ML043200114

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Duke Energy Corporation'S First Supplemental Response to Blue Ridge Environmental Defense League'S First Set of Interrogatories on Bredl Security Contention 5
ML043200114
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 11/02/2004
From: Wetterhahn M
Duke Energy Corp, Winston & Strawn, LLP
To:
Atomic Safety and Licensing Board Panel
Byrdsong A T
References
50-413-OLA, 50-414-OLA, ASLBP 03-815-03-OLA, RAS 8793
Download: ML043200114 (7)
v • d • e


Text

sRas gT93 L LTHE (:ORRESPONDSENF November 2, 2004 DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION November 9,2004 (11:07AM)

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

)

DUKE ENERGY CORPORATION )

) DocketNos. 50413-OLA (Catawba Nuclear Station, ) 50-414-OLA Units I and 2) )

)

DUKE ENERGY CORPORATION'S FIRST SUPPLEMENTAL RESPONSE TO BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE'S FIRST SET OF INTERROGATORIES ON BREDL SECURITY CONTENTION 5 Duke Energy Corporation ("Duke") supplements its July 2, 2004 response to General Interrogatory Nos. 2 and 3 of the June 19, 2004 "Blue Ridge Environmental Defense League's First Set of Discovery Requests to Duke Energy Corporation Regarding Security Plan Submittal" as follows:

Supplemental Response to General Interrogatorv No. 2 Ms. Rita A. Edwards will testify as an additional expert witness on behalf of Duke regarding Security Contention 5. A copy of Ms. Edwards' Statement of Qualifications is attached.

Supplemental Response to General Interrogatory No. 3 The designated witnesses are also expected to testify collectively to the following facts and opinions which demonstrate that Security Contention 5 is without merit:

The mission and structure of the Catawba security organization, and its relationship with other site and offsite organizations.

-em) late sc 036-SF Cy- O.

  • Security features at the Catawba site.
  • Security operations, training, and procedures.
  • How the armed response force is selected, trained, equipped and how it responds to security events.
  • How all elements of the security function are integrated into an overall strategy, which when implemented, has as its objective to provide high assurance that activities involving special nuclear material are not inimical to the common defense and security and do not constitute an unreasonable risk.
  • The role that access authorization and continuing behavioral observation programs play in security and how insider threats are eliminated or minimized and dealt with in the security response.
  • How the elements of the security response and the integrated response are developed and tested.
  • The additional security measures taken as a result of the presence of the MOX lead assemblies at Catawba for each evolution, e.g., receipt, inspection and storage, and how such measures when integrated with the measures already in place, assure that the MOX fuel can be successfully protected against theft or diversion within the scope of the appropriate DBT for theft and diversion.

The validity and likely outcome of the proposed BREDL scenario(s) for theft and diversion of strategic special nuclear material from Catawba.

  • Why each requested exemption is justified.

2

  • To the extent it remains an issue in the proceeding, the limited increment of the design basis threat ("DBT") for theft and diversion as compared to the radiological sabotage DBT.
  • To the extent it remains an issue in the proceeding, the relative attractiveness of the MOX lead assemblies to theft or diversion.

Moreover, in addition to the grounds previously provided, the opinions of the witnesses will be based on their review of responses to discovery.

The information provided in this supplemental response was supplied by Mr. Michael T. Cash, as previously identified in response to BREDL General Interrogatory No.1.

Respectfully submitted, Da idA. Repka Mark J. Wetterhahn Anne W. Cottingham WINSTON & STRAWN, LLP 1400 L Street, NW Washington, D.C. 20005-3502 Timika Shafeek-Horton DUKE ENERGY CORPORATION 422 South Church Street Mail Code: PB05E Charlotte, N.C. 28201-1244 ATTORNEYS FOR DUKE ENERGY CORPORATION Dated in Washington, District of Columbia This 2 nd day of November 2004 3

November 2, 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 (Catawba Nuclear Station, ) 50-414-OLA Units I and 2) )

AFFIDAVIT OF MICHAEL T. CASH Michael T. Cash hereby declares under penalty of perjury that the following statements are true and correct of his own knowledge:

1. I have prepared Duke Energy Corporation's responses to "Duke Energy Corporation's First Supplemental Response to Blue Ridge Environmental Defense League's First Set of Interrogatories on BREDL Security Contention 5," dated November 2, 2004.
2. The information provided in these responses is responsive to the requests and is true and-correct to the best of my knowledge, information and belief.

Michael T. Cash

STATEMENT OF QUALIFICATIONS RITA A. EDWARDS Duke Energy Corporation Catawba Nuclear Station 4800 Concord Road York, South Carolina 29745 Experience Nuclear Shift Captain, Charlie Team - Catawba Nuclear Station 1997 - Present Training Department - Catawba Nuclear Station Firearms Instructor 1995-1997 Security - Shift Supervisor (developmental) - Catawba Nuclear Station 1994 - 1995 Security Specialist - Catawba Nuclear Station Responsibilities included CAS/SAS Operator/Badging/Access Control 1987 - 1994 Security Officer - Catawba Nuclear Station 1983 - 1987 Law Enforcement Officer City of Gastonia, North Carolina 1981-1983 Law Enforcement Officer Sheriff's Department Gaston County, North Carolina 1976- 1981 Police Dispatcher Gaston County, North Carolina 1974 - 1976 Education West Lincoln High School Lincolnton, North Carolina DC:384027.1

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

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of "DUKE ENERGY CORPORATION'S FIRST SUPPLEMENTAL RESPONSE TO BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE'S FIRST SET OF INTERROGATORIES ON BREDL SECURITY CONTENTION 5" in the captioned proceeding have been served on the following by deposit in the United States mail, first class, this 2nd day of November, 2004. Additional e-mail service, designated by *, has been made this same day, as shown below.

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: AMY~nrc.gov) (e-mail: AJB5(nrc.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: ellemaneeos.ncsu.edu) (original + two copies)

(e-mail: HEARINGDOCKETnrc.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

U.

Susan L. Uttal, Esq.* Diane Curran*

Antonio Fernandez, Esq.* Harmon, Curran, Spielberg &

Office of the General Counsel Eisenberg, LLP U.S. Nuclear Regulatory Commission 1726 M Street, N.W.

Washington, DC 20555 Suite 600 (e-mail: slugnrc.gov) Washington, DC 20036 (e-mail: axf2(nrc.gov) (e-mail: dcurraneharmoncurran.com)

(e-mail: mjb5nrc.gov)

Mark J. Wetterhahn Counsel for Duke Energy Corporation

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