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Category:Legal-Interrogatories and Response
MONTHYEARML0501203612005-01-0404 January 2005
Letter from Mark J. Wetterhahn to Diane Curran Enclosing Duke Energy Corporation'S Fourth Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Discovery Requests to Duke Regarding Bredl Security Contention 5
ML0433501372004-11-19019 November 2004
Duke Energy Corporation'S Second Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Interrogatories on Bredl Security Contention 5
ML0432404862004-11-19019 November 2004
Catawba - NRC Staff'S Second Supplemental Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal
ML0433103352004-11-17017 November 2004
Letter from Mark J. Wetterhahn to Diane Curran Attaching an Updated Index of Documents Responsive to Bredl Security Discovery Requests
ML0432001142004-11-0202 November 2004
Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Interrogatories on Bredl Security Contention 5
ML0430003892004-10-22022 October 2004
Catawba - NRC Staff'S Supplemental Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal
ML0428200922004-10-0505 October 2004
NRC Staff'S Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal
ML0427800972004-09-24024 September 2004
Duke Energy Corporation'S Objections to Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to Duke Energy Corporation Regarding Security Plan Submittal
ML0427306022004-09-24024 September 2004
Catawba - NRC Staff'S Objections to Bredl'S Second Set of Discovery Requests to NRC Staff Regarding Security Contention 5
ML0426600152004-09-20020 September 2004
Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal
ML0419404662004-07-0202 July 2004
Status of Duke Energy Corporation Responses and Objections to Blue Ridge Environmental Defense League'S Interrogatories and Document Production Requests on Security Contention 5
ML0419404652004-07-0202 July 2004
Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S First Document Production Request on Bredl Security Contention 5
ML0419404682004-07-0202 July 2004
Duke Energy Corporation'S Response to the NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation on the Admitted Security Contention
ML0419404852004-06-29029 June 2004
Duke Energy Corporation'S Third Supplemental Response to Blue Ridge Environmental Defense League'S First Discovery Request
ML0417603382004-06-23023 June 2004
Catawba - NRC Staff'S Objections to Bredl'S First Set of Discovery Requests to NRC Staff Regarding Security Plan Submittal and Request for Protective Order
ML0417601422004-06-23023 June 2004
Catawba - NRC Staff'S Response to the Blue Ridge Environmental Defense League'S Request for a Need to Know Determination
ML0417504182004-06-21021 June 2004
Catawba - Addendum to NRC Staff'S First Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League on Security Contention 5
ML0417503962004-06-21021 June 2004
Catawba - NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation on Admitted Security Contention
ML0416805232004-06-0808 June 2004
Blue Ridge Environmental Defense League'S Response to NRC Staff'S Second Set of Interrogatories and Request for Production of Documents
ML0416805182004-06-0808 June 2004
Blue Ridge Environmental Defense League'S Response to Duke Energy Corporation'S Second Set of Interrogatories and Requests for Production of Documents
ML0416100672004-06-0404 June 2004
NRC Staff Third Supplemental Response to Bredl'S First Discovery Request
ML0416203782004-06-0303 June 2004
Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S Second Discovery Request
ML0413303672004-05-11011 May 2004
Catawba - NRC Staff Second Supplemental Response to Bredl'S First Discovery Request
ML0413202212004-05-10010 May 2004
Catawba - NRC Staff Response to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests
ML0414005142004-05-10010 May 2004
Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S Second Discovery Request
ML0413303642004-05-0505 May 2004
Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S First Discovery Request
ML0412600262004-04-30030 April 2004
Catawba - NRC Staff'S (1) Objections to the Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff and (2) Request for Protective Order
ML0412603522004-04-26026 April 2004
Duke Energy Corporation'S Second Set of Interrogatories and Requests for Production of Documents Directed to Blue Ridge Environmental Defense League
ML0412603442004-04-26026 April 2004
Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to Duke Energy Corporation
ML0412603392004-04-26026 April 2004
Blue Ridge Environmental Defense League'S Second Set of Discovery Requests to NRC Staff
ML0411906402004-04-26026 April 2004
Catawba - NRC Staff'S Second Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League and NRC Staff'S Notice of Deposition
ML0412000232004-04-22022 April 2004
Blue Ridge Environmental Defense League'S First Supplemental Response to NRC Staff'S First Set of Interrogatories and Request for Production of Documents
ML0411005292004-04-14014 April 2004
Catawba - Certificate of Service for NRC Staff'S Response to the Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff and NRC Staff Brief in Response to the Aslb'S April 8, 2004 Order
ML0411005212004-04-14014 April 2004
Catawba - NRC Staff Brief in Response to the Aslb'S April 8, 2004 Order
ML0411005262004-04-14014 April 2004
Catawba - NRC Staff'S Response to the Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff
ML0411005272004-04-14014 April 2004
Orr, Palla Shoop and Shih-Liang Wu
ML0411205212004-04-14014 April 2004
Blue Ridge Environmental Defense League'S Response to Duke Energy Corporation'S First Set of Interrogatories and Requests for Production of Documents
ML0411205252004-04-14014 April 2004
Blue Ridge Environmental Defense League'S Response to NRC Staff'S First Set of Interrogatories and Request for Production of Documents
ML0411300692004-04-14014 April 2004
Duke Energy Corporation'S Response to the NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation
ML0411303922004-04-14014 April 2004
Duke Energy Corporation'S Response to Blue Ridge Environmental Defense League'S First Discovery Request
ML0410001142004-04-0202 April 2004
Duke Energy Corporation'S Objections to Blue Ridge Environmental Defense League'S First Discovery Request
ML0409602572004-04-0202 April 2004
League'S First Set of Discovery Requests to NRC Staff
ML0411205272004-03-31031 March 2004
Blue Ridge Environmental Defense League'S First Set of Discovery Requests Directed to Duke Energy Corporation
ML0410704432004-03-31031 March 2004
NRC Staff'S First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation
ML0409801972004-03-31031 March 2004
Blue Ridge Environmental Defense League'S First Set of Discovery Requests to NRC Staff
ML0409801882004-03-31031 March 2004
Duke Energy Corporation'S First Set of Interrogatories and Requests for Production of Documents Directed to Blue Ridge Environmental Defense League
ML0409200232004-03-31031 March 2004
Catawba - NRC Staff'S First Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League
ML0210803372002-04-11011 April 2002
First Response of Duke Energy Corporation to the Nuclear Information and Resource Service'S Interrogatories, Requests for Admission and Requests for Production to Duke Energy
ML0210803512002-04-0808 April 2002
Letter from David A. Repka to ASLBP Forwarding a Written Recounting of the Remaining Discovery Disputes Involving the Nuclear Information and Resource Service
ML0210701452002-04-0505 April 2002
Duke Energy Corporation'S First Set of Interrogatories, Requests for Admission, and Document Production Requests to the Nuclear Information and Resource Service
2005-01-04
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RAS 7976 RELATED CORRESPONDENCE June 21, 2004 DOCKETED 06/22/04 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
DUKE ENERGY CORPORATION ) Docket Nos. 50-413-OLA
) 50-414-OLA
)
(Catawba Nuclear Station )
Units 1 and 2) )
ADDENDUM TO NRC STAFFS FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE ON SECURITY CONTENTION 5 Pursuant to 10 C.F.R. §§ 2.740b and 2.741, the NRC staff ("Staff") hereby files the following addendum to NRC Staffs First Set of Interrogatories and Request for Production of Documents to the Blue Ridge Environmental Defense League on Security Contention 5 (Request), served by hand on June 21, 2004. All instructions and definitions included in the Request are applicable to the following interrogatory:
- 26. Identify and describe in detail the qualifications of any expert(s) whose opinion BREDL expects to rely upon or whose testimony BREDL expects to offer on any and all issues pertaining to BREDL Security Contention 5. Please include information on the expert(s)s qualifications, knowledge, and experience related specifically to security and safeguards of commercial nuclear power reactors and/or strategic special nuclear materials.
Respectfully submitted,
/RA/
Margaret J. Bupp Counsel for NRC Staff Dated in Rockville, Maryland This 21st day of June, 2004
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
DUKE ENERGY CORPORATION ) Docket Nos. 50-413-OLA
) 50-414-OLA
)
(Catawba Nuclear Station )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of the ADDENDUM TO NRC STAFFS FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO THE BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE ON SECURITY CONTENTION 5 in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class; or as indicated by an asterisk(*), by deposit in the Nuclear Regulatory Commissions internal mail system; and by e-mail as indicated by a double asterisk(**), this 21st day of June, 2004.
Ann Marshall Young, Chair * ** Office of the Secretary * **
Administrative Judge ATTN: Docketing and Service Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Mail Stop: O-16C1 U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555-0001 (E-mail: HEARINGDOCKET@nrc.gov)
(E-mail: AMY@nrc.gov)
Office of Commission Appellate Anthony J. Baratta * ** Adjudication
- Administrative Judge Mail Stop: O-16C1 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mail Stop: T-3F23 Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Atomic Safety and Licensing Board Panel (E-mail: AJB5@nrc.gov) Adjudicatory File
- U.S. Nuclear Regulatory Commission Thomas S. Elleman ** Mail Stop: T-3F23 Administrative Judge Washington, DC 20555 Atomic Safety and Licensing Board 5207 Creedmoor Rd #101 Diane Curran, Esq. **
Raleigh, NC 27612 Harmon, Curran, Spielberg (E-mail: elleman@eos.ncsu.edu) & Eisenberg, LLP 1726 M Street, NW, Suite 600 Washington, DC 20036 (E-mail: dcurran@harmoncurran.com)
David A. Repka, Esq. **
Lisa F. Vaughn, Esq ** Anne W. Cottingham, Esq. **
Legal Department Mark Wetterhahn, Esq. **
Mail Code - PB05E Winston & Strawn, LLP Duke Energy Corporation 1400 L Street, NW 426 S. Church Street (EC11X) Washington, DC 20005-3502 Charlotte, NC 28201-1006 (E-mail: drepka@winston.com (E-mail: lfVaughn@duke-energy.com) acotting@winston.com)
/RA/
Margaret J. Bupp Counsel for NRC Staff
