|
|---|
Category:Legal-Pleading
MONTHYEARML13231A2972013-08-18018 August 2013
Citizens Oversight'S Answer to Motion Vacate Ruling of ASLB on Petition to Intervene and Request a Hearing and the Subsequent Appeal of That Ruling
ML13183A5402013-07-0202 July 2013
NRC Staff'S Answer to Motion to Submit Brief Amici Curiae
ML13168A4312013-06-17017 June 2013
Friends of the Earth'S Motion for an Extension of Time in Which to File an Answer to Staff'S Motion to Vacate
ML13154A3952013-06-0303 June 2013
NRC Staff'S Answer to Foe & Nrdc'S Motion to Convene a Board and Consolidate License Amendment Proceedings
ML13154A5202013-06-0303 June 2013
Southern California Edison Company'S Answer Opposing Motion to Notice a De Facto License Amendment Proceeding, Convene a Board, Consolidate License Amendment Proceedings, and Prohibit No Significant Hazards Consideration Determinations
ML13130A3742013-05-10010 May 2013
Notice of Withdrawal for Maxwell C. Smith
ML13130A3722013-05-10010 May 2013
Notice of Withdrawal of Maxwell C. Smith, on Behalf of the U.S. Nuclear Regulatory Commission in the Matter of San Onofre, Units 2 and 3
ML13070A4702013-03-11011 March 2013
Southern California Edison Company'S Answer Opposing Friends of the Earth'S Motion to Bar Board Notifications
ML13059A6452013-02-28028 February 2013
NRC Staff'S Answer Opposing Sce'S Motion to Strike Portions of the Declaration of John Large
ML13059A4732013-02-28028 February 2013
Friends of the Earth'S Answer to Southern California Edison Company'S Motion to Strike Portions of Declaration of John Large
ML13044A8402013-02-13013 February 2013
Reply Brief of Petitioner Friends of the Earth
ML13039A1082013-02-0808 February 2013
Southern California Edison Company'S Answer in Opposition to the Citizens Oversight Petition for Review of LBP-12-25
ML13039A1932013-02-0808 February 2013
NRC Staff Answer to Citizens Oversight Appeal
ML13036A1252013-02-0505 February 2013
Friends of the Earth'S Answer Opposing Motion by Nuclear Energy Institute for Leave to File Amicus Curiae Brief
ML13032A0482013-02-0101 February 2013
Southern California Edison Company'S Answer Opposing Petitioner'S Extension Request
ML13031A5472013-01-31031 January 2013
Friend'S of the Earth'S Motion for Extension of Time
ML13030A4622013-01-30030 January 2013
SCE Brief on Issues Referred by the Commission, Attachments 12 - 24
ML13030A4512013-01-30030 January 2013
SCE Brief on Issues Referred by the Commission, Attachments 1 to 5, Including Affidavits of Richard Brabec, Vickram Nazareth, Confirmatory Action Letter CAL 4-12-001
ML13030A4672013-01-30030 January 2013
SCE Brief on Issues Referred by the Commission, Attachments 25 to 37
ML13030A4952013-01-30030 January 2013
Affidavit of Mr. Kenneth J. Karwoski Concerning Foe'S Claims Regarding Staff'S March 27, 2012 CAL Issued to SCE (Attachment to NRC Staff Answering Brief Dated 1/30/13)
ML13030A4982013-01-30030 January 2013
Appendix 1 to NRC Staff Answering Brief - Documents That Provide Material Support for Staff'S Arguments
ML13030A5012013-01-30030 January 2013
Corrected Certificate of Service for NRC Staff'S Answering Brief in the San Onofre Nuclear Generating Station CAL Proceeding
ML13030A4412013-01-30030 January 2013
Southern California Edison Company'S Brief on Issues Referred by the Commission
ML13030A4962013-01-30030 January 2013
NRC Staff'S Answering Brief in the San Onofre Nuclear Generating Station CAL Proceeding
ML13028A1142013-01-28028 January 2013
NRC Staff'S Answer to Southern California Edison'S (Sce'S) Motion for Sanctions
ML13025A1972013-01-25025 January 2013
Friends of the Earth'S Answer to Southern California Edison Company'S Motion for Sanctions Against Friends of the Earth
ML13023A1372013-01-22022 January 2013
Corrected Attachment 1 to Opening Brief of Petitioner -Affidavit of John H. Large
ML13018A4452013-01-18018 January 2013
Natural Resources Defense Council'S Amicus Response in Support of Friends of the Earth Opening Brief
ML13011A3082013-01-11011 January 2013
Opening Brief of Petitioner, Friends of the Earth (Non-Proprietary)
ML13011A3052013-01-11011 January 2013
Attachment 3 to Opening Brief of Petitioner - Hirsch Report
ML13011A3072013-01-11011 January 2013
Attachment 4 to Opening Brief of Petitioner - Petition to Intervene and Request for Hearing by Friends of the Earth
ML13011A3062013-01-0909 January 2013
Attachment 2 to Opening Brief for Petitioner - Curriculum Vitae and Affidavit of Arnold Gundersen
ML12354A5302012-12-19019 December 2012
NRC Staff'S Answer to Citizens Oversight'S Objection to the Use of Nondisclosure Agreements
ML12354A4762012-12-19019 December 2012
Petitioner'S Reply to Answers of NRC Staff and SCE to Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure
ML12349A0232012-12-14014 December 2012
NRC Staff'S Answer to Petitioner'S Motion to Amend the Proposed Scheduling Order and Clarify Scope of Disclosure
ML12349A1162012-12-14014 December 2012
Southern California Edison Company'S Answer Opposing Citizens Oversight'S Objection to the Board'S December 10, 2012 Protective Order
ML12348A5072012-12-13013 December 2012
Southern California Edison Company'S Answer Opposing Petitioner'S Motion to Amend the Board'S December 7, 2012 Order
ML12318A3222012-11-13013 November 2012
Southern California Edison Company'S Answer Opposing Petition to Intervene and Request for Hearing by Citizens Oversight
ML12299A5132012-10-25025 October 2012
NRC Staff'S Response to Request That the NRC Decide Petition to Intervene and Application to Stay Restart Decision
ML12297A4872012-10-23023 October 2012
Southern California Edison Company'S Response to Request That the NRC Decide Petition to Intervene and Application by Friends of the Earth to Stay Any Decision to Restart Units 2 or 3 at the San Onofre Nuclear Generating Station
ML12258A0842012-09-14014 September 2012
Notice of Withdrawal for Lauren Woodall in the Matter of San Onofre Nuclear Generating Station
ML12202B2112012-07-20020 July 2012
Supplemental Declaration of Lyn Harris Hicks
ML12202B2122012-07-20020 July 2012
Reply to Sce'S and NRC Staff'S Answer to Petition to Intervene and Request for Hearing by Friends of the Earth
ML12195A3302012-07-13013 July 2012
NRC Staff'S Answer to Petition to Intervene and Request for Hearing by Friends of the Earth on the Restart of the San Onofre Reactors
ML12195A0242012-07-13013 July 2012
Southern California Edison Company'S Answer Opposing Friends of the Earth'S Hearing Request and the Natural Resources Defense Council Response Regarding San Onofre Nuclear Generating Station Units 2 and 3
ML12180A6512012-06-28028 June 2012
Southern California Edison'S Answer Opposing Friends of the Earth'S Application to Stay Any Decision to Restart Units 2 or 3 at the San Onofre Nuclear Generating Station
ML12180A5082012-06-28028 June 2012
Notice of Appearance for Lauren Woodall
ML12118A5412012-04-27027 April 2012
Joint Answer Opposing Hearing Requests Regarding Sufficiency of Order EA-12-051 Modifying Licenses with Regard to Spent Fuel Pool Instrumentation
ML12118A5402012-04-27027 April 2012
Notices of Appearance of Paul M. Bessette and Stephen J. Burdick
ML13030A4562009-06-25025 June 2009
SCE Brief on Issues Referred by the Commission, Attachments 6 to 11
2013-08-18
[Table view] |
Text
January 28, 2013 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
SOUTHERN CALIFORNIA EDISON COMPANY ) Docket Nos. 50-361-CAL/50-362-CAL
)
(San Onofre Nuclear Generating Station )
Units 2 and 3) )
)
NRC STAFFS ANSWER TO SCE'S MOTION FOR SANCTIONS Pursuant to the Atomic Safety and Licensing Board Panels (Board) January 23 order,1 the Staff of the Nuclear Regulatory Commission (Staff) hereby files its answer to Southern California Edison's (SCE's) motion for sanctions against Friends of the Earth (FoE)2 for violations of the Board's Protective Order.3 SCE requests that the Board (1) strike all protected information from FoE's filings, (2) require FoE to return or destroy the protected information, and (3) modify the Protective Order to prohibit further use of Protected Information.4 FoE opposes the request, stating that the Board should consider (1) the relative insignificance of FoEs four isolated accidental disclosures; (2) the unintentional nature of the disclosures; (3) FoEs immediate actions to remedy the situation; (4) the lack of harm to SCE; 1
Order (Directing Friends of the Earth and the NRC Staff to File Expedited Answers to SCEs Motion for Sanctions) at 3 (January 23, 2013) (unpublished) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13023A257) (directing answers by noon on January 28, 2013).
2 Southern California Edison Companys Motion for Sanctions Against Friends of the Earth for Violating the Protective Order (January 22, 2013) (Adams Accession No. ML13022A378) (Motion).
3 Order (Granting Joint Motion for Entry of a Protective Order and Non-Disclosure Agreement)
(December 10, 2012) (unpublished) (Protective Order). Under the terms of the Protective Order, the Board may impose appropriate sanctions. Id. ¶¶ 6 & 13.
4 Motion at 7.
and (5) the publics interest in the Boards ability to consider the parties arguments based on all relevant information.5 Since the enforcement of its Orders are best left to the sound judgment of the Board, and compliance under the Protective Order provisions are matters in dispute between SCE and FoE, the Staff does not take an advisory or adversarial position with respect to what sanctions the Board should impose on FoE, if any, as appropriate under the Boards Protective Order.
However, the Staff continues to believe that access to proprietary information is not necessary to resolve the issues currently before the Board.
Respectfully submitted,
/Signed (electronically) by/
David E. Roth Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O-15 D21 Washington, DC 20555-0001 Telephone: (301) 415-2749 E-mail: David.Roth@nrc.gov 5
Friends of the Earths Answer To Southern California Edison Companys Motion for Sanctions Against Friends of the Earth, at 3 (January 25, 2012) (ADAMS Accession No. ________) (FoE Answer).
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
SOUTHERN CALIFORNIA EDISON CO. ) Docket Nos. 50-361-CAL/ 50-362-CAL
)
(San Onofre Nuclear Generating Station) )
)
)
CERTIFICATE OF SERVICE Pursuant to 10 C.F.R § 2.305 (revised), I hereby certify that copies of the foregoing "NRC STAFFS ANSWER TO SCE'S MOTION FOR SANCTIONS" dated January 28, 2013 has been served upon the Electronic Information Exchange, the NRCs E-Filing System, in the above captioned proceeding, this 28th day of January, 2013:
/Signed (electronically) by/
David E. Roth Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Mail Stop O-15 D21 Washington, DC 20555-0001 Telephone: (301) 415-2749 E-mail: David.Roth@nrc.gov Dated at Montgomery Village, Maryland this 28th day of January, 2013
