ML19338C412
| ML19338C412 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/13/1980 |
| From: | Hamilton P CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | |
| Shared Package | |
| ML17083A469 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8008150374 | |
| Download: ML19338C412 (7) | |
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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275
)
50-323 (Diabic Canyon Nuclear Power Plant,
)
Units 1 and 2)
)
)
AMENDED AFFIDAVIT OF NON-DISCLOSURE 0
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,being duly sworn, state:
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As used in this Affidavit of Non-Disclosure, (a) " Protected information" is (1) any form of the physical security plan for the licensee's Diablo Canyon Nuclear Power Plant, Units 1 and 2; or (2) any information obtained by virtue of these pro-ce'e' dings which is not otherwise a matter of public
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,s record and whi~ch deals with. or describes details of the security plan. -
(b)
An " authorized person" is (1) an employee of the Nuclear Regulatory Commission entitled to access to protected information; (2) a person who, at the invi-tation of the Atomic Safety and Licensing Appeal Board
(" Appeal Board"), has executed a copy of this affidavit; or (3) a person employed by Pacific Gas and Electric SfesL54)374
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. Company, the licensee, and authorized by it in accordance with Commission regulations to have access to protected information.
2.
I shall not disclose protected information to anyone except an authorized person, unless that information has previously been disclosed in the public record of this pro-ceeding.
I will safeguard protected information in written form (including any portions of transcripts of in camera hearings, filed testimony or any other documents that contain such information), so that it remains at all times under the control of an authorized person and is not disclosed to anyone else.
3.
I will not reproduce any protected information by any means without the Appeal Board's express approval or direction.
So long as I possess protected information, I shall continue to take these precautions until further order of the Appeal Board.
4.
I shall similarly safeguard and hold in confidence any data, notes, or copies of protected information and all other papers which contain any protected information by means of the following:
(a) my use of the protected information will be made at a facility in San Francisco to be made available by Pacific
Pv
. Gas and Electric Company.
I will keep and saf eguard all such material in a (b) safe to be obtained by intervenors at Pacific Gas and after consultation with Electric Company's expense, Pacific Gas and Electric Company and to be located at all times at the above designated location.
An'y secretarial work performed at my request or (c) under my supervision will be performed at the above I
location by one secretary of my designation.
shall furnish Pacific Gas and Electric Company, the Board and Staff an appropriate resume of the secretary's background and experience.
Necessary typing and reproduction equipment will (d) be furnished by Pacific Gas and Electric Company.
All mailings by me involving protected information (e) shall be made from the f acility furnished by pacific Gas and Electric Co.
If I prepare papers containing protected information 5.
in order to participate in further proceedings in this case, I will assure that any secretary or other individual who must I
receive protected information in order to help me prepare those i
papers has executed an affidavit like this one and has agreed Copies of any such affidavit will be to abide by its terms.
l filed with the Appeal Board before I reveal any protected l
information to any such parson.
6.
I shall use protected information only for the purpose of preparation for this proceeding or any further proceedings in this case dealing with security plan issues, and for no other purpose.
7.
I shall keep a record of all protected information in my possession, including any copies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Appeal Board or to a Commission employee desig-nated by that Board for all the papers or other materials containing protected information in my possession and deliver them as provided herein.
VTnen I have finished using the pro-tected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Appeal Board (or to a Commission employee designated by the Board), together with all notes and data 1
which contain protected information for safekeeping during the lifetime _of the plant.
8.
I make this agreement with the following understandings:
(a) I do not waive any objections that any other person may have to executing an affidavit such as this one; (b) I will not corroborate the accuracy or inaccuracy of information obtained outside this proceeding by using protected information gained through the hearing process.
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Nodary Public Mr F^=~% sics Er;:m Febu=y 14, 1935
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.PAULETTE 11AMILTON l
2693-Arlington Drive, v203 Alexandria,_ Virginia 22306 703-765-5270.
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EDUCATION:
Henderson Institute Henderson, North Carolina 27536 Graduated June 1967 North Carolina Agricultural & Technical University Greensboro, North Carolina 27411 i
Graduated June 1971-B.S.
Office Administration Hunter College New York City, New York 1973 to 1974 masters program in business education EMPLOYMENT HISTORY:
Mainzer Minton Co.,
Inc.
437 Fifth Avenue New York, New York Administrative Secretary 1971 to 1975 Suoerior Career Institute 116 West 14th Street New York City, New York Administrative Assistant 1975 to 1979 Hill, Christopher & Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Legal Secretary - Presently employed with this law firm.
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CLERICAL SKILLS:
i
-Typing Speed 85/90
-Dictaphone skills
-Shorthand Speed 90/100
-Able to do own correspondence
-Experienced in Litigation
-Some bookkeeping skills
-Interviewing of clerical Energy law and' criminal law applicants for jobs PERSONAL REFERENCES CAN BE SUBMITTED UPON YOUR REQUEST.
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 O.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power Plant,
)
Units 1 and 2)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the " MOTION OF GOVERNOR EDMUND G.
BROWN, JR. FOR REVISION OF NON-DISCLOSURE AFFIDAVIT AND FOR REVISION OF THE PREHEARING SCHEDULE" in the above-captioned proceeding have been served on the following in the manner and on the date indicated below.
Richard S.
Salzman, Esq., Chairman
- Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Dr. W.
Reed Johnson
- Atomic Safety and Licensing Appeal Board U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 Mr. Thomas S. Moore, Member
- Atomic Safety and Licensing Appeal Board U.
S.
Nuclear Regulatory Commission Washington, D.
C.
20555 William J. Olmstead, Esq.
l Executive Legal Director's Office l
Nuclear Regulatory Commission Washington, D.
C.
20555 Andrew Baldwin, Esq.
601 California Street Suite 21.00 i
San Francisco, CA 94108 Mr. Harry M. Willis 601 California Street Suite 2100 San Francisco, CA 94100 f
2.
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s, Herbert H.
Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P. C.
1900 M Street, N. W.
Washington, D. C.
20035 August 13, 1980 4
By hand on August 13, 1980 By Federal Express on August 13, 1980 I
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