ML20112G343

Affidavit of J Wilson Re Nondisclosing of Safeguards Info. Related Correspondence

ML20112G343
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/26/1985
From:	Joshua Wilson KIRKPATRICK & LOCKHART
To:
Shared Package
ML20112G333	List: ML20112G330 ML20112G343
References
OL-4, NUDOCS 8504010074
Download: ML20112G343 (5)

Text

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UNITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of

. LONG ISLANO LIGHTING COMPANY ) Occket No. 50-322-OL-4

) (Low Power)

(Shoreham Nuclear Generating Plant, )

Unit 1) )

)

AFFIDAVIT OF NON-0ISCLOSURE I, C / [ d , being duly sworn, state:

1. As used in this Affidavit of Non-Disclosure, (a) "protectec information" is (1) any form of the ;;hysical security plan for the Applicant's Shoreham Nuclear Pcwer Station; Or (2) may inferrati:n obtained by virtue of these pecceecings nich is nc: : rer ise a a :e-

. of public record and which deals witn or describes cetails of t.he security plan; (b) an "authori:ed :ersen is (1) an emolcyee of : Pe Nuclear Regulatory C:=ission enti:'ec :o access to cr tectec information; (2) a :ers:n ono, a: tre invita:icn :# :.-. :::ci: Safe:f and Licensing 3:ard ('"_':ersing Scare"), has executec a c::y Of thi !

Pe Affidavit; (3) a ;ers:n emoleyed y _:ng :s'and Lignting C:mpany,

[Ba*A88M BI88lgga

- Applicant, and authorized by it in accordance with Conm ission

- regulations to have access to protected information, or (4) counsel for.

Long Island Lighting Company.

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, icamera hearings, filed testimony or any other documents that contain such inforretion), so that it remains at all times under 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. support services.

3. I will not reproduce any protected information by. any means It is without the Licensing Board's express approval or direction.

understood, however, .that pleadings which are necessary to be preparec i

.in this proceeding can be reproduced, provided that each cocy thereof maintained in confidence as required by the Board's protective orcer l

. described hereafter. 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 foll:wirg:

l l

\

(a) Except as otherwise permitted in the Board's Protective Order entered August 16, 1984, my use of the protected infomation will be made at a facility on Long Island to be made available by Long Island ,

Lighting Company or at a f acility in Silver Spring, Maryland, made available by the NRC Staff.

(b) Except- as otherwise permitted in the Board's protective Order entered August 16, 1984, 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, aad to be located at all times at the above-designated locations.

(c) Except as otherwise permitted in the Board's Protective Order entered August 16, 1984, any secretarial work perfomed at my request or under my supervi. on will be performed at the above locations either (1) by a secretary provided by the Long Island Lighting Ccmpany or the NRC Staff authorized in accordance with paragraph 1(b) above, or (2) by a secretary of my designation who has been authorized by the Board to perfom such work.

(d) Necessary typing and recrodt.ction equi: ment wiii ::e furnished by Long Island Lighting Company and the NRC Staff when secretarial work is perforced at the LILCO or Staff of' fees.

5. I shall use protected information only for the purposes of participation in matters directly pertaining to Suffolk County e d ,

t security contentions and any hearirgs that may te held or any furtner

7 i .

proceedings in this case dealing with security plan issues, and for no other purpose.

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 infomation 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) 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 (including any necessary appeals), I shall deliver those papers and materials that were not destroyed to the Licensing Board (or to a Commission employee designated by the Board), for safekeeping during the lifetime of the plant.

7. I make this agreement with the understanding that I will not corroborate the accuracy or inaccuracy of infomation obtained outside this proceeding by using protected information gained througn 7/'

participation in matters directly pertaining to Suffolk Ccunty's.hu ty flOJ frid

E I security contentions and any hearing that may be held or any further I l

proceedings in this case dealing with security plan issues.  ;

/ / k & //

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Washington, District of Columbia ) ss Sworn to before me this 26th day of March, 1984.

Q/ k abN M otary Public My commission expires:

11r Cc=m!:shrt Crptres rebruary 1(,136

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