ML25107A256

Request for Extension of Time to Comment on Proposed Director’S Decision Regarding Seismic Core Damage Frequency for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (EPID L-2024-CRS-0000) (Redacted)

ML25107A256
Person / Time
Site:	Diablo Canyon
Issue date:	04/16/2025
From:	Curran D, Leary C, Templeton H Environmental Working Group, Friends of the Earth, Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, San Luis Obispo Mothers for Peace
To:	Dennis Galvin NRC/NRR/DORL/LPL4
References
EPID L-2024-CRS-0000, OEDO-24-00083
Download: ML25107A256 (1)

Text

April 16, 2025 Dennis Galvin, Project Manager / Agency 2.206 Petition Coordinator Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Plant Licensing Branch IV U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By email to: dennis.galvin@nrc.gov

SUBJECT:

Request for extension of time to comment on Proposed Directors Decision Regarding Seismic Core Damage Frequency for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (EPID L-2024-CRS-0000)

Dear Mr. Galvin:

On behalf of Petitioners San Luis Obispo Mothers for Peace (SLOMFP), Friends of the Earth (FoE), and Environmental Working Group (EWG), we are writing to request an extension of time to submit comments on the Proposed Directors Decision Regarding Seismic Core Damage Frequency for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (EPID L-2024-CRS-0000)

(April 10, 2025) (Proposed Decision). Because the Proposed Decision was e-mailed to us on April 11, 2025, you informed us that the deadline for our comments is April 25, 2025. As provided by MD 8.11, Handbook Section V.E.2, Petitioners respectfully request a 20-day extension until May 15, 2025.

Our request for an extension is based on the following circumstances:

First, given the complexity of the issues, the size of the record, and the significant number of technical errors and omissions in the Proposed Decision, Petitioners respectfully submit that the two weeks provided by your cover letter does not provide us with an adequate or meaningful opportunity to prepare comments on the Proposed Decision. The issues are complex, as demonstrated by the fact that the PRB has been reviewing Petitioners enforcement petition for more than a year.1 The evidentiary record is also lengthy and complex, presented in multiple submissions by Petitioners and their expert, Dr. Peter Bird, as well as a meeting with the Petition Review Board (PRB); and a presentation by PG&E.2 In addition, in their initial review of the Proposed Decision, Petitioners have found that the PRB appears to misunderstand or completely ignore a significant number of Dr. Birds key concerns and evidence.

1 See Proposed Decision at 1 (citing March 12, 2024 referral memorandum from the Secretary of the Commission).

2 See Proposed Decision at 1-3 (citing Petitioners seismic shutdown petition of March 4, 2025; supplemental submissions by Petitioners on June 7, 2024 and October 31, 2024; oral and written presentations by Petitioners at a meeting with the PRB on July 17, 2024; and a written submission by PG&E on October 24, 2025).