ML20116N557

Affidavit of Nondisclosure of Ta Constantine.Related Correspondence

ML20116N557
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/30/1985
From:	Constantine T LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20116N554	List: ML20116N548 ML20116N557 ML20116N558
References
OL-4, NUDOCS 8505070254
Download: ML20116N557 (5)

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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0mI5510N ATOMIC 5AFETY AND LICENSING 80ARD DeCMETED USNRC

, '85 MY -6 N1 :37 0FFICE OF SECRETAR V l 00CKETING & SERVICI.  !

_, BRANCH l J

In the Matter of J

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Docket No. 50-322-OL-4 LOM !$ LAND LIGHTI M COMPANY (Low Power)

(Shoreham Nuclear Generating Plant,

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AFFIDAVIT OF NON-0ISCLOSURE

[, THOMAS A. CONSTANTINE ,being duly sWoen, state:

1. As used in this Affidavit of Non-Disclosure, (a) "protecteo information" is (1) any form of the physical security plan for the Applicant's Shoreham Nuclear Power Station; or (2) any infor-ati:n l

obtained by virtue of these proceedings which is co: ::Perdise a atte- l of public record and which deals with or describes cetails of the security plan; (b) an "authori:ed :erson is (1) an employee of the d l Nuclear Regulatory Comissian entitled to ac:ess to crotected information; (2) a person wno, at the invitation of tne At::fc Safs )

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' and Licensing Board ("'.f censing Boarc"), has executed a c:sy of this Affidavit; (3) a pers:n employed by L:ng *sland Lighting C:mpany, tre i

8505070254 850503 - i PDR ADOCK 05000322 i

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Applicant, and authorized by it in accordance with Consission 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 I I will safeguard protected in the public record of this proceeding.

n informationinwrittenform(includinganyportionsoftranscriptsofin,

,f g hearings, filed testimony or any other documents that contain such information), so that it remains at all times under the control of ,

It is an authorized person and is not disclosed to anyone else.

understood that any secretaries having accer,s to protected information shall execute Affidavits of Non-Disclosure and shall have such acce solely for the purpose of necessary typing and other support services.

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

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understood, however, that pleadings which are necessary to be preparec h in this proce,eding can be reproduced, provided that each copy there j

maintained in confidence as required by the Board's protective or:er f

So long as I possess protected information, I i described hereafter. 1 shall continu,e to take thesF precautions until further order of the I

j Licensing Board. l i

4. I shall similarly safeguard and hold in confidence any data.-

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notes, or copies of protected information by means of the follcwing:

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. 1 (a) Except as otherwise permitted in the Board's Protective Order entered August 16, 1984, my use of the protected infomation witi 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 NAC Staff.

,, (b) Except as otherwise permitted in the Board's Protective 1 Order entered August 16, 1984, I will keep and safeguard all such I material in a safe to be provided by Long Island Lighting Company or the

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' 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) Except as otherwise permitted in the Board's Protective Order entered August 16, 1984, 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) above, or (2) by a secretary of my designation who has been authorized by the h

Board to perform such work.

! (d) Nece.ssary typing and repredt.ction equip. Tent will be furnished by Long Island Lighting Company and the NRC Staff when secretarial work is perforced at the LILCO or Staff of* ices.

5. I shall use protected information only for the purposes of participation in matters directly pertaining to Suffolk Cougg y

' security contentions and any hearings that may be held or any further l

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9 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 Comission employee designated by that Board for all papers or other materials (including notes and papers prepared by I may either me) containing protected information in my possession.

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 Comission 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

orroborate the accuracy or inaccuracy of infcmation cbtained outside this proceeding by using protected infseation gained througn N

participation in matters directly pertaining to Suffolk Ccunty's c Y

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security contentions and any hearing that may be held or any further proceedings in this case dealing with security plan issues.

Washington, District of Columbia ) ss

i Sworn to before me this k dast of- 8 4 , 1985.

Notary My comunission expires:

THOMAS R. MONTEFORTE NOTARY PUBLIC, Stateof New York No.2750ess OrangeCounty PMAEspiresMarch4198[

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