Commission (NRC or Commission) issued decision CLI-12-20 referring to the Atomic Safety and Licensing Board Panel a portion of Friends of the Earths (FoE) June 18, 2012 intervention petition. FoEs petition related to a March 27, 2012 Confirmatory Action Letter (CAL) issued by the Commission to SCE. On December 3, 2012, the participants in this proceeding, SCE, FoE, and the NRC Staff, participated in a conference call with the Licensing Board established for this proceeding to discuss scheduling and management issues.

On December 7, 2012, the Licensing Board issued an Order that directed SCE to disclose to the Board and FoE the numerous proprietary documents referred to in SCEs response to the CAL and . . . documents generated pursuant to the CAL in SCEs Restart Plan. Order at 4. The Order also contained a Proposed Scheduling Order, and invited the parties to negotiate an alternative schedule if the proposed schedule does not provide adequate time to prepare thorough, high-quality briefs. Order at 5.

CLARIFICATION OF THE SCOPE OF DISCLOSURE In its December 7 Order, the Board directed SCE to make broad disclosure of proprietary versions of documents generated pursuant to the CAL in SCEs Restart Plan and the proprietary versions of the documents referred to in SCEs response to the CAL. Order at 4

[emphasis supplied]. These two groups - documents referred to in SCEs response to the CAL 1

Counsel for NRC Staff do oppose what they describe as discovery against the government. Petitioners view is that its request is not a discovery request, but rather a clarification of items the Board has already ordered to be produced.

2

and the documents generated pursuant to the CAL - are, in the Boards view, necessary to determine . . . whether the CAL itself is a de facto license amendment. Order at 4.

Based on an exhaustive review of the publicly available documents provided and referred to by SCE in its response to the CAL and restart plan, Petitioners experts have identified proprietary documents relied upon, but either redacted or simply referred to, in support of SCEs response to the CAL and restart plan. Since these documents are quoted or referred by SCE in support of the companys response to the CAL and restart plan, there can be no argument regarding their relevance to this proceeding. As the Board noted, these documents, incident to and subsequent to the CAL . . . will inform the Boards understanding of the CAL and its effect.

Order at 3.

Respondent will no doubt make the argument that the publicly available documentation for the CAL response and restart plan is sufficient for Petitioner to understand the issues under consideration by the Board. The Board has made clear that it does not agree with this position.

Much of the CAL response includes conclusory statements based on analyses and data from proprietary documents included by reference, but unavailable to Petitioner without disclosure by SCE. In order to illustrate for the Board the types of relevant information that is currently unavailable to the Petitioner and the Board, Petitioner notes the following:

  • SCE claims to have benchmarked its analysis of whether 70% power would be safe by reference to another reactor, simply labeled Reactor A. To date, SCE has not revealed the identity of Reactor A. Neither the Board nor Petitioner will be able to assess whether running San Onofre Unit 2 will cause a more than minor increase in the risk of damage to the steam generator unless we know the identity of Reactor A.

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  • At its December 7, 2012 public meeting with SCE, the NRC Staff inquired whether SCE had performed a Section 50.59 analysis of all the matters associated with the CAL response. SCE replied it had. In light of Question (iii) in the Boards Order, requesting the parties to address the extent to which the standards in 10 CFR § 50.59(c)(1) and (c)(2) apply, it is obvious that SCEs Section 50.59 analysis is directly related to the CAL response and the restart plan and must be made available to the Board and the parties.
  • The Board has asked (Question (iv)) whether the Final Safety Analysis Report (FSAR) analyzed a steam generator tube failure event, and directed that a copy be provided to the parties and the Board of the relevant section(s) of the FSAR. On December 10, 2012, a representative of FoE sought to obtain the most recent version (dated 2009 and subsequently revised) of the FSAR for San Onofre. An extensive search by an NRC librarian was unable to locate the most recent version of the FSAR even on the NRCs internal server, which contains documents that may not be publicly available on the NRCs ADAMS database.

Appended to this motion is a list of specific proprietary documents directly associated with or quoted or referred to by SCE in the response to the CAL and restart plan. These documents fall into three categories:

1. Documents included in the categories referred to in footnotes 5 and 6 on page 4 of the Boards December 7, 2012 Order;
2. Documents directly associated with, quoted, redacted, or referred to in support of the conclusions of the SCE response to the CAL and restart plan that are necessary in order for Petitioners experts to analyze and answer questions (iv) -

(vii) posed by the Board in its December 7 Order, and other documents that are 4

necessary to determine . . . whether the CAL itself is a de facto license amendment. Order at 4;

3. Relevant SCE proprietary documents referred to in the Augmented Inspection Team Report.

Respondent SCE agrees that it is obligated to provide documents in Category 1. Petitioners experts have identified the specific documents listed in Categories 2 and 3 as relevant and probative with respect to the questions put by the Board, and the two issues referred by the Commission.

FoE therefore requests the Board to direct SCE and NRC Staff to disclose to FoE the propriety documents listed in the attachments. These documents are necessary to address the questions posed by the Board.

NEED FOR REVISION OF PROPOSED SCHEDULE The proprietary documents requested by Petitioner contain a large amount of technical information that has not been made available to FoE and that is directly relevant to the questions before the Board. In its Order, the Board recognized that:

(1) [T]he issues underlying the questions referred by the Commission are several and complex, and (2) there are numerous proprietary documents that Friends of the Earth has not yet seen that, when released by SCE, will require time by counsel and their experts to review and evaluate.

Order at 5.

Additionally, the Board observed that this case will proceed with greater dispatch if the participants provide the Board with thoughtful, well analyzed, and well-written briefs. Id.

Unless FoE is given time for its experts to review the proprietary documents the Board has directed SCE to provide, FoE will not be able to prepare the thorough, high quality briefs the 5

Board wishes to receive. As of this date, the Petitioners brief would be due under the Boards proposed schedule in only 10 days. SCE has so far delivered no documents under the Boards Order. Unless the due date for the opening brief is extended, it is not clear that Petitioner will have any meaningful opportunity to review the proprietary documents the Board wished Petitioner to see.

Therefore, FoE respectfully requests that time be provided to allow for expert review of these documents prior to preparation of briefs. FoE proposes to allow a three-week period to review disclosed documents, beginning when the documents have been disclosed. Briefing would begin three weeks after that, on a schedule identical to the one proposed by the Board.

For example, if all the documents were disclosed to FoE by December 14, 2012, the schedule would be as follows:

January 4, 2013 Review of documents January 25, 2013 Brief for Petitioner February 1, 2013 Brief for Amicus February 15, 2013 Brief for Respondent February 15, 2013 Brief for NRC Staff February 22, 2013 Reply brief for Petitioner The proposed schedule would not unduly delay the proceeding and is necessary to allow for thoughtful and accurate determination of the issues by the Board.

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Signed (electronically) by Richard Ayres Richard E. Ayres Jessica L. Olson Kristin Hines Gladd Ayres Law Group 1707 L St., N.W., Suite 850 Washington, D.C. 20036 Phone: 202-452-9200 E-mail: ayresr@ayreslawgroup.com; olsonj@ayreslawgroup.com; gladdk@ayreslawgroup.com Counsel for Friends of the Earth Dated in Washington, D.C.

this 11th day of December 2012 7

Attachment UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

E. Roy Hawkens, Chairman Dr. Anthony J. Baratta Dr. Gary S. Arnold In the Matter of Docket Nos. 50-361-CAL, 50-362-CAL SOUTHERN CALIFORNIA EDISON CO.

ASLBP No. 13-924-01-CAL-BD01 (San Onofre Nuclear Generating Station, Units 2 and 3) December __, 2012 MEMORANDUM AND ORDER Upon consideration of the December 11, 2012 Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure by Petitioner Friends of the Earth (FoE), we GRANT the Motion and issue this Amended Briefing Schedule and clarification to govern the adjudication of the issues referred by the Commission (CLI-12-20) to the Atomic Safety and Licensing Board (ASLB) on November 8, 2012 regarding a March 27, 2012 Confirmatory Action Letter (CAL) issued by the Nuclear Regulatory Commission (NRC) to SCE.

The Board recognizes that (1) the underlying issues in this matter are numerous and complex and (2) in order to prepare thoughtful, well-analyzed, and well-written briefs, the parties will need adequate time to disclose and consider the numerous proprietary documents ordered to be made available to the parties under a Non-Disclosure Agreement. We hereby order that the documents to be disclosed shall include those documents described in the lists appended to 1

Attachment Petitioners December 11, 2012 Motion, as well as SCEs analysis of its restart plan performed pursuant to 10 C.F.R. § 50.59.

The Board also hereby amends the Proposed Scheduling Order to allow for a three-week review period after all parties receive all documents ordered to be disclosed in this Order. For example, if all the documents were disclosed to FoE by December 14, 2012, the schedule would be as follows:

January 4, 2013 Review of documents January 25, 2013 Brief for Petitioner February 1, 2013 Brief for Amicus February 15, 2013 Brief for Respondent February 15, 2013 Brief for NRC Staff February 22, 2013 Reply brief for Petitioner It is so ORDERED.

FOR THE ATOMIC SAFETY AND LICENSING BOARD E. Roy Hawkins CHAIRMAN Rockville, Maryland December __, 2012 2

Attachment ATTACHMENT 1 DOCUMENTS DIRECTLY ASSOCIATED WITH, QUOTED, REDACTED, OR REFERRED TO IN SUPPORT OF THE CONCLUSIONS OF THE SCE RESPONSE TO THE CAL AND RESTART PLAN Table 1 Redacted Documents in ADAMS ML122850320 ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT ML12285A263 - San Onofre Nuclear Generating Station, Unit NRC ADAMS ML122850320 1 2 - Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation. (134 page(s), 10/3/2012)

ML12285A264 - Attachment 3 - AREVA Document 51- NRC ADAMS ML122850320 9180143-001 - SONGS Unit 3 February 2012 Leaker Outage 2

Steam Generator Condition Monitoring Report. (100 page(s),

10/1/2012)

NRC ADAMS ML122850320 ML12285A265 - Attachment 4 - MHI Document L5-04GA564 3 - Tube Wear of Unit-3 RSG, Technical Evaluation Report. (142 page(s), 10/1/2012)

ML12285A266 - Attachment 4: Appendix-2 Attachment-1, NRC ADAMS ML122850320 4 Tube-to-TSP wear depth diagram for Unit-2/3. (226 page(s),

10/1/2012)

ML12285A267 - Attachment 4: SG Tube Wear Analysis for NRC ADAMS ML122850320 5

Unit-2/3. (239 page(s), 10/1/2012)

ML12285A268 - Attachment 6 - Appendix B: SONGS U2C17 - NRC ADAMS ML122850320 6 Steam Generator Operational Assessment for Tube-to-Tube Wear. (105 page(s), 10/2/2012)

ML12285A269 - Attachment 6: Appendix A: Estimates of FEI- NRC ADAMS ML122850320 7

Induced TTW Rates. (209 page(s), 10/2/2012)

Peter T. Dietrich, Senior Vice President &

Chief Nuclear Officer, SCE, Letter to Elmo Enclosure 2 - San Onofre Nuclear Generating Station Unit 2 E. Collins, Regional Administrator, Region 8 Return To Service Report October 3, 2012 IV, US NRC, Docket No. 50-361, [CAL] -

Actions to Address Steam Generator Tube Degradation [SONGS], Unit 2 (Oct. 3, 2012) 1

Attachment Table 2 Documents Needed to Address ASLB Factual Issue (iv)

SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE San Onofre 2&3 FSAR Updated NRC AIT Inspection Report 9 05000361/2012007 and 05000362/2012007 SONGS Steam Generator Program ENCLOSURE 2, San Onofre 10 (SO23-SG-1) Nuclear Generating Station 10 Unit 2 Return to Service Report, SCE October 3 1012 SONGS Technical Specifications 1) ATTACHMENT 2, AREVA 17 Latest amendment Section 5.5.2.11, Steam Generator Document 51-9182368-003, required (SG) Program, SONGS 2C17 Steam Generator Condition 18 Amendment 204 Monitoring Report 11 ATTACHMENT 3, AREVA Document 51-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report ECT Data for Input to Return to Service ATTACHMENT 4, MHI 3.1 and Repair Design Documents (RSG- Document L5-04GA564 Tube P89 SCE/MHI-12-5688), e-mail from SCEs Wear of Unit-3 RSG Mr. Calhoun on March 23, 2012 (JST) Technical Evaluation Report 2 12 ATTACHMENT 5, MHI Document L5-04GA571, Screening Criteria for Susceptibility to In-Plane Tube Motion 2

Attachment TABLE 3 Documents Needed to Address ASLB Factual Issue (v) and (vi)

SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE MHI Document L5-04GA111, San ATTACHMENT 2, AREVA 22 Onofre Generating Station, Units 2 & 3 Document 51-9182368-003, SONGS 13 Replacement Steam Generators Vendor 2C17 Manual, Rev 6 (SONGS Document Steam Generator Condition SO23-617-1-M1273, Rev 6) Monitoring Report MHI, SONGS Unit 2 & 3 RSGs, ATTACHMENT 3, AREVA 12 Regulatory Guide 1.121 Analysis, Document 51-9180143-001 SONGS 14 SO23-617-1-C1262, Rev. 4 Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report AREVA Document 03-9180130-000, ATTACHMENT 3, AREVA 22 SONGS 3F16B SSI Final Report Document 51-9180143-001 SONGS 15 Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report MHI report, Case study of the input ATTACHMENT 4, MHI Document 5 parameters and tube plugging impact on L5-04GA564 Tube Wear of Unit-3 21) internal SG thermal hydraulic RSG Technical Evaluation Report 16 parameters, L5-04GA566 the latest pg.423 ATTACHMENT 4, MHI Document revision L5-04GA564 Tube Wear of Unit-3 RSG Technical Evaluation Report MHI report, Evaluation of Stability ATTACHMENT 4, MHI Document 6 Ratio for Return to Service, L5- L5-04GA564 Tube Wear of Unit-3 04GA567 the latest revision RSG Technical Evaluation Report SONGS Document SO23-617-1-M1523 Rev. 5, Replacement Steam Generators, 20 Same 17 ATTACHMENT 6 - Appendix B Evaluation of Stability Ratio for Return to document?

SONGS U2C17 Steam Generator Service Operational Assessment for Tube-to-Tube Wear MHI report, Analytical Evaluations for ATTACHMENT 4, MHI Document 10 18 Operating Assessment, L5-04GA585 the L5-04GA564 Tube Wear of Unit-3 latest revision RSG Technical Evaluation Report MHI report, Screening Criteria for ATTACHMENT 4, MHI Document 8 Unredacted 19 Susceptibility to In-Plane Tube Motion, L5-04GA564 Tube Wear of Unit-3 copy L5-04GA571 the latest revision RSG Technical Evaluation Report required SCE project letter, Updated ECT Data ATTACHMENT 4, MHI Document 11 for Input to Return to Service and Repair L5-04GA564 Tube Wear of Unit-3 Design Documents, RSG-SCE/MHI RSG Technical Evaluation Report 20 5749, August 2012 1

ATTACHMENT 5, MHI Document L5-04GA571, Screening Criteria for Susceptibility to In-Plane Tube 3

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Motion

3) L5-04FU001 the latest revision, ATTACHMENT 4, MHI Document 8.3) TO 20)

Component and Outline Drawing L5-04GA564 Tube Wear of Unit-3 P141 1/3 RSG Technical Evaluation Report

4) L5-04FU002 the latest revision, Component and Outline Drawing 2/3
5) L5-04FU003 the latest revision, Component and Outline Drawing 3/3
6) L5-04FU021 the latest revision, Tube Sheet and Extension Ring 1/3
7) L5-04FU022 the latest revision, Tube Sheet and Extension Ring 2/3
8) L5-04FU023 the latest revision, Tube Sheet and Extension Ring 3/3
9) L5-04FU051 the latest revision, Tube Bundle 1/3
10) L5-04FU052 the latest revision, Tube Bundle 2/3
11) L5-04FU053 the latest revision, Tube Bundle 3/3
12) L5-04FU111 the latest revision, AVB assembly 1/9
13) L5-04FU112 the latest revision, AVB assembly 2/9
14) L5-04FU113 the latest revision, AVB assembly 3/9
15) L5-04FU114 the latest revision, AVB assembly 4/9
16) L5-04FU115 the latest revision, AVB assembly 5/9
17) L5-04FU116 the latest revision, AVB assembly 6/9
18) L5-04FU117 the latest revision, AVB assembly 7/9
19) L5-04FU118 the latest revision, AVB assembly 8/9
20) L5-04FU119 the latest revision, AVB assembly 9/9 WJS16263, MHI Test Report of Fluid ATTACHMENT 4, MHI Document 8.30) P141 21 Elastic Vibration L5-04GA564 Tube Wear of Unit-3 RSG Technical Evaluation Report
1) L5-04FU051 Rev.1 Design drawing ATTACHMENT 4, MHI Document 8.10 TO 8) 22 of Tube Bundle 1/3 L5-04GA564 Tube Wear of Unit-3 P363
2) L5-04FU052 Rev.1 Design drawing RSG Technical Evaluation Report 4

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE of Tube Bundle 2/3

3) L5-04FU053 Rev.3 Design drawing of Tube Bundle 3/3
4) L5-04FU108 Rev.3 Design drawing of Tube Support Plate Assembly 3/3
5) L5-04FU111 Rev.2 Design drawing of Anti-Vibration Bar Assembly 1/9
6) L5-04FU112 Rev.1 Design drawing of Anti-Vibration Bar Assembly 2/9
7) L5-04FU118 Rev.3 Design drawing of Anti-Vibration Bar Assembly 8/9
8) L5-04FZ014 Rev.4, Purchase specification of heat transfer tubing Design of AVB, L5-04GA428 Rev.5 ATTACHMENT 4, MHI Document 8.7) 23 L5-04GA564 Tube Wear of Unit-3 P407 RSG Technical Evaluation Report L5-04GA510 the latest revision, Thermal ATTACHMENT 4, MHI Document 22) 24 and Hydraulic Parametric Calculations L5-04GA564 Tube Wear of Unit-3 P423 RSG Technical Evaluation Report L5-04GA565 the latest revision, Selection ATTACHMENT 4, MHI Document 20) 25 of Thermal Hydraulic Analysis (ATHOS) L5-04GA564 Tube Wear of Unit-3 P423 Model RSG Technical Evaluation Report MHI document, L5-04GA401 Rev.7, ATTACHMENT 4, MHI Document 1)

Design Report of the Tubesheet Region L5-04GA564 Tube Wear of Unit-3 P456 26 (Tubesheet, RSG Technical Evaluation Report Extension Ring, Lower Shell, Divider Plate).

MHI document, L5-04GA411 Rev.7, ATTACHMENT 4, MHI Document 2)

Design Report of the Tubes Support Plate L5-04GA564 Tube Wear of Unit-3 P456 27 and Stay RSG Technical Evaluation Report Rod.

MHI document, L5-04GA418 Rev.5, ATTACHMENT 4, MHI Document 3) 28 Design Report of the Tube. L5-04GA564 Tube Wear of Unit-3 P456 RSG Technical Evaluation Report Root Cause Evaluation, San Onofre ATTACHMENT 6 - Appendix A 16 Complete Nuclear Generating Station, Condition SONGS U2C17 Outage - Steam copy, not Report: 201836127, Unit 3 Steam Generator Operational Assessment internet-29 Generator Tube Leak and Tube-to-Tube leaked Wear, Revision 0, 5/7/2012. version, required AREVA Document 51-9182833-002, ATTACHMENT 6 - Appendix B 6 SONGS 2C17 Outage - Steam SONGS U2C17 Steam Generator 30 Generator Operational Assessment Operational Assessment for Tube-to-(SONGS Document 1814-AU651-M0144 Tube Wear Rev. 1) 31 [ REDACTED] , Simulation of Tube-to- ATTACHMENT 6 - Appendix B A.3.1 5

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Tube Impact, Phase 2 Report, June 2012 SONGS U2C17 Steam Generator P129 (AREVA NP Document 38-9191195- Operational Assessment for Tube-to-000). Tube Wear SONGS Drawing SO23-617-1-D507 Rev. ATTACHMENT 6 - Appendix B 9 5, San Onofre Nuclear Generating SONGS U2C17 Steam Generator Station Unit 2 & 3 Replacement Steam Operational Assessment for Tube-to-32 Generators - Design Drawing - Anti- Tube Wear Vibration Bar Assembly 1/9 (MHI Drawing L5-04FU111 Rev. 2).

SONGS Drawing SO23-617-1-D542 Rev. ATTACHMENT 6 - Appendix B 10 9, San Onofre Nuclear Generating SONGS U2C17 Steam Generator Station Unit 2 & 3 Operational Assessment for Tube-to-33 Tube Wear Replacement Steam Generators - Design Drawing - Anti-Vibration Bar Assembly 7/9 (MHI Drawing L5-04FU117 Rev. 9)

AREVA NP Document 51-9188725-000, ATTACHMENT 6 - Appendix B 14 SONGS U2C17 and U3F16B AVB Gap SONGS U2C17 Steam Generator 34 and Tube-to-Tube Proximity Operational Assessment for Tube-to-Measurement Program (SONGS Tube Wear Document 1814-AU651-M0151 Rev. 0)

SONGS Document 90200, Rev. 0. ATTACHMENT 6 - Appendix B 18 Average and Maximum Thermal- SONGS U2C17 Steam Generator 35 Hydraulic Parameter Comparisons Operational Assessment for Tube-to-between Songs RSGs and Similar Plants. Tube Wear SONGS Document SO23-617-1-M1520 ATTACHMENT 6 - Appendix B 22 Unredacted Rev. 6, Tube Wear of Unit-3 RSG - SONGS U2C17 Steam Generator copy 36 Technical Evaluation Report (MHI Operational Assessment for Tube-to- required Document L5-04GA564 Rev. 8). Tube Wear SONGS Document SO23-617-1-M1532 ATTACHMENT 6 - Appendix B 26 Rev. 2, Analytical Evaluations for SONGS U2C17 Steam Generator 37 Operational Assessment (MHI Document Operational Assessment for Tube-to-L5-04GA585 Rev. 2). Tube Wear AREVA NP Document 32-9187024-000, ATTACHMENT 6 - Appendix B 27 SONGS Steam Generator Probability of SONGS U2C17 Steam Generator 38 Fluid Elastic Instability Calculation. Operational Assessment for Tube-to-Tube Wear Operational Assessment for SONGS ATTACHMENT 6 - Appendix D 3 Unit 2 Steam Generators for Upper Operational Assessment of Wear 39 Bundle Tube-to-Tube Wear Degradation Indications In the U-bend Region of at End of Cycle 16, APTECH Report, San Onofre Unit 2 Replacement AES 12068150-2Q-1, September 2012. Steam Generators SONGS 2C17 Steam Generator ATTACHMENT 6 - Appendix D 4 Possible Operational Assessment for Tube-to-Tube Operational Assessment of Wear duplication Wear, AREVA Report, 51-9187230, Indications In the U-Bend Region of September 2012. San Onofre Unit 2 Replacement 15 40 Steam Generators ATTACHMENT 6 - Appendix A SONGS U2C17 Outage - Steam 6

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Generator Operational Assessment Flow-Induced Vibration and Tube Wear ATTACHMENT 6 - Appendix D 5 Possible Analysis of the San Onofre Nuclear Operational Assessment of Wear duplication Generating Station Unit 2 Replacement Indications In the U-Bend Region of Steam Generators Supporting Restart, San Onofre Unit 2 Replacement Westinghouse Report LTR-SGDA-12-36, Steam Generators 21 41 Revision 1, September 13, 2012.

ATTACHMENT 6 - Appendix B SONGS U2C17 Steam Generator Operational Assessment for Tube-to-Tube Wear SONGS Material Properties, E-mail ATTACHMENT 6 - Appendix D 8 transmittal with Excel files SONGS2 Operational Assessment of Wear 42 CMTR.xlsx and SONGS3 CMTR.xlsx Indications In the U-Bend Region of from Mr. David Calhoun of SCE to Vince San Onofre Unit 2 Replacement Merritt of Westinghouse, June 22, 2012. Steam Generators San Onofre Nuclear Generating Station ATTACHMENT 6 - Appendix D 9 Units 2 and 3 Replacement Steam Operational Assessment of Wear Generators Evaluation of Stability Ratio Indications In the U-Bend Region of 43 San Onofre Unit 2 Replacement for Return to Service, Mitsubishi Heavy Industries Ltd., L5-04GA567, Revision 4, Steam Generators July 21, 2012.

SONGS Unit 2 Tube-to-tube Wear ATTACHMENT 6 - Appendix D 27 Indication Data Westinghouse letter Operational Assessment of Wear 44 LTR-SGMP-12-80, October 2, 2012. Indications In the U-Bend Region of San Onofre Unit 2 Replacement Steam Generators 7

Attachment Table 4 Documents Needed to Address ASLB Factual Issue (vii)

SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Unit 3 LER 2012-002, dated May 10, 2012, ENCLOSURE 2, San 8 SG Tube Degradation Indicated by Failed Onofre Nuclear In-situ Pressure Testing as required by 10 Generating Station 46 CFR 50.73(a)(2)(ii)(A) Unit 2 Return to Service Report, SCE October 3 1012 Letter from Elmo E. Collins (NRC) to Peter ENCLOSURE 2, San 7 T. Dietrich (SCE), dated March 27, 2012, Onofre Nuclear 2012 - Manual Reactor Trip Due to the SG Generating Station 47 Tube Leak as required by 10 CFR Unit 2 Return to 50.73(a)(2)(iv)(A), actuation of the Reactor Service Report, SCE Protection System October 3 1012 Special Reports relating to both Units 2 and 3 ATTACHMENT 1, Reports of inspections RSG inspections SONGS Unit 2 as required by 10 CRF Relevant Technical 5.7.2 c), submitted by Specifications SCE and held by Document Control 48 Desk, Washington, D.

C. 20555, with a copy to the Regional Administrator of the Regional Office of the NRC AREVA Document 51-9176667-001, ATTACHMENT 2, 6 SONGS 2C17 & 3C17 Steam Generator AREVA Document Degradation Assessment 51-9182368-003, 49 SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 51-9104383-002, ATTACHMENT 2, 7 SONGS Units 2 & 3 Replacement Steam AREVA Document Generators Eddy Current Technique 51-9182368-003, 50 Validation SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 03-9170186-003, ATTACHMENT 2, 8 Secondary Side Visual Inspection Plan and AREVA Document Procedure for SONGS 2C17 (SONGS 51-9182368-003, 51 Procedure Number SO23-XXVII-25.36) SONGS 2C17 Steam Generator Condition Monitoring Report SONGS Unit 2 Replacement Steam ATTACHMENT 2, 11 Generator Receipt Inspection QA Document AREVA Document 52 Review Package, (statistics evaluated in 51-9182368-003, Excel file CMTR Final with Stats.xlsx) SONGS 2C17 Steam Generator 8

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Condition Monitoring Report AREVA Document 51-9177395-000, In- ATTACHMENT 2, 12 Situ Pressure Test Summary for SONGS AREVA Document Unit 2 (Feb 2012) 51-9182368-003, 53 SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 51-9177491-001, ATTACHMENT 2, 14 SONGS 2C17 Steam Generator Condition AREVA Document Monitoring and Preliminary Operational 51-9182368-003, 54 Assessment SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 51-9179808-000, In- ATTACHMENT 3, 11 Situ Pressure Test Results for SONGS AREVA Document U3F16B Outage. 51-9180143-001 SONGS Unit 3 55 February 2012 Leaker Outage Steam Generator Condition Monitoring Report AREVA Document 51-9179946-001, ATTACHMENT 2, 16 Comparison of Bobbin and +Point POD for AREVA Document Tube-Tube Wear in SONGS Steam 51-9182368-003, 56 Generators SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 51-9181604-000, ATTACHMENT 2, 23 SONGS Unit 2 Cycle 17 and U2 Return to AREVA Document Service Eddy Current Inspection Technical 51-9182368-003, 57 Summary SONGS 2C17 Steam Generator Condition Monitoring Report AREVA Document 51-9176667-001, ATTACHMENT 3, 7 SONGS 2C17 & 3C17 Steam Generator AREVA Document Degradation Assessment. 51-9180143-001 SONGS Unit 3 58 February 2012 Leaker Outage Steam Generator Condition Monitoring Report 59 SONGS Unit 3 Replacement Steam ATTACHMENT 3, 10 9

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Generator Receipt Inspection QA Document AREVA Document Review Package 51-9180143-001 SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report MHI report, Retainer Bar Tube Wear ATTACHMENT 4, 4 Report, L5-04GA561 the latest revision MHI Document L5-04GA564 Tube Wear 60 of Unit-3 RSG Technical Evaluation Report SONGS 2C17 Steam Generator Condition ATTACHMENT 6 - 3 Monitoring Report, Document No. 51- Appendix C 9182368-002, AREVA NP. Operational Assessment for 61 SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 Verification of Program TTWEAR_U2 for ATTACHMENT 6 - 5 the Operational Assessment for SONGS Appendix C Unit 2, Draft Calculation No, AES-C-8150- Operational 1, Intertek APTECH, (September 2012) Assessment for 62 SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 Email from A. Brown (AREVA) to R. ATTACHMENT 6 - 6 Cipolla (Intertek APTECH), SONGS Tube Appendix C to-Tube Wear Indications, dated June 09, Operational 2012, Attachments: a) SONGS3 AVB and Assessment for 63 TSP Wear Depth Distribution.xlxs b) SONGS Unit 2 SG for SONGS2 AVB and TSP Wear Depth Upper Bundle Tube-Distribution.xlxs to-Tube Wear Degradation at End of Cycle 16 Email from A. Brown (AREVA) to R. ATTACHMENT 6 - 10 Cipolla (Intertek APTECH), OA Data Appendix C Request, dated June 14, 2012, Attachments: Operational a) SONGS Wear Table w All Tubes.xlxs b) Assessment for 64 SONGS2 CMTR.xlxs SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 10

Attachment SOURCE ITEM DOCUMENT FOR DISCLOSURE SOURCE DOCUMENT DOCUMENT COMMENTS REFERENCE Email from A. Brown (AREVA) to R. ATTACHMENT 6 - 11 Cipolla (Intertek APTECH), AVB Wear Appendix C Info, dated June 16, 2012, Attachments: a) Operational SONGS2 AVB Wear Structural Assessment for Dimensions.xlxs b) SONGS AVB Wear SONGS Unit 2 SG 65 Length Review.xlxs for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 Email from C. Waskey (AREVA) to R. ATTACHMENT 6 - 15 Cipolla (Intertek APTECH), Dynamic Appendix C Pressure Data for Power Reduction, (June Operational 27, 2012) Assessment for 66 SONGS Unit 2 SG for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 Emails from A. Brown (AREVA) to R. ATTACHMENT 6 - 16 Cipolla (Intertek APTECH), SONGS Tube- Appendix C to-Tube Wear Indications, Attachment Operational SONGS TTW Depth Distributions Assessment for 2012.xlsx, (June 9, 2012) SONGS Unit 2 SG 67 for Upper Bundle Tube-to-Tube Wear Degradation at End of Cycle 16 11

Attachment ATTACHMENT 2 RELEVANT SCE PROPRIETARY DOCUMENTS REFERRED TO IN AUGMENTED INSPECTION TEAM REPORT NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE a) UHNR- SON-RSG-06N005 Relates to quality control b) Work Order UHH- ML12188A748 issues encountered during 1 G06A097 vii) p40 - A1-11 the manufacture of the c) Sumitomo Corrective RSG tubing by Sumuitomo Action Plan UHCP-07N004.

Seems to be a detailed assessment of the tube inspections for Units 2 and AREVA NP Document 51-3 following the Unit 3 9176667-001, SONGS ML12188A748 forced shutdown of 31 2 2C17 & 3C17 Steam vii) p42 January 2012 - this Generator Degradation document is cited in SCE Assessment.

Attachment 6, Songs U2C17 Steam Generator Operational Assessment Specified limiting design parameters for the RSG, Certified Design leaving other unspecified Specification of SONGS ML12188A748 parameters to be 3 vii)

Unit 2&3 RSGs (SO23-617- p44 determined by the design 01, Revision 4) process - enables the MHI design approach to be evaluated in greater detail b) Mitsubishi Document L5-04GA510, Thermal and Hydraulic Parametric Relates to the MHI FIT-III Calculations, Revision code analysis of FEI

5. conditions and tube ML12188A748 vibration - this document c) Mitsubishi Document iv), v),

4 a) is cited in Attachment 4 L5-04GA521, 3D p48 vi)

MHI Document L5-Thermal and Hydraulic 04GA564 Tube Wear of Analysis, Revision 3.

Unit-3 RSG Technical d) Mitsubishi Document Evaluation Report L5-04GA504 Evaluation of Tube Vibration, Revision 3.

Mitsubishi Document KAS- Used in conjunction with 20040253, FIVATS Code ML12188A748 iv), v), FIT-III to determine the 5

Validation and Qualification P51 vi) FEI Stability Ratio Report, throughout the RSG.

Mitsubishi KAS-20050201 iv), v), Relates to the MHI FIT-III 6 ML12318A342 FIT-III Code Validation vi) code analysis of FEI 12

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE Report SUPPLEMENTAL conditions and tube INFORMATION vibration Page 57 states that an NRC senior reactor analyst performed a preliminary risk assessment. The risk is This analysis would be composed of two parts: (1) a useful to determine what non-consequential steam ML12188A748 actions are assume of SCE 7 line break that induces a vii) in averting multiple tube steam generator tube P57 ruptures during the rupture, specifically postulated in the involving the degraded unpublished NRC analysis tubes; and (2) an elevated risk of a tube rupture as an initiating event.

SO23-617-01 Specifications for design ML12188A748 Should provide the 8 and fabrication of RSG for v), vi) geometric design of the Unit 2 and Unit 3 PA1-4 tube banks, etc SO23-617 Retainer Bar Tube Wear Details of the retainer bar ML12188A748 9 M1562 Report v), vi) assembly and location of PA1-5 worn tubes from RB wear Design of Anti-Vibration L5-04GA428 Bar ML12188A748 Details of the anti-vibration 10 v), vi)

PA1-6 bar assembly SDR-037 43366- Tube-to-Tube Clearance in ML12188A748 11 06037 2A RSG v), vi) Tube layout PA1-6 SDR-079 43366- Statistical Size of Tube-to-ML12188A748 12 08079 AVB Gap v), vi) Tube to AVB geometry PA1-6 Specifications for Unit 3 SDR-086 RSG Tube Material ML12188A748 13 10041870-09086 v), vi) Tube material specification PA1-7 a) SO23-617 D115 Design Drawing Tube b) SO23-617 ML12188A748 14 Bundle v), vi) Tube Bundle design D118 PA1-8 c) SO23-617 D118 a) SO23-617 D294 Design Drawing Tube ML12188A748 15 b) SO23-617 Support Plate Assembly v), vi) Tube Support Plate D295 PA1-9 c) SO23-617 13

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE D296 a) SO23-617 D507 b) SO23-617 D508 c) SO23-617 D539 Design Drawing Anti-d) SO23-617 ML12188A748 16 Vibration Bar Assembly v), vi) Anti-vibration assembly D540 PA1-9/10 e) SO23-617 D541 f) SO23-617 D542 g) SO23-617 D543 a) L5-04FW111 b) L5-04FW112 AVB Detail ML12188A748 17 c) L5-04FW113 v), vi) AVB detail PA1-10 d) L5-04FW114 e) L5-04FW115 Tube motion, should Evaluation of Tube ML12188A748 differentiate between FEI 18 SO23-617-1-C157 viii)

Vibration PA1-10 and other modes of fluid excitation AVB motion response, could Analytical Report of AVB ML12188A748 give reason to the out of 19 SO23-617-1-C749 viii)

Assembly PA1-10 plane twisting of certain AVBs May include dimensioning of ovoid distortion of tubes ML12188A748 during bending and 20 SO23-617-01R3 Design Report of Tube v), vi)

PA1-10 flowering and, from this, reduction in the inter-tube gapping in the U-bend region Non-conformance Report ML12188A748 UGNR-SON2- Matter of detail on the TSP 21 Unacceptable local diameter v), vi)

RSG-038 PA1-12 support restraint change of tube holes Non-conformance Report Matter of detail on the AVB UGNR-SON3- Some gaps between tubes ML12188A748 degree of restraint 22 viii)

RSG-024 and AVBs are larger than PA1-12 the criterion Anti-Vibration Bar ML12188A748 Could be pre- or post-service 23 UGS-L5-050043 Inspection Procedure v), vi)

PA1-12 inspection (Individual Bar) 24 UGS-L5-050045 Inspection Procedure for ML12188A748 v), vi) Could be pre- or post-service 14

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE Tube and Anti-Vibration PA1-12 inspection Bar Inspection Stop Work Order for FMA (Final Mill Annealing) on ML12188A748 Could be tube manufacturing 25 UHH-G06A97 Manufacturing of Heat v) dimension compliance Transfer Tubing for SONGS PA1-13 RSG Could indicate why and the Specification for Design andML12188A748 approval of the dimensional 26 SO23-617-01 Fabrication of RSGs for v) changes instituted between Unit 2 and Unit 3 PA1-13 the assembly of Unit 2 and 3 RSGs Specification for Baseline Could provide indication or Pre-Service Examination ML12188A748 evidence of tube geometry 27 SO23-617-02 (PSE) on Tubing for v)

PA1-13 variations between the Units Replacement Steam 2 and 3 RSGs Generators Important to determine Updated Final Safety ML12188A748 which issue was in place at Analysis Report for San 28 FSAR iv) the time of the Unit 2 first Onofre Units 2 and 3 - PA1-13 start up and the Unit 3 forced April 2009 shutdown Reply to Notice of Non- ML12188A748 Corrective measure 29 SMI-AQA-9041 conformance (99901 iv)

PA1-14 implemented 384/2009-201-01)

ML12188A748 Could provide indications of SO23-617 AVB Structure Assembly 30 v) tolerancing and out-of-plane M819 Procedure PA1-16 (twisting) specification SO23-617 Tubing and AVB ML12188A748 Matter of detail on the AVB 31 v)

M820 Installation Procedure PA1-16 degree of restraint Anti-Vibration Bar ML12188A748 SO23-617 Matter of detail on the AVB 32 Inspection Procedure (After v)

M821 PA1-16 degree of restraint Assembly)

Engineering Information Record, SONGS 2C17 & ML12188A748 Could indicate any similarity 33 51-9176667-001 iv) 3C17 Steam Generator PA1-16 between OSGs and RSGs Degradation Assessment Discrepancy for tube UGNR-SON2- thickness of TSP between ML12188A748 Could be tube manufacturing 34 v)

RSG-014 Drawing and Purchase PA1-16 dimension non-compliance Specification Insufficient clearance ML12188A748 Could be tube manufacturing UGNR-SON2- between the tubes in Row 35 v) dimension or assembly non-RSG-058 No. 28 and 30 in Column PA1-17 compliance No. 22 Insufficient clearance ML12188A748 Could be tube manufacturing UGNR-SON2-36 between the tubes in Row v) dimension or assembly non-RSG-059 N 92 and 94 in Column No. PA1-17 o

compliance 15

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE 34 Could be tube manufacturing UGNR-SON2- Unacceptable Gaps between ML12188A748 37 v) dimension or assembly non-RSG-067 Tubes and AVBs PA1-17 compliance Could be tube manufacturing UGNR-SON2- Unacceptable gaps between ML12188A748 dimension or assembly non-38 v) compliance RSG-075 Tubes and AVBs PA1-17 Some Gaps between Tubes ML12188A748 Could be tube manufacturing UGNR-SON3-39 and AVBs are larger than v) dimension or assembly non-RSG-024 PA1-17 the criterion compliance Some gaps between tubes ML12188A748 Could be tube manufacturing UGNR-SON3-40 and AVBs are larger than v) dimension or assembly non-RSG-030 PA1-17 the criterion compliance Fabrication Process Sheet 3901-SG-A-400E (Order Could indicate inherent 2563901/G101 Rework of ML12188A748 defect in assembly and/or 41 AVB Insertion for SONGS v)

PA1-17 assembly (insertion)

Unit 2 Replacement Steam procedure Generator #A - Lower Portion ML12318A342 This should be the complete Root Cause Evaluation for SCE report being complete 42 NN 201843216 Steam Generator Tube Wear SUPPLEMENTAL iv) and more reliable than the

- SONGS 2 April 2, 2012 INFORMATION present leaked report ML12318A342 SO23-617 Tube Wear of Unit 3 RSG - iv), v), There seems to be no similar 43 SUPPLEMENTAL M1520 Technical Evaluation Report vi) evaluation report for Unit 2 INFORMATION ML12318A342 Might relate to any SO23-617 44 Evaluation of PWHT SUPPLEMENTAL v) weldments on the AVB and M1310 INFORMATION RB assemblies SONGS Design Bases ML12318A342 Document: Steam 45 DBD-SO23-365 SUPPLEMENTAL iv) Ambiguously titled Generators and Secondary Side INFORMATION ML12318A342 SO23-617 Matter of detail on the RB 46 Detail of Retaining Bar SUPPLEMENTAL v)

D781 degree of restraint INFORMATION AREVA - SONGS 2C17 ML12318A342 Ambiguously titled - is this 47 51-9182368-002 Steam Generator Condition SUPPLEMENTAL iv), v) applicable to the OSG or Monitoring Report INFORMATION RSG ML12318A342 SO23-617 48 Summary Design Report SUPPLEMENTAL iv) Ambiguously titled M1265 INFORMATION SO23-617 Retainer Bar Tube Wear ML12318A342 If for Units 2 and 3 RSGs 49 iv), v)

M1562 Report SUPPLEMENTAL than useful comparison of 16

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE INFORMATION RB wear rates and advancement into slackening-off phase for Unit 2

If for Units 2 and 3 RSGs than useful comparison of AVB wear rates and/or geometry (twisting, ML12318A342 clearance, force loading, etc)

Analytical Report of AVB 50 SO23-617-1-C749 SUPPLEMENTAL v), vi) and advancement into Assembly INFORMATION slackening-off phase for Unit 2

ML12318A342 Could be the input SO23-617 Thermal and Hydraulic 51 SUPPLEMENTAL iv) parameters for either FIT-III C1106 Parametric Calculations INFORMATION and/or ATHOS modelling Three-dimensional Thermal ML12318A342 Could provide information 52 SO23-617-1-C683 and Hydraulic Analysis SUPPLEMENTAL iv) about the shortfalls in FEI (FIT-III Code Analysis) INFORMATION prediction of FIT-III ML12318A342 Could include other modes Evaluation of Tube 53 SO23-617-1-C157 SUPPLEMENTAL iv), v) of tube excitation as well as vibration INFORMATION FEI If for Units 2 and 3 RSGs ML12318A342 than useful comparison of SO23-617 Tube Wear of Unit 3 RSG- tube wear rates and 54 SUPPLEMENTAL iv), v)

M1520 Technical Evaluation Report advancement into INFORMATION slackening-off phase for Unit 2

ML12318A342 Could provide information SO23-617 Validity of Use of the FIT- iv), v),

55 SUPPLEMENTAL about the shortfalls in FEI M1530 III Results during Design vi)

INFORMATION prediction of FIT-III ML12318A342 SO23-617 Performance Analysis 56 SUPPLEMENTAL iv), v) Ambiguously titled M1231 Report INFORMATION Attachment 12 Meeting This may be the precursor to Minutes of Design Review ML12318A342 the RB problems being and Technical Meeting with recognized by SCE and/or 57 SUPPLEMENTAL MHI on Retainer Bar MHI but with no effective Design September 12-15, INFORMATION action being taken 2006 subsequently.

Part Steam Generator This relates to a late Tube Wear Adjacent to NRC REGION 1 submission by MHI directly Retainer Bars, October 5 e-mail from to NRC stating the retainer 58 2012, NRC Region 1, MHI October 5 bars to be unsafe and that Defects and Non- 2012 these (smaller diameter RBs)

Compliance, 10 CFR should be removed.

17

Attachment NRC/AIT CITATION IN ALSB ITEM DOCUMENT COMMENTS REFERENCE AIT REPORT ISSUE 21.21(d)(3)(i)

ML12318A342 These and all subsequent SONGS RSG Project meeting notes between SCE 59 Meeting Notes October 23, SUPPLEMENTAL and NRC should be 2009 INFORMATION disclosed 18

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-361-CAL & 50-362-CAL SOUTHERN CALIFORNIA EDISON COMPANY )

)

(San Onofre Nuclear Generating Station, ) December 11, 2012 Units 2 and 3) )

)

CERTIFICATE OF SERVICE I hereby certify that, on this date, a copy of Petitioners Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure was filed through the E-Filing system.

Signed (electronically) by Richard Ayres Richard E. Ayres Jessica L. Olson Kristin Hines Gladd Ayres Law Group 1707 L St., N.W., Suite 850 Washington, D.C. 20036 Phone: 202-452-9200 E-mail: ayresr@ayreslawgroup.com; olsonj@ayreslawgroup.com; gladdk@ayreslawgroup.com Counsel for Friends of the Earth 1

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