ML20054C616

Notice That Ms Miller Granted Access to Util Security Plan Data.Notice of Appearance,Affidavit of Nondisclosure & Certificate of Svc Encl

ML20054C616
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/19/1982
From:	Lanpher L KIRKPATRICK & LOCKHART, SUFFOLK COUNTY, NY
To:
References
ISSUANCES-OL, NUDOCS 8204210431
Download: ML20054C616 (8)

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1 UNITED STATES OF AMERICA "7 NUCLEAR REGULATORY COMMISSION

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• BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

LONG ISLAND LIGHTING COMPANY Docket No.

50-32g[\[ 3 (Shoreham Nuclear Power Station

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> gj SUFFOLK COUNTY ADDITION OF COUNSEL h\ ~

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Suffolk County hereby advises that Michael S. Miller?of. the 's/

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law firm of Kirkpatrick, Lockhart, Hill, Christopher & Phillips .

has been granted access to the LILCO security plan data. In accordance with the Board's April 7, 1982 "Further Revision of Protective Order Governing Access to Security Plan Information,"

Suffolk County has received agreement from LILCO and the Staff to Mr. Miller's access to these data. A copy of Mr. Miller's Notice of Appearance and his executed Affidavit of Non-Disclosure (revised per the April 7 Order to permit use of protective informa-tion at the NRC Staff offices) are enclosed.

Respectfully submitted, David H. Gilmartin Patricia A. Dempsey Suffolk County Department of Law Veterans Memorial Highway Hauppauge, New York 11788 Gn unu tup {

Herbert H. Brown '

Lawrence Coe Lanpher Karla J. Letsche KIRKPATRICK, LOCKHART, HILL, d CHRISTOPHER & PHILLIPS 3 8204210431 020419 1900 M Street, N.W., 8th Floor ,

PDRADOCK05000h, Washington, D.C. 20036 //

G (202) 452-7000 April 19, 1982 Attorneys for Suffolk County

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 OL (Shoreham Nuclear Power Station, )

Unit 1) )

NOTICE OF APPEARANCE The undersigned attorney enters an appearance in this proceeding. In accordance with 10 C.F.R. S 2.713, the following information is provided:

Name Michael S. Miller Address Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street, N.W.

Washington, D.C. 20036 Telephone (202) 452-7022 '

Admission District of Columbia Court of Appeals Name of Party Suffolk County fits W Michael S. Miller DATED: April /d , 19 82

,v UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 0.L.

)

(Shoreham Nuclear Power Station, )

Unit 1) )

)

AFFIDAVIT OF NON-DISCLOSURE I, MICHAEL S. MILLER , being duly sworn, state:

1. As used in this Affidavit of Non-Disclosure, (a)

" protected information" is (1) any form of the physical security plan for the Applicant's Shoreham Nuclear Power Station; or (2) any in~ formation obtained by virtue of these proceedings which is not otherwise a matter of public record and which 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 informa-tion; (2) a person who, at the invitation of the Atomic Safety and Licensing Board (" Licensing Board"), has executed a copy of this Affidavit; (3) a person employed by Long Island Lighting Company, the Applicant, and authorized by it in accordance with Commission regulations to have access to protected information,

or (4) counsel for Long Island Lighting Company.

2. I shall not disclose protected ir: formation to anyone except an authorized person, unless that information has previously been disclosed in the public record of this proceeding.

I will safeguard protected information in written form (including any portions of transcripts of in camera hearings, filed testi-mony 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 Licensing 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 Licensing Board.

4. I shall similarly safeguard and hold in confidence any data, notes, or copies of protected information by means of the following:

(a) My use of the protected information will be made at a facility on Long Island to be made available by Long Island Lighting Company or at a facility in Silver Spring, Maryland, made available by the NRC Staff.

(b) I will keep and safeguard all such material in a safe to be provided by Long Island Lighting Company or the NRC Staff, after consultation with Long Island Lighting Company or the Staff, and to be located at all times at the above designated locations.

(c) Any secretarial work performed at my request or under my supervision will be performed at the above locations either (1) by a secretary provided by the Long Island Lighting Company or the NRC Staff authorized in accordance with paragraph 1(b) (3) above, or (2) by one secretary of my designation. I shall furnish Long Island Lighting Company, the Board and Staff an appropriate resume of the designated secretary's background and experience, and that secretary shall comply with paragraph 5 below.

(d) Necessary typing and reproduction equipment will be furnished by Long Island Lighting Company and the NRC Staff.

5. If I prepare papers containing protected information in order to participate in further proceedings in this matter, I will assure that any secretary or other individual who must receive protected information in order to help me prepare those papers has executed an affidavit like this one and has agreed to abide by its terms. Copies of any such affidavit must be filed with and approved by the Licensing Board before I reveal any protected information to any such person, subject to the Licensing Board's April 8, 1982 Order entitled "Further Revision of Protective Order Governing Access to Security Plan Information."

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. l I shall sign the receipt provided by the Applicant with any document I receive that contains protected information. At l l

the conclusion of this proceeding, I shall account to the Licensing

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Board or to a Commission employee designated by that Board for all the papers or other materials (including notes and papers prepared by me) containing protected information in my possession and deliver.them as provided herein. When I have finished using the protected information they contain, but in no event later than the conclusion of this proceeding, I shall deliver those papers and materials to the Licensing Board (or to a Commission employee designated by the Board) , together with all notes and data which contain protected information for safekeeping during the lifetime of the plant.

8. I make this agreement with the understanding that I will not corroborate the accuracy or inaccuracy of information obtained outside this proceeding by using protected information gained through the hearing process.

ad 7EdV Subscribed and sworn to before me this

/64 day of My , 1982.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAPS -

)

In the Matter of )

)

LONG ISLAND LIGHTING COMPANY )

) Docket No. 50-322 (OL)

(Shoreham Nuclear Power Station, )

Unit 1) - )

)

CERTIFICATE OF SERVICE I hereby certify that copies of "SUFFOLK COUNTY ADDITION OF COUNSEL," dated April 19, 1982, have been served to the following on April 19, 1982 by U.S. Mail, first class.

Lawrence Brenner, Esq. Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New Yor' , New York 10016 Washington, D.C. 20555 Howard L. Blau, Esq.

Dr. James L. Carpenter 217 Newbridge Road Administrative Judge Hicksville, New York 11801

• Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Commission W. Taylor Reveley III, Esq.

Washington, D.C. 20555 Hunton & Williams P.O. Box 1535 i Dr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger ,

Washington, D.C. 20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq. Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Stephen B. Latham, Esq.

Mineola, New York 11501 Twomey, Latham & Shea Attorneys at Law Mr. Brian McCaffrey P.O. Box 398 Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801

l Marc W. Goldsmith Mr. Jeff Smith -

Energy Research Group, Inc. Shoreham Nuclear Power Station 400-1 Totten Pond Road P.O. Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.

New York Public Service Commission MHB Technical Associates The Governor Nelson A. Rockefeller 1723 Hamilton Avenue Building Suite K Empire State Plaza San Jose, Californi,a 95125 Albany, New York 12223 Hon. Peter Cohalan David H. Gilmartin, Esq. Suffolk County Executive Suffolk County Attorney County Executive / Legislative County Executive / Legislative Bldg. Building Veterans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Atomic Safety and Licensing Ezra I. Bialik, Esq.

Board Panel Assistant Attorney General U.S. Nuclear Regulatory Commission Environmental Protection Bureau Washington, D.C. 20555 New York State Department of Law Docketing and Service Section 2 World Trade Center Office of the Set:retary New York, New York 10047 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Bernard M. Bordenick, Esq. U.S. Nuclear Regulatory David A. Repka, Esq. Commission

! U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1 Washington, D.C. 20555 Matthew J. Kelly, Esq.

Staff Counsel, New York State Public Service Commission 3 Rockefeller Plaza l

Albany, New York 12223 l . ,9 d?b1/tuf./ . &

! Lawrenc.e Coe Lanphdr i KIRKPATRICK, LOCKHART, HILL,

! CHRISTOPHER & PHILLIPS l

1900 M Street, N.W., 8th Floor Washington, D.C. 20036 April 19, 1982 l

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