ML103570266
| ML103570266 | |
| Person / Time | |
|---|---|
| Site: | 05200042 |
| Issue date: | 12/23/2010 |
| From: | Blackburn J Blackburn-Carter Law, Texans for a Sound Energy Policy Alliance (TSEPA) |
| To: | Hawkens E Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 52-042-ESP, Early Site Permit 1, RAS 19286, +reviewedtvg | |
| Download: ML103570266 (6) | |
Text
A Carbon Neutral Law Firm BLACKBURN CARTER A Professional Corporation - Lawyers 4709 Austin Street, Houston, Texas 77004 Telephone (713) 524-1012 Telefax (713) 524-5165 www.blackburncarter.com JAMES B. BLACKBURN, JR MARY W. CARTER CHARLES W. IRVINE ADAM M. FRIEDMAN MARY B. CONNER KRISTI J. DENNEY JAMES B. BLACKBURN, JR.
Senders E-Mail: jbblaw@blackburncarter.com December 23, 2010 Via Electronic Information Exchange E. Roy Hawkens Chief Administrative Judge The Atomic Safety and Licensing Board Panel 11555 Rockville Pike Rockville, MD 20852 RE:
Docket No.52-042; Exelon Nuclear Texas Holdings, LLC; Early Site Permit for Victoria County Station Site; Before The U.S. Nuclear Regulatory Commission, The Atomic Safety and Licensing Board; Non-Disclosure Affidavits
Dear Judge Hawkens:
Pursuant to the Memorandum and Order issued on December 21, 2010, attached are four Non-Disclosure Affidavits for access to SUNSI in the above matter. One is signed by Mr. Bill Jones as a Board Member of Texans for a Sound Energy Policy (TSEP). The other affidavit is signed by Charles W. Irvine of our firm. Finally, we have engaged John C. Halepaska and Steven L. Lange of Halepaska & Associates, Inc. and expect to utilize them as our experts and/or consultants. Non-Disclosure Affidavits executed by Mr. Halepaska and Mr. Lange are also attached.
Please contact Charles W. Irvine of our firm at (713) 524-1012 or via email at charles@blackburncarter.com with any questions regarding this submission.
Sincerely, BLACKBURN CARTER, P.C.
by s/James B. Blackburn, Jr.
James B. Blackburn, Jr.
c: See attached Certificate of Service Attachments:
Non-Disclosure Affidavit by Bill Jones Non-Disclosure Affidavit by Charles W. Irvine Non-Disclosure Affidavit by John C. Halepaska Non-Disclosure Affidavit by Steven L. Lange
Docket No. 52-042-ESP; Non-Disclosure Affidavits December 23, 2010
- p. 2 CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of December, 2010, copies of the foregoing letter and attached Non-Disclosure Affidavits have been served upon the following persons by Electronic Information Exchange.
s/James B. Blackburn, Jr.
James B. Blackburn, Jr.
E. Roy Hawkens Chief Administrative Judge The Atomic Safety and Licensing Board Panel 11555 Rockville Pike Rockville, MD 20852 Ann Hove, Law Clerk Email: ann.hove@nrc.gov U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Mail Stop T-3 F23 Washington, DC 20555-0001 Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Email: ocaamail@nrc.gov U.S. Nuclear Regulatory Commission Office of the Secretary of the Commission Mail Stop O-16C1 Washington, DC 20555-0001 Hearing Docket Email: hearingdocket@nrc.gov J. Bradley Fewell Exelon Generation Co., LLC 4300 Winfield Road Warren, IL 60555 Email: bradley.fewell@exeloncorp.com U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop O-15D-21 Washington, DC 20555-0001 Marian Zobler, Esq.
Sara Kirkwood, Esq.
Stephanie Liaw, Esq.
Patrick A. Moulding, Esq.
Laura Goldin, Esq.
Anthony Wilson, Esq.
Joseph Gilman, Paralegal Emails:
marian.zobler@nrc.gov sara.kirkwood@nrc.gov stephanie.liaw@nrc.gov patrick.moulding@nrc.gov laura.goldin@nrc.gov anthony.wilson@nrc.gov jsg1@nrc.gov OGC Mail Center:
OGCMailCenter@nrc.gov Steven P. Frantz Stephen Burdick Jonathan M. Rund Mary Freeze Morgan Lewis & Bockius, LLP 1111 Pennsylvania Ave., NW Washington, DC 20004 Emails: sfrantz@morganlewis.com sburdick@morganlewis.com jrund@morganlewis.com mfreeze@morganlewis.com
NON~OISCLOSURE AFFIDAVIT
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.' being duly sworn, state:
(Print Name)
- 1.
I have read the December 21 r 2010 Atomic Safety and Licensing Board Panel (ASLBP)
Protective Order issued in this proceeding and will comply in all respect.s with its terms and conditions regarding the Protected Information produced in conneGtion therewith. I will protect and keep confidential all Sensitive Unclassified Non-Safeguards Information (SUNSI), including security related and/or proprietary information in accordance with the terms of this Non-Disclosure Affidavit.
- 2.
I will not disclose SUNSI to anyone except an authorized person. I will protect documents containing or revealing SUNSI in written or recorded form (including any portions of transcripts of in camera hearings, filed testimony, or any ot.her documents that contain or reveal such SUNSI), so the SUNSI contained therein remains at a\\l times under the control of an authorized person and is not revealed to anyone else.
- 3.
When not under my direct control or the direct control of another authorized person, I will keep and protect all documents containing or revealing SUNSI (includin!], without limitation, transcripts, pleadings I may generate, and any notes and copies that I may make) in a secure locked place such as a filing cabinet, closet, or other storage container. I will not transmit by facsimile transmission any material corrtf.~ining SUNSI.
- 4.
Each docurnent that contains or reveals SUNSI shall be marked "Contains SUNSI Information" in a conspicuous manner.
- 5.
Neither during nor after this proceeding willi publicly reveal any SUNSI that I receive by virtue of this proceeding as long as the information remains SUNSI and is not otherwise a matter of public record.
- 6.
I acknowledge that any violation of the terms of this affidavit or the ASU3P's Protective Order, which establishes the terms and conditions of this affidavit. may result in the imposition of such sanctions on me that the presiding officer or the Commission deems to be appropriate.
Notary Public
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My cornmission expires: _ ry\\Q..~>--- tJ,,\\ I t J t.d I), ~I
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"'~rx:~:"r" DONNA COLEMAN
{;,-:~~l.#.;.'T;,.~.~.~.,~,~,.:-} d~TrYcPUbliC. State of Texas
'v \\' ommlssion Expires I
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March 11. 2014
NON-DISCLOSURE AFFIDAVIT I, &rr~ tJ kWIli£.
, being duly sworn, state:
(Print Name)
- 1.
I have read the December 21,2010 Atomic Safety and Licensing Board Panel (ASLBP)
Protective Order issued in this proceeding and will comply in all respects with its terms and conditions regarding the Protected Information produced in connection therewith. I will protect and keep confidential all Sensitive Unclassified Non-Safeguards Information (SUNSI), including security related and/or proprietary information in accordance with the terms of this Non-Disclosure Affidavit.
- 2.
I will not disclose SUNSI to anyone except an authorized person. I will protect documents containing or revealing SUNSI in written or recorded form (including any portions of transcripts of in camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI), so the SUNS I contained therein remains at all times under the control of an authorized person and is not revealed to anyone else.
- 3.
When not under my direct control or the direct control of another authorized person, I will keep and protect all documents containing or revealing SUNS I (including, without limitation, transcripts, pleadings I may generate, and any notes and copies that I may make) in a secure locked place such as a filing cabinet, closet, or other storage container. I will not transmit by facsimile transmission any material containing SUNSI.
- 4.
Each document that contains or reveals SUNSI shall be marked "Contains SUNSI Information" in a conspicuous manner.
- 5.
Neither during nor after this proceeding will I publicly reveal any SUNSI that I receive by virtue of this proceeding as long as the information remains SUNSI and is not otherwise a matter of public record.
- 6.
I acknowledge that any violation of the terms of this affidavit or the ASLBP's Protective Order, which establishes the terms and conditions of this affidavit, may result in the imposition of such sanctions on me that the presiding officer or the Commission deems to be appropriate.
REFORE, I do solemnly agree to protect and keep confidential such Protected Information as y e disclos d to me in this proceeding, in accordance with the terms of this affidavit.
Subscribed to and sworn before me this ~
~
of UctMR>tI-, 201Q.
Notary Public My commission expires: _~U~?-=--.,q......::n~V-r'(c.....w:QU).:""-.,j:;,,1-,-1 __
VEllA ANDAVERDE Notary Public. State of Texas My Commission Expires May 10, 2011
NON-DISCLOSURE AFFIDAVIT I,
John C. Halepaska
, being duly sworn, state:
(Print Name)
- 1.
I have read the December 21, 2010 Atomic Safety and Licensing Board Panel (ASLBP)
Protective Order issued in this proceeding and will comply in all respects with its terms and conditions regarding the Protected Information produced in connection therewith. I will protect and keep confidential all Sensitive Unclassified Non-Safeguards Information (SUNS I), including security related and/or proprietary information in accordance with the terms of this Non-Disclosure Affidavit.
- 2.
I will not disclose SUNSI to anyone except an authorized person. I will protect documents containing or revealing SUNSI in written or recorded form (including any portions of transcripts of in camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI), so the SUNSI contained therein remains at all times under the control of an authorized person and is not revealed to anyone else.
- 3.
When not under my direct control or the direct control of another authorized person, I will keep and protect all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings I may generate, and any notes and copies that I may make) in a secure locked place such as a filing cabinet, closet, or other storage container. I will not transmit by facsimile transmission any material containing SUNSI.
- 4.
Each document that contains or reveals SUNSI shall be marked "Contains SUNSI Information" in a conspicuous manner.
- 5.
Neither during nor after this proceeding will I publicly reveal any SUNSI that I receive by virtue of this proceeding as long as the information remains SUNSI and is not otherwise a matter of public record.
- 6.
I acknowledge that any violation of the terms of this affidavit or the ASLBP's Protective Order, which establishes the terms and conditions of this affidavit, may result in the imposition of such sanctions on me that the presiding officer or the Commission deems to be appropriate.
WHEREFORE, I do solemn y agree to protect and keep confidential such Protected Information as may be disclosed to me In this proceeding, in accordance with the terms of this affidavit.
/
/
Subscribed to and sworn before me this.....3l.. day of December Notary Public ('~;/f, ~
My commission expires: ----'9"'1-=2;,,::4!.,./::.20::.,:1:.,:3=---______
, 201.9....
COLLEEN M. DENNIS NOT MY PUBLIC STATE OF COLORADO My Commission Expires 9/241201,
I, Steven L. Lange (Print Name)
NON-DISCLOSURE AFFIDAVIT
, being duly sworn, state:
- 1.
I have read the December 21, 2010 Atomic Safety and Licensing Board Panel (ASLBP)
Protective Order issued in this proceeding and will comply in all respects with its terms and conditions regarding the Protected Information produced in connection therewith. I will protect and keep confidential all Sensitive Unclassified Non-Safeguards Information (SUNSI), including security related and/or proprietary information in accordance with the terms of this Non-Disclosure Affidavit.
- 2.
I will not disclose SUNSI to anyone except an authorized person. I will protect documents containing or revealing SUNSI in written or recorded form (including any portions of transcripts of in camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI), so the SUNSI contained therein remains at all times under the control of an authorized person and is not revealed to anyone else.
- 3.
When not under my direct control or the direct control of another authorized person, I will keep and protect all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings I may generate, and any notes and copies that I rT)ay make) in a secure locked place such as a filing cabinet, closet, or other storage container. I will not transmit by facsimile transmission any material containing SUNSI.
- 4.
Each document that contains or reveals SUNSI shall be marked "Contains SUNSI Information" in a conspicuous manner.
- 5.
Neither dUring nor after Ihis proceeding will I publicly reveal any SUNSllhat I receive by virtue of this proceeding as long as the information remains SUNSI and is not otherwise a mailer of public record.
- 6.
I acknowledge that any violation of the terms of this affidavit or the ASLBP's Protective Order, which establishes the terms and conditions of this affidavit, may result in the imposition of such sanctions on me that the presiding officer or the Commission deems to be appropriate.
WHEREFORE, I do solemnly agree 10 protect and keep confidential such Protected Information as may be disclosed to me in this proceeding, in accordance with the terms of this affidavit.
(Signature)
Subscribed to and sworn before me this 23 day of December Notary Public (~~ /11. D~
My commission expires: _",9/",2"",4'-1.1-=2",0",1",3 ______ _
,201Q...
COLLEEN M. DENNIS NOTARY PUBLIC STATE OF COLORADO My Commission Expires 12 12 13