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Category:Legal-Correspondence
MONTHYEARML0602604342006-01-12012 January 2006
Letter from Mark J. Wetterhahn to Emile L. Julian Regarding the Disposition of Protected Information Held by Winston & Strawn Llp
ML0527201292005-09-28028 September 2005
Letter from Emile L. Julian Diane Curran Requesting Return of Safeguards Documents
ML0513100102005-05-10010 May 2005
Catawba - Letter from Nathan Wildermann to Emile L. Julian Enclosing a Corrected Certificate of Service for the NRC Staff'S Reply to Duke Energy Corporation'S Brief on Review of the Licensing Board'S Final Order
ML0515700462005-04-19019 April 2005
Catawba - Letter from Kathryn L. Winsberg to Administrative Judges Informing That as of April 14, 2005, Antonio Fernndez Has Been Reinstated by the State of Maryland as a Licensed Attorney in Good Standing
ML0510903682005-04-12012 April 2005
Letter from Diane Curran to the Commissioners Requesting Measures to Correct Apparent Illegal Shipment of Plutonium MOX Fuel to the Catawba Nuclear Power Plant
ML0512305012005-04-0808 April 2005
Catawba - Letter from Kathryn L. Winsberg to Administrative Judges Regarding Antonio Fernndez'S Status as a Licensed Attorney in the State of Maryland
ML0509703242005-03-31031 March 2005
Notice of Change of Address and Telephone Numbers
ML0509703102005-03-30030 March 2005
Plutonium MOX Fuel Assemblies Not Be Sent to the Catawba Nuclear Plant Until Duke Has Fulfilled the License Conditions to the Satisfaction of the ASLB
ML0506803102005-03-0303 March 2005
Letter from Anne W. Cottingham to Emile L. Julian Enclosing the Original Affidavit of Steven P. Nesbit Submitted in Support of Duke Energy Corporation'S Response to Bredl'S Motion to Re-Open the Record on Security Contention 5
ML0436401522004-12-23023 December 2004
Catawba MOX - Letter from Susan L. Uttal to the Administrative Judges Re Inspection of the Measures for the Protection of SGI at the Offices of Diane Curran
ML0435701562004-12-20020 December 2004
E-mail from Mark J. Wetterhahn to Diane Curran Re Service of Bredl Exhibit 4
ML0435701412004-12-20020 December 2004
E-mail from Mark J. Wetterhahn to the Administrative Judges Re Bredl'S 12/20/04 Motion for Leave to File Testimony Out of Time
ML0435700492004-12-17017 December 2004
E-mail from Administrative Judge Young to Parties Re Bredl'S Prefiled Testimony
ML0434802742004-12-0909 December 2004
Letter from Diane Curran to Administrative Judges Informing That Bredl Is Planning to File an Appeal of the NRC Staff'S 12/03/04 Adverse need-to-know Determination Regarding SECY-03-0215, Insider Threat Mitigation by Licensees
ML0434303982004-12-0707 December 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Informing That the Public Citrix-based Version of ADAMS Publicly Available Records System (PARS) Has Been Partially Restored
ML0435002612004-12-0606 December 2004
Letter from David A. Repka to Annette Vietti-Cook Providing Additional Information That Duke Energy Corporation Considers Directly Pertinent to an Important Matter Pending Before the Commission
ML0434503102004-12-0303 December 2004
Catawba MOX - Letter from Susan L. Uttal to Mark Wetterhahn Enclosing a Redacted Copy of the Final Report on the Pilot Expanded Force-on-Force Exercise Program with Lessons Learned and Recommendations for Future Activities
ML0434304512004-12-0303 December 2004
Catawba MOX - Letter from Antonio Fernndez to Mark J. Wetterhahn Re Determination That Bredl Has a need-to-know the Contents of NEI-03-01
ML0435700152004-12-0202 December 2004
E-mail from Diane Curran to Counsel for Duke Energy Corp. and the NRC Staff Re Safeguards Clearance for Edward Johns
ML0435604072004-12-0202 December 2004
E-mail from Diane Curran to Patricia Smith Re Safeguards Clearance for Court Reporter
ML0433801742004-12-0202 December 2004
Catawba - Letter from Susan L. Uttal to Diane Curran Enclosing a Copy of Administrative Change to Facility Operating Licenses in Conjunction with Commission Order EA-03-086
ML0433403782004-11-29029 November 2004
Catawba - Letter from Antonio Fernndez to Diane Curran Re Documents Relating to NRC-sponsored force-on-force Exercises Conducted as Part of the Pilot force-on-force Program
ML0435603492004-11-24024 November 2004
E-mail from Diane Curran to Antonio Fernndez Re Pilot force-on-force Exercise Documents
ML0432803412004-11-22022 November 2004
Catawba - Letter from Susan L. Uttal to Mark Wetterhahn and Diane Curran Informing That the Staff Does Not Object to the Settlement Agreed to by Duke and Bredl
ML0435602912004-11-18018 November 2004
E-mail from Administrative Judge Young to Counsel for Parties Re Availability for Conference Call on 11/19/04
ML0432303782004-11-18018 November 2004
Catawba - Letter to Mark Wetterhahn Procedures
ML0432302472004-11-17017 November 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Informing of the Status of the Temporary Suspension of Public Access to ADAMS
ML0432303582004-11-17017 November 2004
Catawba - Letter from Susan L. Uttal to Mark Wetterhahn Enclosing a Redacted Copy of NRC Guidance on Implementation of the April 2003 Revised Design Basis Threat
ML0433600862004-11-12012 November 2004
Catawba - Letter from Susan L. Uttal to Mark J. Wetterhahn Enclosing Redacted Copies of Duke Security Procedures 1305-C, 1304-C, 213 and 412
ML0431701382004-11-10010 November 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Informing That the Staff Is Unable to Provide Access to an 08/25/76 NRC Classified Letter from George P. Fisher to Maurice Eisenstein
ML0632105362004-11-0505 November 2004
E-mail from Diane Curran to the Licensing Board Informing That Bredl and Duke Energy Have Resolved Contention 6
ML0435000712004-11-0505 November 2004
E-mail from Diane Curran to Administrative Judges Informing That Bredl and Duke Energy Corp. Have Resolved Contention 6
ML0431703842004-11-0202 November 2004
Letter from David A. Repka to Administrative Judges Disagreeing with Statement Made in the Letter of October 29, 2004, Submitted by Counsel for the Blue Ridge Environmental Defense League, on Schedule Matters
ML0431703952004-11-0202 November 2004
Letter from Mark J. Wetterhahn to Diane Curran Responding to 10/20/2004 Letter and e-mail of 10/21/2004 Requesting That Blue Ridge Environmental Defense League Be Given Access to a Number of Documents Through Informal Discovery
ML0431001902004-11-0101 November 2004
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
ML0430602532004-10-29029 October 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Confirming Electronic Mail Message Sent to Board and Parties on 10/28/04 Re Incorrect Identification of Enclosure 4 to Item 3 of Ms. Curran'S Informal Discovery Letter.
ML0431703752004-10-29029 October 2004
Letter from Diane Curran to Administrative Judges Responding to Duke Energy Corp.'S 10/29/04 Letter to the Licensing Board Which Purports to Clarify the Schedule for the Plutonium Mixed Oxide (MOX) Fuel Lead Test Assembly (LTA) Program
ML0430904522004-10-28028 October 2004
Letter from David A. Repka to Administrative Judges Discussing the Misunderstanding About the Schedule for the Mixed Oxide (MOX) Fuel Lead Assembly Program
ML0430200062004-10-27027 October 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Request for Discovery Document
ML0430100422004-10-25025 October 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Informing That the Commission Has Blocked Public Access to Documents in ADAMS
ML0432303892004-10-22022 October 2004
Letter from Antonio Fernndez to Administrative Judges Responding to the Licensing Board'S 10/01/04 Order in Which the Board Directed the Staff Counsel to Communicate to the Board and Parties Whether Invitation May Have Been Issued.
ML0429601852004-10-19019 October 2004
Letter from Diane Curran to Mark J. Wetterhahn and Anne W. Cottingham Re Possible Settlement of Blue Ridge Environmental Defense League'S Contention 6
ML0429601762004-10-19019 October 2004
Letter from Diane Curran to Antonio Fernndez and Susan L. Uttal Re Informal Discovery Request for security-related Documents and Request for need-to-know Determination
ML0429303712004-10-14014 October 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Responding to the Board'S 10/01/04 Order Re Impact of Information Provided in Duke'S 09/20/04 Letter
ML0429401452004-10-13013 October 2004
Letter from Mark J. Wetterhahn to Administrative Judges Regarding Responses to Information Provided by the Staff Relating to Three Questions Discussed in the September 28 Closed Session
ML0430700902004-10-0808 October 2004
E-mail from Diane Curran to Administrative Judge Young Informing That Bredl Is Not Prepared at This Point to Comment on Whether New Information Regarding Dose Consequences That Duek Provided to the NRC on 09/20/04 Is Relevant to Contention
ML0428704752004-10-0606 October 2004
Letter from David A. Repka to Administrative Judges Enclosing a Copy of Duke Energy Corp.'S 10/04/04 Submittal Which Provides Further Information Re Issue Addressed in Mr. Repka'S Correspondence of 08/31/04 and 09/20/04
ML0428002082004-10-0505 October 2004
10/5/2004 - Letter to Diane Curran Specific Interrogatory 4
ML0427804812004-10-0404 October 2004
Catawba MOX - Letter from Susan L. Uttal to Administrative Judges Responding to the Licensing Board'S 10/01/04 Order Re NRC Staff'S View of the Impact of the Information Provided by Duke in Its 09/20/04 Letter Related to Contention I
ML0427504572004-10-0101 October 2004
Catawba MOX - Letter from Antonio Fernandez to Mark Wetterhahn Enclosing a Redacted Copy of the Physical Security Plan for the Catawba Nuclear Station, Revision 0 (Plan)
2006-01-12
[Table view]
Category:Legal-Correspondence/Maintenance
MONTHYEARML0602604342006-01-12012 January 2006
Letter from Mark J. Wetterhahn to Emile L. Julian Regarding the Disposition of Protected Information Held by Winston & Strawn Llp
ML0527201292005-09-28028 September 2005
Letter from Emile L. Julian Diane Curran Requesting Return of Safeguards Documents
ML0513100102005-05-10010 May 2005
Catawba - Letter from Nathan Wildermann to Emile L. Julian Enclosing a Corrected Certificate of Service for the NRC Staff'S Reply to Duke Energy Corporation'S Brief on Review of the Licensing Board'S Final Order
ML0515700462005-04-19019 April 2005
Catawba - Letter from Kathryn L. Winsberg to Administrative Judges Informing That as of April 14, 2005, Antonio Fernndez Has Been Reinstated by the State of Maryland as a Licensed Attorney in Good Standing
ML0510903682005-04-12012 April 2005
Letter from Diane Curran to the Commissioners Requesting Measures to Correct Apparent Illegal Shipment of Plutonium MOX Fuel to the Catawba Nuclear Power Plant
ML0512305012005-04-0808 April 2005
Catawba - Letter from Kathryn L. Winsberg to Administrative Judges Regarding Antonio Fernndez'S Status as a Licensed Attorney in the State of Maryland
ML0509703242005-03-31031 March 2005
Notice of Change of Address and Telephone Numbers
ML0509703102005-03-30030 March 2005
Plutonium MOX Fuel Assemblies Not Be Sent to the Catawba Nuclear Plant Until Duke Has Fulfilled the License Conditions to the Satisfaction of the ASLB
ML0506803102005-03-0303 March 2005
Letter from Anne W. Cottingham to Emile L. Julian Enclosing the Original Affidavit of Steven P. Nesbit Submitted in Support of Duke Energy Corporation'S Response to Bredl'S Motion to Re-Open the Record on Security Contention 5
ML0435701562004-12-20020 December 2004
E-mail from Mark J. Wetterhahn to Diane Curran Re Service of Bredl Exhibit 4
ML0435701412004-12-20020 December 2004
E-mail from Mark J. Wetterhahn to the Administrative Judges Re Bredl'S 12/20/04 Motion for Leave to File Testimony Out of Time
ML0435700492004-12-17017 December 2004
E-mail from Administrative Judge Young to Parties Re Bredl'S Prefiled Testimony
ML0434802742004-12-0909 December 2004
Letter from Diane Curran to Administrative Judges Informing That Bredl Is Planning to File an Appeal of the NRC Staff'S 12/03/04 Adverse need-to-know Determination Regarding SECY-03-0215, Insider Threat Mitigation by Licensees
ML0434303982004-12-0707 December 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Informing That the Public Citrix-based Version of ADAMS Publicly Available Records System (PARS) Has Been Partially Restored
ML0435002612004-12-0606 December 2004
Letter from David A. Repka to Annette Vietti-Cook Providing Additional Information That Duke Energy Corporation Considers Directly Pertinent to an Important Matter Pending Before the Commission
ML0434503102004-12-0303 December 2004
Catawba MOX - Letter from Susan L. Uttal to Mark Wetterhahn Enclosing a Redacted Copy of the Final Report on the Pilot Expanded Force-on-Force Exercise Program with Lessons Learned and Recommendations for Future Activities
ML0434304512004-12-0303 December 2004
Catawba MOX - Letter from Antonio Fernndez to Mark J. Wetterhahn Re Determination That Bredl Has a need-to-know the Contents of NEI-03-01
ML0435700152004-12-0202 December 2004
E-mail from Diane Curran to Counsel for Duke Energy Corp. and the NRC Staff Re Safeguards Clearance for Edward Johns
ML0435604072004-12-0202 December 2004
E-mail from Diane Curran to Patricia Smith Re Safeguards Clearance for Court Reporter
ML0433801742004-12-0202 December 2004
Catawba - Letter from Susan L. Uttal to Diane Curran Enclosing a Copy of Administrative Change to Facility Operating Licenses in Conjunction with Commission Order EA-03-086
ML0433403782004-11-29029 November 2004
Catawba - Letter from Antonio Fernndez to Diane Curran Re Documents Relating to NRC-sponsored force-on-force Exercises Conducted as Part of the Pilot force-on-force Program
ML0435603492004-11-24024 November 2004
E-mail from Diane Curran to Antonio Fernndez Re Pilot force-on-force Exercise Documents
ML0432803412004-11-22022 November 2004
Catawba - Letter from Susan L. Uttal to Mark Wetterhahn and Diane Curran Informing That the Staff Does Not Object to the Settlement Agreed to by Duke and Bredl
ML0435602912004-11-18018 November 2004
E-mail from Administrative Judge Young to Counsel for Parties Re Availability for Conference Call on 11/19/04
ML0432303582004-11-17017 November 2004
Catawba - Letter from Susan L. Uttal to Mark Wetterhahn Enclosing a Redacted Copy of NRC Guidance on Implementation of the April 2003 Revised Design Basis Threat
ML0432302472004-11-17017 November 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Informing of the Status of the Temporary Suspension of Public Access to ADAMS
ML0433600862004-11-12012 November 2004
Catawba - Letter from Susan L. Uttal to Mark J. Wetterhahn Enclosing Redacted Copies of Duke Security Procedures 1305-C, 1304-C, 213 and 412
ML0431701382004-11-10010 November 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Informing That the Staff Is Unable to Provide Access to an 08/25/76 NRC Classified Letter from George P. Fisher to Maurice Eisenstein
ML0435000712004-11-0505 November 2004
E-mail from Diane Curran to Administrative Judges Informing That Bredl and Duke Energy Corp. Have Resolved Contention 6
ML0431703952004-11-0202 November 2004
Letter from Mark J. Wetterhahn to Diane Curran Responding to 10/20/2004 Letter and e-mail of 10/21/2004 Requesting That Blue Ridge Environmental Defense League Be Given Access to a Number of Documents Through Informal Discovery
ML0431703842004-11-0202 November 2004
Letter from David A. Repka to Administrative Judges Disagreeing with Statement Made in the Letter of October 29, 2004, Submitted by Counsel for the Blue Ridge Environmental Defense League, on Schedule Matters
ML0431001902004-11-0101 November 2004
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
ML0430602532004-10-29029 October 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Confirming Electronic Mail Message Sent to Board and Parties on 10/28/04 Re Incorrect Identification of Enclosure 4 to Item 3 of Ms. Curran'S Informal Discovery Letter.
ML0431703752004-10-29029 October 2004
Letter from Diane Curran to Administrative Judges Responding to Duke Energy Corp.'S 10/29/04 Letter to the Licensing Board Which Purports to Clarify the Schedule for the Plutonium Mixed Oxide (MOX) Fuel Lead Test Assembly (LTA) Program
ML0430904522004-10-28028 October 2004
Letter from David A. Repka to Administrative Judges Discussing the Misunderstanding About the Schedule for the Mixed Oxide (MOX) Fuel Lead Assembly Program
ML0430200062004-10-27027 October 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Request for Discovery Document
ML0430100422004-10-25025 October 2004
Catawba - Letter from Antonio Fernndez to Administrative Judges Informing That the Commission Has Blocked Public Access to Documents in ADAMS
ML0432303892004-10-22022 October 2004
Letter from Antonio Fernndez to Administrative Judges Responding to the Licensing Board'S 10/01/04 Order in Which the Board Directed the Staff Counsel to Communicate to the Board and Parties Whether Invitation May Have Been Issued.
ML0429601762004-10-19019 October 2004
Letter from Diane Curran to Antonio Fernndez and Susan L. Uttal Re Informal Discovery Request for security-related Documents and Request for need-to-know Determination
ML0429601852004-10-19019 October 2004
Letter from Diane Curran to Mark J. Wetterhahn and Anne W. Cottingham Re Possible Settlement of Blue Ridge Environmental Defense League'S Contention 6
ML0429303712004-10-14014 October 2004
Catawba - Letter from Susan L. Uttal to Administrative Judges Responding to the Board'S 10/01/04 Order Re Impact of Information Provided in Duke'S 09/20/04 Letter
ML0429401452004-10-13013 October 2004
Letter from Mark J. Wetterhahn to Administrative Judges Regarding Responses to Information Provided by the Staff Relating to Three Questions Discussed in the September 28 Closed Session
ML0430700902004-10-0808 October 2004
E-mail from Diane Curran to Administrative Judge Young Informing That Bredl Is Not Prepared at This Point to Comment on Whether New Information Regarding Dose Consequences That Duek Provided to the NRC on 09/20/04 Is Relevant to Contention
ML0428704752004-10-0606 October 2004
Letter from David A. Repka to Administrative Judges Enclosing a Copy of Duke Energy Corp.'S 10/04/04 Submittal Which Provides Further Information Re Issue Addressed in Mr. Repka'S Correspondence of 08/31/04 and 09/20/04
ML0427804812004-10-0404 October 2004
Catawba MOX - Letter from Susan L. Uttal to Administrative Judges Responding to the Licensing Board'S 10/01/04 Order Re NRC Staff'S View of the Impact of the Information Provided by Duke in Its 09/20/04 Letter Related to Contention I
ML0427504572004-10-0101 October 2004
Catawba MOX - Letter from Antonio Fernandez to Mark Wetterhahn Enclosing a Redacted Copy of the Physical Security Plan for the Catawba Nuclear Station, Revision 0 (Plan)
ML0430700832004-09-30030 September 2004
E-mail from Mark J. Wetterhahn to Board and Parties Informing That Duke Energy Corporation Will Not Appeal the Licensing Board Order Regarding Access to Proposed Security Plan
ML0430700682004-09-30030 September 2004
E-mail from Susan L. Uttal to Administrative Judge Young Re Site Visit
ML0430700292004-09-30030 September 2004
E-mail from Administrative Judge Young to Counsel for Parties Re Site Visit of Security Expert Advisor
ML0430700442004-09-29029 September 2004
E-mail from Administrative Judge Young to Counsel for Parties Re Site Visit
2006-01-12
[Table view] |
Text
WVINSTON & STRAWNLLP 1400 L STREEr, N.W. WAsHINGTON DC 20005-3502 202-371-5700 35 W W OW 80
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"4020>7429-0000 December 6, 2004 DOCKETED USNRC VIA ELECTRONIC MAIL December 14, 2004 (12:52pm)
Annette Vietti-Cook OFFICE OF SECRETARY Secretary RULEMAKINGS AND ADJUDICATIONS STAFF U.S. Nuclear Regulatory Commission Washington, D.C. 20005 Re: In the Matter of Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-413-OLA, 50-414-OLA
Dear Ms. Cook:
This letter provides additional information that Duke Energy Corporation
("Duke") considers directly pertinent to an important matter pending before the Commission.
On October 28, 2004, Duke Energy Corporation ("Duke") filed a response to Blue Ridge Environmental Defense League's ("BREDL") motion for reconsideration of CLI-04-29 in the captioned matter. In Section D of that response, Duke asked the Commission to provide further specific guidance on the design basis threat ("DBT") to be utilized in the ongoing proceeding relating to the licensing of mixed oxide lead assemblies. As a basis for this request, Duke stated:
[A]s this proceeding has unfolded, it has become increasingly clear to Duke that the Commission must set the specific adversary characteristics that make up the DBT for theft and diversion to be applied to Catawba during the interim between receipt of the MOX fuel assemblies at the site and insertion of these assemblies into the reactor. It is untenable for Duke, a private entity, to address that issue. Moreover, the Licensing Board -
which is not privy to classified threat information - cannot reasonably be left to make significant policy determinations on security in an individual case.
Duke further recommended that, in addressing the matter before it, the Commission should be more specific as to the DBT to assure an efficient and timely resolution of this case:
le lD/ace -5 ECY- o43 _1a
Annette Vietti-Cook December 6, 2004 Page 2 Duke recommends, however, that in addressing the current Motion, the Commission be even more specific to assure an efficient and timely resolution of this case. The Conmmission can and should weigh the relevant factors and state any specific changes (the "increment") from the 10 C.F.R. Part 50 DBT for radiological sabotage that will apply to Catawba, including any changes with respect to the number of attackers, the weaponry to be utilized, and the role of insider assistance. Duke maintains that the applicable Part 50 DBT and relevant Staff positions should apply.
On December 3, 2004, BREDL filed three supplemental discovery responses which set forth the size and other attributes of the DBT it would have the Atomic Safety. and Licensing Board consider in this proceeding. These responses, which are filed on the docket but involve Safeguards Information, are directly relevant to and illustrate the importance of defining an appropriate DBT. Duke believes BREDL's filings provide even more impetus for the Commission to act on Duke's request for supervisory guidance.
The Commission is undoubtedly aware that a timely ruling in this case is needed to enable loading the four MOX fuel lead assemblies in Catawba this spring, thereby avoiding a one year delay in the qualification of MOX fuel for the plutonium disposition program. Duke respectfully requests that the Commission review the BREDL supplemental discovery responses and consider them in its deliberation on the pending motion.
Sincerely, David A. Repka Counsel for Duke Energy Corporation cc: Service List DAR/kmj DC:390278.1
