Letter from Mark J. Wetterhahn to Diane Curran and Antonio Fernndez Forwarding Proposed Language Defining What Would Constitute Radiological Sabotage of the MOX Lead Assemblies Re Settlement of Proposed Bredl Security Contention 6| ML043100190 |
| Person / Time |
|---|
| Site: |
Catawba  |
|---|
| Issue date: |
11/01/2004 |
|---|
| From: |
Wetterhahn M
Duke Energy Corp, Winston & Strawn, LLP |
|---|
| To: |
Curran D, Fernandez A
Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, NRC/OGC |
|---|
| Byrdsong A T |
| References |
|---|
| 50-413-0LA, 50-414-0LA, ASLBP 03-815-03-OLA, RAS 8763 |
| Download: ML043100190 (1) |
|
|
|---|
Category:Legal-Correspondence
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[Table view]
Category:Legal-Correspondence/Maintenance
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Letter from Mark J. Wetterhahn to Emile L. Julian Regarding the Disposition of Protected Information Held by Winston & Strawn Llp
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[Table view] |
Text
PA 5 43 RMIJL, OORRESPQN9NM DOCKETED USNRC November 4, 2004 (12:53PM)
WINSTON & STRAWNLLP OFFICE OF SECRETARY RULEMAKINGS AND 1400 L STREEr, N.W., WASHINGTON DC 20005-3502 ADJUDICATIONS STAFF 202-371-5700 35 W.W- 0.4 200 P~A 3MI`TWO.33355 042000W 0 04A4402 43 mm.50404 XI AOS.*VVI." It22 *.cza0642 660I4 0C~sOL 00000 3 66YO2.1V N 601644193 L-.4A-CAN. CA 0007 .1545 43 F4 r42CA 0466I6.5504 6204 0050.. *.,7 751 6662.-. r4..e 3 0Q~t204S84 a I Z659_6-S00 00 66209244700 21346161700 4614051.0000 46.22-317-0787 33-645-044924 LC~0. E22u.04N 6ON" 44-0207420-0000 November 1, 2004 VIA MESSENGER VIA OVERNIGHT COURIER Diane Curran, Esq. Antonio Fernandez, Esq.
Harmon, Curran, Spielberg & Eisenberg, LLP Office of the General Counsel 1726 M Street, N.W., Suite 600 U.S. Nuclear Regulatory Commission Washington, D.C. 20036 -Washington, D.C. 20555-0001 Re: In the Matter of Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413-OLA, 50-414-OLA
Dear Diane and Antonio,
As we discussed on October 25, 2004, I am forwarding to you proposed language defining what would constitute radiological sabotage of the MOX lead assemblies which could be.used as a basis for settlement of proposed BREDL Security Contention 6. This language should be considered Safeguards Information. I would appreciate your response to this proposal as soon as possible. This proposal is submitted for settlement purposes only and does not concede the admissibility of Contention 6 or the jurisdiction of the Atomic Safety and Licensing Board to consider radiological sabotage issues at the Catawba facility in this proceeding.
I am also sending a copy of this letter to the members of the Atomic Safety and Licensing Board (without the Safeguards attachment) to fulfill our commitment made at the October 25, 2004 oral argument (Tr. 3717) to inform the Board of the status of settlement discussions related to Security Contention 6.
Sincerely, Mark J. Wetterhahn Counsel for Duke Energy Corporation MJW:sdd Enclosures Service List (w/o enclosure)
The Attachment to this letter contains Safeguards Information.
Upon separation of the attachment, this cover letter is decontrolled.
Izplate cs= 54C _ @/3