ML20077N376

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Contentions Arising from Review of Applicant Security Plan. Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl
ML20077N376
Person / Time
Site: Harris  
Issue date: 09/06/1983
From: Runkle J
JOINT INTERVENORS - SHEARON HARRIS
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8309130056
Download: ML20077N376 (4)


Text

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DOCKETED September 6, 1983 USNaC

'83 SEP 12 p;:og 0FFI;E OF SEcag$7 00 CME-7:nG & SEf-UNITED STATES OF AMERICA BRANcn NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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Docket Nos. 50-400 OL CAROLINA POWER & LIGHT COMPANY

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50-401 OL and NC EASTERN MUNICIPAL

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POWER AGENCY

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(Shearon Harris, Units 1 & 2)

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CONTENTIONS ARISING FROM REVIEW OF APPLICAN1?' SECURITY PIAN Following the guidelines of the Board's " Protective Order Governing Access to Security Plan Information," August 3, 1983, and in accordance with the Diablo Canyon decision, Counsel and expert witnesses for Intervenors, Wells Eddleman, Conservation Council of North Carolina, and Kudzu Alliance (Intervenors) reviewed " protected informat'7n" relating to the Applicants' Security Plan and related information.

At : Affidavits of Non-Disclosure were signed by Counsel, John Runkle, and.xperts, John R. Maples and WHEN SEFARATED FROM ENCLGSURES, HANDLE THIS DOCUMENT AS DECONTR01. LED.

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Earl Roy Bleacher, the Applicants permitted access to their Security The review of the Plan began on August 8 at the CP&L offices and Plan.

continued until August 23.

At this point, our review of the Plan is complete, and we will not call on any of the other experts which have Review included a been qualified in the Board's Protective Order.

security-oriented tour of the Shearon Harris site lead by Applicants' 4

security experts, i

In accordance with discussion on August 2 during a conference call

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with the Board and all parties, the Applicants did not " sanitize" the 4

Plan and readily made their security experts available to Intervenor

-u Counsel and Experts.

It was agreed that the internal operating procedures iS which support the Plan would not be discoverable by Intervenors although a

applicants may use certain parts of these procedures to respond to h

interrogatories and the like if the need would arise further in the T:

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proceedings.

n fi Attachment I includes a brief discussion of the Applicants' Security is Plan and contentions which have arisen in our review of the Plan.

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il Attachment I contains material that is classified as " SAFEGUARDS INFORM

.:e and is clearly marked as such. Attachment I should be protected under f"

10 CFR 73.21. In cooperation with Applicants, we are limiting the number

a jf 51 The limited service of copies of Attachment I which are being sent out.

=m f$f list clearly delineates who has received Attachment I.

It is requested b

that other persons request ruling by the Board in order to receive 5.

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this information.

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Intervenor Counsel will make every effort to expedite this matter; however, it should be noted that as all security-related information is located at the Applicants Raleigh office, it is somewhat of a hardship

.for Intervenor Counsel to schedule time to go there. We feel that any scheduling problem which arises can be worked out with Applicants although slight extensions may need to be granted. Again, Applicants have been particularly accommodating so far in this matter.

Respectfully submitted, John Runkle, J.D.

Counsel for Intervenors (Security Plan)

Dated this 6th Day of September, 1983 JR:nbs*

Attachment - Refer to Service List

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  • l 00LKETED CERTIFICATE OF SERIVCE
ENRC 183 SEP 12 PI
08 I hereby certify that copies of this filing were served in accordance to the Board's Protective Order to the following Modified Serv [g g {,;: g g y F

BRANCH Contentions) on this 6th day of September, 1983, by deposit in the United States mail, first class postage prepaid, or by hand-delivery, to the following:

James L. Kelley*

Richard E. Jones

  • Atomic Safety and Licensing Board Vice President and Senior Counsel US Nuclear Regulatory Commission Carolina Power & Light Compa'ny Washington, D.C.

20555 PO Box 1551 Raleigh, NC 27602 Glenn O. Bright Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington, D.C.

20555 Dr. James H. Carpenter Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington, D.C.

20555

\\ Docketing and Service Section Office of the Secretary US Nuclear Regulatory Commission Washington, D.C.

20555 l

Charles A. Barth*

/

Myron Karman John D. Runkle Office of Executive Legal Director Attorney-at-Law US Nuclear Regulatory Commission Counsel for Intervenors Washington, D.C.

20555 (Security Contentions)

Ruthanne G. Miller i

Atomic Safety and Licensing Board US Nuclear Regulatory Commission l

Washington, D.C.

20555 Thomas A. Baxter John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C.

20036

  • Including Attachment I containing SAFEGUARDS INFORMATION.

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