ML20212J587

Affidavit of CE Gaskin Re Contentions UT Security A,B & C.* Affidavit Prepared in Response to Applicant Motion for Summary Disposition of Contentions Utah Security a & B & Partial Summary Disposition for C.With Certificate of Svc

ML20212J587
Person / Time
Site:	07200022
Issue date:	07/01/1999
From:	Gaskin C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20212J560	List: ML20212J556 ML20212J587
References
ISFSI, NUDOCS 9907060070
Download: ML20212J587 (5)

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July 1,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PRIVATE FUEL STORAGE, L.L.C. ) Docket No. 72-22-ISFSI

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(Independent Spent Fuel )

Storage Installation) )

AFFIDAVIT OF CHARLES E. GASKIN CONCERNING CONTENTIONS UTAH SECURITY-A. SECURITY-B. AND_ SECURITY-C I, Charles E. Gaskin, having first been duly sworn, do hereby state as follows:

1. My name is Charles E. Gaskin. I am employed as a Senior Safeguards Project j Manager in the Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety -

and Safeguards, U.S. Nuclear Regulatory C.ommission ("NRC"), in Washington, D.C. A statement of my professional qualifications is attached hereto.

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2. This Affidavit is prepared in response to the " Applicant's Motion for Summary I Disposition of Contentions Utah Security-A and Security-B, and Partial Summary Disposition of i

Contention Utah Security-C" (" Motion"), filed on June 11,1999, by Private Fuel Storage L.L.C.

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(" Applicant" or" PFS"), and the " Statement of Material Facts on Which No Genuine Dispute l L Exists" (" Statement of Material Facts") attached thereto.  !

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3. As part of my official responsibilities, I reviewed the adequacy of the Applicant's Physical Protection Plan, submitted with its application for an Independent Spent Fuel Storage Installation ("ISFSI") license, as revised on June 8,1999, and am involved in preparing the related 9907060070 990701 PDR ADOCK 07200022 C PDR L' _a_

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4 2-section of tne NRC Staff's Safety Evaluation Report ("SER"). In addition, I participated in preparing the "NRC Staff Position" on Contentions Utah Security-A, Security-B and Security-C, as set forth in the "NRC Staff's Statement ofIts Position Concerning Group I Contentions," dated June 15,1999 (at 23-25). The NRC Staff Position accurately represents my views concerning these three contentions.

4. Also as part of my official responsibilities, I have reviewed the Applicant's Motion and the attachments thereto, in which PFS seeks summary disposition of Contentions Utah Security-A and Security-B, and partial summary disposition of Contention Utah Security-C. On l the basis of my review of the Applicant's physical protection plan, as revised, and the documents attached to the Applicant's Motion, I am satisfied that the Statement of Material Facts attached to the Applicant's Motion is correct.

5. I hereby certify that the foregoing is true and correct to the best of my knowledge, information and belief, b '

Charles E. Gaskin Subscribed and sworn to before Ine this 1st day of July,1999.

i NOTARY w ,_ 1 Notary Public My commission expires:7ffrtb mod.3

Charles E. Gaskin Senior Safeguards Project Manager Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission I am a S*nior Safeguards Project' Manager in the Division of Fuel Cycle Safety and Safeguards.

My 38 years have included service in the security and law enforcement fields with the U. S. Navy, the Central Intelligence Agency, the Department of Justice, and the Nuclear Regulatory Commission (NRC). In the capacity of a Senior Safeguards Project Manager, I review of the physical protection programs at NRC-licensed Category I facilities. I also have worked as a Plant i Protection Analyst for the NRC with respect to nuclear power reactors licensed under 10 C.F.R. Part 50. In that capacity, I performed reviews and assessments of the adequacy of reactor site physical security plans developed to protect against radiological sabotage and theft. I was responsible for the 10 C.F.R. i 73.55 review for various reactors, including Diablo Canyon, Shoreham, Seabrook, and Clinch River.

Prior to commencing employment at the NRC, I provided technical operational surveillance support in law enforcement for the Drug Enforcement Administration (DEA). While in the positica of project manager with that organization, I gained experience in the positive operational side of security. I developed specific surveillance equipment of various operations, conducted hardware feasibility studies, tested surveillance equipment, developed equipment for air and I surface vehicles and worked with the international community in the application of technology to law enforcement. Also, I participated in establishing security regulations for the DEA. In addition, I processed wiretap evidence for court presentation, and restified in many drug cases where technical surveillance equipment was deployed.

While at the Central Intelligence Agency, I served as technical security officer with overseas experience in both physical and technical security. I developed and implemented security systems i and programs. During this time I worked in many areas of the world.

While in the U.S. Navy, I was with the Naval Security Group and was involved in communications security.

I am a member of the Institute of Electrical and Electronic Engineers and participate in the writing of engineering standards for the industry. I am also a member of the American Society for Industrial Security and the American Standard Testing and Materials.

UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USHRC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9 jul -2 P 1 :04 In the Matter of ) g

) F' PRIVATE FUEL STORAGE L.L.C. ) Docket No.72-224SFSI v

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(Independent Spent )

Fuel Storage Installation) )

CERTIFICATE OF SERVICE I hereby certify that copies of the "NRC STAFF'S RESPONSE TO APPLICANT'S MOTION FOR

SUMMARY

DISPOSITION OF UTAH SECURITY-A AND SECURITY-B, AND PARTIAL

SUMMARY

DISPOSITION OF UTAH SECURITY-C" in the above captioned proceeding have been served on the following through deposit in the Nuclear Regulatory Commission's internal mail system, or by deposit in the United States mail, first class, as indicated by an asterisk, with copies by electronic mail as indicated, this 1st day of July,1999:

G. Paul Bollwerk, III, Chairman Atomic Safety and Licensing Board Panel Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary (E-mail copy to GPB@NRC. GOV) ATTN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline Washington, DC 20555 Administrative Judge (E-mail copy to:

Atomic Safety and Licensing Board HEARINGDOCKET@NRC. GOV)

U.S. Nuclear Regulatory Commission Washington, DC 20555 Office of the Commission Appellate  ;

(E-mail copy to JRK2@NRC. GOV) Adjudication Mail Stop: 16-C-1 OWFN Dr. Peter S. Lam U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission James M. Cutchin, V Washington, DC 20555 Atomic Safety and Licensing Board (E-mail copy to PSL@NRC. GOV) U.S. Nuclear Regulatory Commission Washington, DC 20555 (by E-mail to JMC3@NRC. GOV)

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/ Danny Quintana, Esq.* Diane Curran, Esq.*

I' Danny Quintana & Associates, P.C. Harmon, Curran, Spielberg 68 South Main Street, Suite 600 & Eisenberg, L.L. P.

Salt Lake City, UT 84101 1726 M. Street N.W., Suite 600 (E-mail copy to quintana @Xmission.com) Washington, D.C. 20036 (E-mail copy to Jay- E. Silb:rg, Esq.* 'dcurran@harmoncurran.com)

Ernest Blake, Esq.*

Paul A. Gaukler, Esq.* John Paul Kennedy, Sr., Esq.*

SHAW, PITTMAN, POTTS & 1385 Yale Ave.

TROWBRIDGE Salt Lake City, UT 84105 2300 N Street, N.W. (E-mail copy to john @kennedys.org)

Washington, DC 20037-8007 (E-mail copies to jay _silberg, Joro Walker, Esq.*

paul _gaukler, and ernest _blake Land and Water Fund of the Rockies

@shawpittman.com) 2056 East 3300 South, Suite 1 Salt Lake City, UT 84109

. Denise Chancellor, Esq.*- (E-mail copy to joro61@inconnect.com)

Fred G. Nelson, Esq.- .

, Utah Attorney General's Office Richard E, Condit, Esq.

160 East 300 South,5th Floor Land and Water Fund of the Rockies P.O. Box 140873 2260 Baseline Road, Suite 200 Salt Lake City, UT 84114-0873 Boulder, CO 80302 (E-mail copy to dchancel@ State.UT.US) (E-mail copy to rcondit@lawfund.org)

Connie Nakahara, Esq.* ~

Utah Dept. of Environmental Quality 168 North 1950 West P. O. Box 144810 Salt Lake City, UT 84114-4810 j (E-mail copy to enakahar@ state.UT.US) J l

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Sherwin E. Turk i Counsel for NRC Staff

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