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Category:Legal-Correspondence/Miscellaneous
MONTHYEARML13218A4312013-08-0606 August 2013
Commission Notification of Southern California Edison'S Withdrawal of Standard Technical Specifications License Amendment Request
ML13148A4402013-05-28028 May 2013
Friends of the Earth'S Affidavit Certifying Destruction or Redaction of Protected Information
ML13143A5272013-05-16016 May 2013
Attachment to Comments Enclosed with Friends of the Earth'S and Natural Resources Defense Council'S Request to Convene Board and Consolidate License Amendment Proceedings - Attachment 2, Declaration of John Large
ML13143A5262013-05-16016 May 2013
Attachment to Comments Enclosed with Friends of the Earth'S and Natural Resources Defense Council'S Request to Convene Board and Consolidate License Amendment Proceedings - Attachment 3, Declaration of Dr. Victor Gilinsky
ML13143A5252013-05-16016 May 2013
Attachment to Friends of the Earth'S and Natural Resources Defense Council'S Request to Convene Board and Consolidate License Amendment Proceedings - Comments in Opposition to Proposed No Significant Hazards Consideration Determination
ML13113A0152013-04-23023 April 2013
Southern California Edison Company'S Eighth Notification of Responses to RAIs
ML13101A4072013-04-11011 April 2013
NRC Staff Board Notification of Federal Register Notice Application for License Amendment
ML13099A4572013-04-0909 April 2013
Notification of License Amendment Request Supplement in the Matter of San Onofre, Units 2 and 3
ML13098B0592013-04-0808 April 2013
Notification of License Amendment Request in the Matter of San Onofre, Units 2 and 3
ML13095A2072013-04-0505 April 2013
Response Letter to Sierra Club, Angeles Chapter Regarding E-mail Pertaining to Issues Concerning the San Onofre Nuclear Generating Station, Including Steam Generator Information Subject to a Non-Disclosure Agreement, and Issues Concerning N
ML13094A4992013-04-0404 April 2013
Southern California Edison Company'S Seventh Notification of Responses to RAIs in the Matter of San Onofre, Units 2 and 3
ML13095A2022013-04-0303 April 2013
Letter in Regard to Summary of Notes of January 14 Meeting and Forwarded Email from George Watland, Sierra Club, Twelve Reasons to Retire San Onofre, from Chairman Alison M. Macfarlane
ML13084A4562013-03-25025 March 2013
Southern California Edison Company, Sixth Notification of Responses to RAIs in the Matter of San Onofre, Units 2 and 3
ML13074A8602013-03-15015 March 2013
Southern California Edison Company'S Fifth Notification of Responses to RAIs
ML13072A6802013-03-13013 March 2013
Notice of Appearance of Jeremy L. Wachutka
ML13070A2072013-03-0808 March 2013
Letter from the Secretary to Glenn Pascall of Sierra Club Angeles Chapter in Response to Mr. Pascall'S 2/15/2013 E-mail (Also Attached)
ML13057A9852013-02-26026 February 2013
Southern California Edison Company'S Fourth Notification of Responses to RAIs in the Matter of San Onofre, Units 2 and 3
ML13056A6042013-02-25025 February 2013
Southern California Edison Company'S Third Notification of Responses to RAIs in the Matter of San Onofre, Units 2 and 3
ML13051A9802013-02-19019 February 2013
Notarized Copy of Attachment 1 to February 13, 2013 Reply Brief of Petitioner, Friends of the Earth, Declaration of John Large - Comments on the NRC and SCE Responses of January 30, 2013
ML13050A7672013-02-19019 February 2013
Letter from the Secretary to Erich Pica of Friends of the Earth Responding to His Letter February 7, 2013 Public Commission Meeting on Steam Generator Tube Degradation and NRC Proceedings Concerning San Onofre
ML13046A3042013-02-15015 February 2013
Friends of the Earth Errata Letter Re Reply Brief
ML13044A8462013-02-13013 February 2013
Letter to Board from Friends of the Earth 2nd Affidavit of John Large in San Onofre CAL Proceeding
ML13043A1782013-02-0808 February 2013
Second Notification of Responses to RAIs
ML13038A1872013-02-0707 February 2013
Notice of Appearance of Maxwell C. Smith in the Matter of Southern California Edison Company (San Onofre Nuclear Generating Station, Units 2 and 3)
ML13028A2952013-01-28028 January 2013
Southern California Edison Company, Notification of Responses to RAIs 1, 5, 7, 9, 10, 11, 12, 13, 15, 16, 17, 18, 19, 27, 28 and 30
ML13011A1432013-01-11011 January 2013
Notice of Chairman Allison M. Macfarlane'S Site Visit to San Onofre, Units 2 & 3 on 01/14/2013
ML13011A1412013-01-11011 January 2013
Memo Regarding Allison M. Macfarlane Plan to Tour San Onofre, Units 2 & 3 on 01/14/2013
ML12353A4042012-12-18018 December 2012
Letter from Friends of the Earth to the Board Seeking Clarification of the Board'S 12/7/12 Order with Respect to the Briefing Schedule in the Matter of San Onofre, Units 2 and 3
ML12353A3082012-12-18018 December 2012
Non-Disclosure Affidavit of John Large
ML12352A3062012-12-17017 December 2012
Non-Disclosure Affidavit of Richard E. Ayres
ML12349A3982012-12-14014 December 2012
Non-Disclosure Affidavit of Margaret Gundersen
ML12349A2332012-12-14014 December 2012
Simon David Freeman Non-Disclosure Affidavit
ML12349A1332012-12-14014 December 2012
Non-Disclosure Affidavit for Shaun Burnie
ML12348A7312012-12-13013 December 2012
Non-Disclosure Affidavit for Julie Dyer
ML12348A1532012-12-13013 December 2012
Non-Disclosure Affidavit for Kendra Ulrich
ML12348A1542012-12-13013 December 2012
Non-Disclosure Affidavit for Damon Moglen
ML12348A5462012-12-13013 December 2012
Non-Disclosure Affidavit for Erich Pica
ML12349A2342012-12-13013 December 2012
Non-Disclosure Affidavit for Arnold Gundersen
ML12347A2332012-12-12012 December 2012
Non-Disclosure Affidavit for Jessica L. Olson in the Matter of San Onofre, Units 2 and 3
ML12347A2322012-12-12012 December 2012
Non-Disclosure Affidavit for Kristin L. Hines in the Matter of San Onofre, Units 2 and 3
ML12347A2302012-12-12012 December 2012
Filing of Non-Disclosure Affidavits
ML12321A3332012-11-16016 November 2012
Letter from Friends of the Earth to the NRC EDO Requesting Transparency in the Section 2.206 Petition Review Process Regarding the 10 CFR Section 50.59 Review for the Replacement Steam Generators at San Onofre Units 2 and 3
ML12318A1142012-11-13013 November 2012
Notice of Appearance of Douglas Porter, Steven P. Frantz, William E. Baer, & Stephen J. Burdick
ML12314A2292012-11-0909 November 2012
Notice of Appearance - David Roth
ML12314A1612012-11-0909 November 2012
Notice of Appearance, David Cylkowski
ML12290A0492012-10-16016 October 2012
Letter Requesting That the NRC Decide Petition to Intervene and Application to Stay Any Decision to Restart
ML12195A0222012-07-13013 July 2012
Notices of Appearance of Douglas Porter, Paul Bessette and William Baer
ML12180A5102012-06-28028 June 2012
Notice of Appearance for Catherine E. Kanatas
ML12180A6102012-06-28028 June 2012
Notice of Appearance for David E. Roth
ML12180A6502012-06-28028 June 2012
Notices of Appearance of Kathryn M. Sutton and Stephen J. Burdick
2013-08-06
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1707 L St, N.W. ¥ Suite 850 ¥ Washington, DC 20036 ¥ Phone: (202) 452
-9200 Web: www.ayreslawgroup.com November 1 6 , 2012 R. William Borchardt Office of the Executive Director for Operations U.S. Nuclear Regulatory Commission Sixteenth Floor One White Flint North 11555 Rockville Pike Rockville, MD 20852 Re: Request for Transparency in the 2.206 Petition Review Process Regarding the 10 CFR 50.59 Review for the Replacement Steam Generators at San Onofre Units 2 and 3. Dear Mr. Borchardt
- The Nuclear Regulatory Commission (NRC) issued an order on November 8, 2012 in response to a petition, filed by Friends of the Earth under 10 CFR 2.309 on June 18, 2012. The petition requested permission to intervene and be provided a hearing on the de facto license amendment proceeding being conducted with respect to San Onofre Units 2 & 3, as made evident by the process set forth in the Confirmatory Action Letter (CAL) issued to the licensee, Southern California Edison (SCE), on March 27 , 2012. NRC staff issued the CAL following a tube rupture and leak in Unit 3s steam generator and indications of substantial and unusual wear in the steam generator tubes in that unit as well as in Unit 2. One of the core claims of the petition filed by Friends of the Earth is that SCE was required to obtain a license amendment when it replaced the original steam generators at San Onofre with new, significantly redesigned steam generat ors in 2010-11. In its order ruling on the petition, the Commission referred this claim to the staff to be examined under the process described in 10 CFR 2.206. In addition, the Commission declared that, the NRC staff is already evaluating whether these SCE actions [replacing the steam generators in Units 2 and 3] required a license amendment.
1 The NRC staffs examination of the 50.59 issue is now part of the formal 2.206 petition review process, which must be transparent and conducted by officials who were not associated with the original staff decision to allow SCE to proceed without a license amendment.
1 NRC Memorandum and Order in the Matter of Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI 20, p. 4.
1707 L St, N.W. ¥ Suite 850 ¥ Washington, DC 20036 ¥ Phone: (202) 452
-9200 Web: www.ayreslawgroup.com The NRC itself recognizes this concern over conflicts and requires the assigned 2.206 petition manager to consider any potential conflict arising from assigning any staff person to the 2.206 review who was previously involved in the decision giving rise to the petition, i.e., the initial decision as to whether a license amendment was required.
2 More broadly, the 2.206 petition review process must allow for an open dialogue between the NRC staff and the public, as recognized by the Commission in its order on Friends of the Earths petition. Indeed, the Chairwoman of the Commission, Allison Macfarlane , recently said, I believe it is incumbent upon us to communicate transparently with these groups and policy makersÉand listen to their concerns.
3 Given the Commissions stated commitment to an open process in this important matter of public safety , Friends of the Earth respectfully requests that: 1. The staff reveal the status of the review process that has occurred thus far and identify the staff members involved
- 2. The staff who will determine Friends of the Earth s 2.206 petition to require a license amendment be named and not include anyone who was involved in the previous decision to allow SCE to proceed without a license amendment, in accordance with good practice under the Commissions own Management Directive; and 3. Friends of the Earth be afforded an opportunity to review the material being considered by the Petition Review Board charged with making a determination on the petition and be given an opportunity to present to the reviewing officials its views and independent expert findings on the matter, as prescribed in the NRCs Management Directive.
In view of the pending proposal of the Edison Company to restart Unit 2, we urge you to proceed with this proceeding as soon as possible so that the public may be assured of their safety prior to possible restart of either or both of the units at San Onofre Nuclear Generating Station.
Thank you for your immediate attention to this matter.
Sincerely, /s/ Richard Ayres Counsel for Friends of the Earth (202) 452-9300 ayresr@ayreslawgroup.com Cc: Docket No. 50-361-CAL and 50
-362-CAL
2 Review Process for 10 CFR 2.206 Petitions, Management Directive 8.11, at 8 (2000).
3 Alison St John, NRC Responds to Problems at San Onofre, KPBS News, Nov. 8, 2012. (http://www.kpbs.org/news/2012/nov/08/nrc
-responds-problems-san-onofre/).
