ML041940468

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

ML041940468
Person / Time
Site:	Catawba
Issue date:	07/02/2004
From:	Wetterhahn M Duke Energy Corp, Winston & Strawn, LLP
To:	NRC/OGC
Byrdsong A T
References
50-413-OLA, 50-414-OLA, ASLBP 03-815-03-OLA, RAS 8093
Download: ML041940468 (4)

Text

RELATED CORRESPONDENCE July 2, 2004 UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC July 6, 2004 (1:30PM)

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY RULEMAKINGS AND In the Matter of: ) ADJUDICATIONS STAFF

)

DUKE ENERGY CORPORATION )

) Docket Nos. 50-413-OLA (Catawba Nuclear Station, ) 50414-OLA Units 1 and 2) )

)

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" In accordance with the schedule established by the Atomic Safety and Licensing Board ("Licensing Board") in its April 28, 2004 "Order (Setting Schedule for Discovery and Hearing on Security-Related Matters)," Duke Energy Corporation ("Duke") hereby files its Response to the June 21, 2004 "NRC Staffs First Set of Interrogatories and Request for Production of Documents to Duke Energy Corporation on the Admitted Security Contention"

("NRC Staff Discovery Request"). This NRC Staff Discovery Requests asks for "all answers to interrogatories, documents or information produced in response to interrogatories and requests for production propounded on Duke by BREDL."

Duke is responding this same date to the "Blue Ridge Environmental Defense League's First Set of Discovery Requests to Duke Energy Corporation Regarding Security Plan Submittal" (June 19, 2004). Duke is providing a copy of that response, and making all documents produced in connection with that response available to the NRC Staff. Duke's p/&te -

M 03* SEC/-C

response to BREDL's June 19, 2004 Discovery Request appears to comprehensively address the June 21, 2004 NRC Staff Discovery Request.

Respectfully submitted, Mark J.tterhahnfl Anne W. Cottingham WINSTON & STRAWN, LLP 1400 L Street, NW Washington, D.C. 20005-3502 Timika Shafeek-Horton DUKE ENERGY CORPORATION 526 South Church Street Mail Code: ECI IX-1 128 Charlotte, N.C. 28201-1006 ATTORNEYS FOR DUKE ENERGY CORPORATION Dated in Washington, District of Columbia This 2 nd day of July 2004 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )

)

DUKE ENERGY CORPORATION )

) DocketNos. 50-413-OLA (Catawba Nuclear Station, ) 50-414-OLA Units 1 and 2) )

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of the documents listed below have been served on the following in the captioned proceeding by Federal Express, this 2nd day of July, 2004. Alternative service by hand delivery, as indicated by **, has also been made this 2nd day of July, 2004.

(1) "Duke Energy Corporation's Answers to Blue Ridge Environmental Defense League's First Set of Interrogatories on BREDL Security Contention 5" (SAFEGUARDS);

(2) "Duke Energy Corporation's Response to Blue Ridge Environmental Defense League's First Document Production Request on BREDL Security Contention 5;"

(3) "Status of Duke Energy Corporation Responses and Objections to Blue Ridge Environmental Defense League's Interrogatories and Document Production Requests on Security Contention 5;"

(4) July 2, 2004 letter to Antonio Fernandez, Esq., and Susan Uttal, Esq., from Mark J. Wetterhahn.

(5) "Duke Energy Corporation's Response to the NRC Staffs First Set Of Interrogatories and Request for Production of Documents to Duke Energy Corporation On The Admitted Security Contention."

Ann Marshall Young, Chairman Anthony J. Baratta Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (e-mail: AMYnrc.gov) (e-mail: AJBSnrc.gov)

Thomas S. Elleman Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission 5207 Creedmoor Road, #101 Washington, DC 20555 Raleigh, NC 27612 Attn: Rulemakings and Adjudications Staff (e-mail: elleman(eos.ncsu.edu) (original + two copies)

(e-mail: HEARINGDOCKET(nrc.gov)

Office of Commission Appellate Adjudicatory File Adjudication Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 (Non-Safeguards Documents & Certificate (Non-Safeguards Documents & Certificate of Service only) of Service only)

Susan L. Uttal, Esq. Diane Curran**

Antonio Fernandez, Esq. Harmon, Curran, Spielberg &

Margaret J. Bupp Eisenberg, LLP Office of the General Counsel 1726 M Street, N.W.

U.S. Nuclear Regulatory Commission Suite 600 Washington, DC 20555 Washington, DC 20036 (e-mail: slugnrc.gov) (e-mail: dcurrangharmoncurran.com)

(e-mail: axf2@nrc.gov)

(e-mail: mjb5@nrc.gov)

Mark J. Wetterhahn Counsel for Duke Energy Corporation 2