ML13044A846

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Letter to Board from Friends of the Earth 2nd Affidavit of John Large in San Onofre CAL Proceeding
ML13044A846
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 02/13/2013
From: Ayres R
Ayres Law Group, Friends of the Earth
To: Gary Arnold, Anthony Baratta, Hawkens E
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 24123, 50-361-CAL, 50-362-CAL, ASLBP 13-924-01-CAL-BD01
Download: ML13044A846 (2)


Text

February 13, 2013 E. Roy Hawkens, Chief Administrative Judge Dr. Anthony J. Baratta Dr. Gary S. Arnold Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike, Sixteenth Floor Rockville, MD 20852 Re: Large 2nd Affidavit in San Onofre CAL Proceeding

Dear Chief Judge Hawkens,

Judge Baratta, and Judge Arnold:

Today, Friends of the Earths filed a Reply Brief in the San Onofre proceeding. Attached to the Brief is a document attested to and signed by John Large, Friends of the Earths expert witness, entitled Comments on the NRC and SCE Responses of January 30, 2013. Mr. Large intended to submit this document as a sworn affidavit, as required by the Boards December 7, 2012 Order (Conference Call Summary and Directives Relating to Briefing at 6).

However, Mr. Large has experienced some logistical difficulties that prevented him from gaining access to a notary public prior to the February 13 filing deadline. Where Mr. Large lives, outside London, notaries qualified to witness U.S. legal documents are available only one day per week, at a location nearly two hours away from Mr. Larges residence and work place.

Given the two-week time frame for responding to the technical information presented in the Answering Briefs, Mr. Large simply could not sacrifice four hours to make the roundtrip journey to a notary and have enough time to provide the Board with a thorough technical response.

To prevent depriving the Board of this important information in a timely fashion, Mr.

Large filed his analysis as a declaration, without a notarys seal. With the Boards indulgence, Counsel for Friends of the Earth will file an executed affidavit from Mr. Large, containing text identical to that in todays filing, on February 20, 2013, one week from today.

In accordance with the Boards February 8, 2013 Order (Denying SCEs Motion for Sanctions Against Friends of the Earth for Violating the Protective Order, but Imposing an Enhanced Document-Review Requirement), we have withheld the 2d Large Affidavit from the Public Docket pending a one week period for review by Southern California Edison Company.

1

Sincerely,

/s/Richard Ayres Richard Ayres Counsel for Friends of the Earth 2