ML20094A889

Forwards Executed Affidavit of Nondisclosure Concerning Concerned Citizens of Louisa County Contention 4 Re Security.Related Correspondence

ML20094A889
Person / Time
Site:	North Anna
Issue date:	10/24/1984
From:	Jay Dougherty CONCERNED CITIZENS OF LOUISA COUNTY, DOUGHERTY, J.B.
To:	Wolfe S Atomic Safety and Licensing Board Panel
References
CON-#484-978 OLA-1, OLA-2, NUDOCS 8411060595
Download: ML20094A889 (6)

Text

.

W .

n gC5?.G Y .

?. R~M~ = ' ~ ~ "

,  : .': y.' T. -

~I3rdic JAMES B. DOUGHERTY ATTORNEY AT LAW h gg7 A10:08 Nbb,Yrg! R .r. . t October 24, 1984 SR [y$55 00 D I'I M O-33h ON ~[

Sheldon J. Wolfe, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission PROD. C U;; ,, r,,c,g 3,,3[,h - / .

Washington DC 20555 c n .r. , .... .so-33P g...-2 rnov. :; .:.. . 4.?. .M.7.;DS A -X In the Matter of -

VIRGINIA ELECTRIC AND POWER COMPANY (North Anna Power Station, Units 1 and 2)

Docket Nos. 50-338/339 OLA-1 and OLA-2

Dear Judge Wolfe:

Enclosed please find an executed Affidavit of Non-Disclosure concerning Concerned Citizen's contention regarding security.

- Sincerely, 0

ames B. D ghert encl.

cc: Judges Ferguson and Kline Counsel for Concerned parties Citizens of Louisa County 8411060595 841024 PDR ADOCK 05000338 G PDR

g. b

• 3045 PORTER ST., N.W. WASHINGTON, D.C. 20008 202/362 7158

~

1 .

I p g_ ,. _7 - - _ _ _ . _ ..

7 NED OCT2S UNITED STATES OF AMERICA 4/0;p7 NUCLEAR REGULATORY COMMISSION j,- ,,

ATOMIC SAFETY AND LICENSING BOARD h.iIf $5(I,. l Before Administrative Judges Sheldon J. Wolfe, Chairman Jerry Kline George A. Ferguson In the Matter of )

)

VIRGINIA ELECTRIC AND POWER COMPANY ) Docket Nos. 50-338/

) 339-OLA-1

)

(North Anna. Power Station,

~

)

Units _1 aha 2) )

AFFIDAVIT OF NON-DISCLOSURE I, 3% DovcAKA7v , being duly sworn, state:

1. As used in this Af fidavit of Non-Disclosure, (a) " protected information: is . (1) any form of the physical protection system, including the physical protection system document, for Vepco's spent fuel shipments; or (2) any information obtained by virtue of these proceedings which is not otherwise a matter of public record and which deals with or describes details of the protection system; (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 invitation of the Atomic Safety and Licensing Board (" Licensing Board") , has executed a copy of this Affidavit; (3) a person employed

ll 2 l s

by Vepco, the Applicant, and authorized by it in ac6crdance with Commission regulations to have access to protected information, or (4) counsel for Vepco.

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 proceeding. 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 unde.r the control of an authorized person and is not disclosed to anyone else. It is understood that any secretaries having access to protected information shall execute Affidavits of Non-Disclosure and shall have such access solely for the purpose of necessary typing and other sppport services.

3. I will not reproduce any protected information by any means without the Licensing Board's express approval or direction. It is understood, however, that pleadings which are necessary to be prepared in this proceeding can be reproduced, provided that each copy thereof is maintained l

. in confidence as required by the Board's Protective Order i described hereafter. So long as I possess protected information, I shall continue to take these precautions i, , until further order of the Licensing Board. l l

'h *g

• l

o.'+, .~ .- e e, w w e e < e e e a ,~ s i . . . . . . c'. ..- - si

. l 3

~

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

(a) Except as otherwise permitted in the Board's Protec,tive Order entered sEPhnat 17 , 1984,'my use of the protected information will be made at a facility in Richmond, Virginia to be made available by Vepco.

(b)~ Except as otherwise permitted iri the Board's Protective Order entered 54rnimgER 27, 1984, I will keep and safeguard all such material in a locked file cabinet to be provide,d by Vepco, after consultation with Vepco, and to be located at all times at the above-designated locations.

~

(c) Except as otherwise parmitted in the Board's Protective Order entered S&TGuMIt '17 _, 1984, any secretari-al work performed at my request or under my supervision will be performed at the above locations either (1) by a secretary provided by Vepco, or (2) by a secretary of my designation who has been authorized by the Board to perform such work.

(d) Necessary typing and reproduction equipment will be furnished Vepco when secretarial work is performed at Vepco.

5. I shall use protected information only for the purposes of participation in matters directly pertaining to Concerned Citizens of Louisa County Revised Contencion 4 and any hearings that may be held or any further

'**e, O

. c -4_

, proceedings in this case dealing with physical protection

- system issues, and for no other purpose.

J

6. At the conclusion of this proceeding, I shall account to the Licensing Board or to a Commission employee designated by that Board for all papers or other materials (including notes and papers prepared by me) containing

protected information in my possession. I may either destroy the papers which do not need to be saved (such as unimportant notes) and certify that action in writing, or for papers which need to be saved (such as transcripts),

j may 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 (includ-

! ing any necessary appeals), I shall deliver those papers

and materials that were not destroyed to the Licensing I

Board (or to a Commission employee designated by the f Board), for safekeeping during the lifetime of the plant.

l

7. I make this agreement with the understanding that l

I will not corroborate the accuracy or inaccuracy of 1 information obtained outside this proceeding by using protected information gained through participation in matters directly pertaining to CCLC's Revised Contention 4 and any hearing that may be held or any further proceedings in this case dealing with security plan issues.

r. 1 J1Sr' '

v h

e i

y- ,.,-rw----r,- -,y,--m,--*v.--. - ---w- n - - - - - ,---+*--,---r-*- --

-5 l

Subscribed and sworn to before me this l 2,f day,of 6 ,gr , 1984.

lM l0%

h Aip /%lla,D- c.,

a Mr Comm! sfon Irpirs Mice C 1'9M d

O

? OO 9.

i

. - . , _ , - - _ _ _ . - . , _ , , , - - _ _ _ .