ML20024E834

Response to ASLB 830824 Order Re Spent Fuel Security

ML20024E834
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Eddleman W EDDLEMAN, W.
To:
Shared Package
ML20024E830	List: ML20024E829 ML20024E832 ML20024E834 ML20024E840 ML20024E846 ML20024E850 ML20024E853 ML20024E856 ML20024E858 ML20024E862
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309070123
Download: ML20024E834 (2)

Text

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00tME'E0 UNITED STATES OF AMERICA August 31, 1983 NUCIEAR REGULAMRY COMMISSION $3 ggo -6 #1 :07 0FFl;E OF SECRC.t-BEFORE THE AMMIC SAFETY AND LICENSING BOARD 00CKE-Tg E?vic!

Glenn O. Bright '

Dr. James M. Carpenter James L. Kelley, Chairman In the Matter of J Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 and 2) ) ASLBP No. 82-h68-01

} OL Wells Eddleman's Response to Board 8-24a8%

Order (pp 6-7) ro Sp ent Fuel Security In this order (received 8-29), the Board conditionally rejects Eddlenan Contention 2h unless I can C ive " sone convincing

explanation"' why I hadn't proff ered a security exnert on spent 1

fuel transport in a tinely nanner. The answer is, I have, already.

John R Maples (see his deposition at 68) is qualified in the field

( of assessing threats and in security planning for sensitive nuclear i

shinnents. In his resune (also subnitted to the Board) he notes that the reouirenents for security of nuclear weapons shipments are - tighter than those for spent nuclear fuel under 10 CFR 73 In retaining Messrs. Bleacher and Stevens I also ascertained that they have experience re security planning for spent fuel

'O shipnents and threat assessnent and " black hat" operations therefor.

gg

~8 In the 2-24 83 special prehearing conference, my atto-ney Greenblatt fo o<

kg stated (p.510 of transcript) that proffers of exnertise co"1d be made in the depositions. Vaplest, at least, was (p.68, his deposition),

sto l

re spent fuel.

RIsponao to 8-24-83 Board Ord;r re Spnnt Fugl Security p ge two The reason we haven't rained this issue (other of the Joint Intervenors are concerned with spent fuel transnort security and participated in discussions with the experts or had ne do so for then),

is that to my knowledge, Apulicants have put forward no plan for security for spent fuel transport to Harris.

Indeed, Aunlicants attached an affidavit to their motion to have all spent fuel contentions disnissed, stating that they A, 52 45 at present have no. firm plans to ship spent fuel to Harris. gM,kote Meetings re Harris site security are annour(ed; I see none re fuel, If Applicants have presented a snent fuel shipment security plan for shipments to Harris to the URC, I haven't seen it in any of the voluminous filings they send to us; nor have I seen reference to such a plan in anything from NRC Staff Routes for such shipmeS+i's $re in t e plan notfact safeguards info, exists, the yet I've exnerts seen Joint noth*ing filed on Intervenors (including me) retained ~ are available to review it, urovided we can pay for the review.. Counsel advised ne to not raise the spent fuel issue 2-24-83 since it wasn't relevant until the Applicants put forward a plan for security of shipments of spent fuel to Harris.

Given that they have no plan to ship spent fuel there, I'd be surprised if they have a security plan. But if they do, we need to be apurised of it and set un a schedule for reviewing it. I have, l

as noted above, at least one expert (Manles) tinely proffered to review security of such plan.

In view of the above, I respectfully request the Board to defer ruling on Eddleman 2h pending review by ny expert (s) of any plan CP&L has for security of spenf fuel shipments to Harris under 10 CFR 73 Since Eddlenan 25 depends on a showing of a real threat to such shipments which cannot be established definitely until the security plan for then is reviewed, I ask that it also remain deferred in such review.

Wells Eddlenan