ML20065M765

Response to ASLB 820922 Memorandum & Order Re Use of Security Plan Experts as Witnesses

ML20065M765
Person / Time
Site:	Harris
Issue date:	10/15/1982
From:	Greenblatt D, Payne M, Runkle J CHAPEL HILL ANTI-NUCLEAR GROUP EFFORT, EDDLEMAN, W., EDELSTEIN & PAYNE, GREENBLATT, D., KUDZU ALLIANCE
To:
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8210210419
Download: ML20065M765 (4)

Text

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DOCKETED U'i'!?.C UNITED STATES OF AMERICA 82 OCT 18 A11:51 NUCLEAR REGULATORY COMMISSION

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::- ;7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD - -

In the Matter of Docket Nos. 50-400 OL CAROLINA POWER & LIGHT COMPANY ) 50-401 OL AND NORTH CAROLINA EASTERN MUNICIPAL)

POWER AGENCY )

ASLBP No. 82-468-01 OL

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(Shearon Harris Nuclear Power Plant,)

Units 1 and 2) )

RESPONSE TO QUESTIONS Now come intervenors Wells Eddleman, Kudzu Alliance (KUDZU),

Conservation Council of North Carolina (CCNC) , and Chapel Hill '

Anit Nuclear Group Effort (CHANGE) in response to three' questions posed by the Board in the Memorandum and Order of September 22, 1982 at pp.16-17 and answer those questions as follows:

1. Yes. Intervenors have secured the services of three security plan experts and intend to use one or more of them accepted by the Board. For this purpose, intervenors Eddleman, KUDZU, CCNC and CHANGE have joined together as suggested by the Board and this response is submitted on behalf of all of them.

The experts proposed are:

A. Charlie A. Beckwith (Col . U. S. Army , Ret . ) is president of Secruity Assistance Services (SAS) Texas , Ltd. , 3445 Executive Center Drive, Austin, Texas 78731.

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i Col. Beckwith has more than 29 years active duty in the United  ;

States Army where he acquired a Top Secret security clearance which he has since maintained. His duties in the military included planning for security operations to deal with nuclear weapons storage and transportation. The corporate experience of SAS of Texas includes formulation of security plans for private corporations and the United States Government ; assessment of security forces, equipment and plans which have dealt with defenses against terrorism and other security contingencies .

B. John Richard Maples is Senior Vice-Presi' dent for Operations ;

and Training of Special Security International, P.O. Box 991, Roanoke, Virginia 24005. Mr. Maples has 11 years of military i

experience in the U.S. Army as a bomb technicicn and doing counter-terrorist duty. He has received training in nuclear weapons main-

. tenance and storage and is experienced in nuclear weapons facility security and site security programs .

Special Security International has provided extensive training i for United States Treasury, FBI and ATF agents and civil police-  :

departments in counter-terrorist operations , bomb threats , and other problem areas. The firm has recently worked with Virginic Electric Power Company (VEPCO) on their security plans for power 3 stations. i C. Richard J. Sanders is Division Manager at Hawkeye Security

& Services Division of Chemrad Corporation. They are-located at  ;

2007 iouisiana St., League City, Texas 77573. Mr. Sanders spent i

, eight years as Security Supervisor for Iowa Electric & Power Company i in Palo, Iowa where he received training in nuclear security and

NRC regulations. He also served four years in the United States Navy working on top secret and classified materials . The Hawkeye -

Security firm specializes in nuclear security and provides system design, training, consulting , implementation and evaluation.

2. Intervenors are continuing to contact experienced security personnel as potential experts for this matter. If such additional experts are found, intervenors will notify the Board and parties of their identities and qualifications.

3. Yes. A protective order consistent with the one entered in the Diablo Canyon case would be acceptable to the intervenors.

In anticipation of such an order intervenors point out the following:

A. For purposes of this matter, Mr. Wells Eddleman has retained an attorney, Deborah Greenblatt (undersigned) to rep-resent him. -

B. Mr. John Runkle, executive co-ordinator of CCNC has, since appearing earlier before the Board, passed the North Carolina Bar, taken the oath and become a licensed attorney. For purposes of this matter he appears for CCNC in that capacity.

l C. CHANGE, while not having retained counsel, joins in the group effort to retain one or more security experts and will rely on counsel for co-intervenors to the extent possible. If necessary, CHANGE will retain counsel in the future.

This the  !!5 ' day of October, 1982. -

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Deborah Greenblatt Attorney for Wells Eddleman l

1634 Crest Road l Raleigh, NC 27606 I

(919)832-3821

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Mt.k_ 1 M. Travis Payne Attorney for KUDZU

[] s ll Edelstein and Payne  :

723 W. Johnson St.  ;

P.0. Box 12643 i Raleigh, NC 27605  !

(919)828-1456  ;

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,s Jphri Runkle' A,ttforney for CCNC ,

M Granville Road Chapel Hill, NC 27514 l

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