ML20207P740

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Requests Exhibit 3 to AD London in Camera Deposition,Filed on 840831.Protective Order Allowing Disclosure of Matl Encl. Related Correspondence
ML20207P740
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 01/14/1987
From: Horin W
BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20207P741 List:
References
CON-#187-2201 OL-2, NUDOCS 8701200149
Download: ML20207P740 (5)


Text

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RELATED CORRE.SPONDtittCg LAW OFFsCEs OF BISHOP, LIBERMAN, COOK, PURCELL '&CREYNOLDS 8200 SEVENTEENTH STREET, N. W.

WAS HINGTON, D. C. 2003 6 g

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N EW YORM, NEW YORM iOO3e (ala) ro.oioO January 14, 1987 WRtTER'S OsRECT DIAL

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Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Docketing and Service Branch Re:

Texas Utilities Electric Company, et al.

(Comanche Peak Steam Electric Station, OL - S Units 1 & 2); Docket Nos. 50-445-2 & 50-446-2

Dear Sir:

With this letter, I request Exhibit 3 to the in camera deposition of Arthur D. London, filed on August 31 1984, in the Comanche Peak proceeding (Docket Nos. 50-445-2 an 50-446-2).

The deposition is dated August 15, 1984.

(My request does not concern the deposition of the same individual, also taken 1984, but filed on August 20, 1984.)

The exhibit on August 15, am requesting is labeled " London Exhibit 3" consisting of I

five handwritten pages.

As this deposition involves in camera material, I am attaching a copy of the protective order executed in the Comanche Peak proceeding, signed by myself, which allows disclosure of,this material to me.

Since4el b

William A.

Horin Counsel for Applicants Attachment WAH:pah i

)go-8701200149 870114 DR ADOCK 05000445 f

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICE!! SING BOARD In the Matter of

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TEXAS UTILITIES ELECTRIC

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Docket Nos. 50-445-2 COMPANY, et al.

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and 50-446-2

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(Comanche Peak Steam Electric

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Station, Units 1 and 2)

PROTECTIVE ORDER It has come to the attention of the Board that several potential witnesses and other individuals who may have knowledge of issues in this proceeding have been granted pledges of confidentiality by the Applicants and the Intervenor.

Applicants have interviewed or otherwise requested information from their employees regarding certain matters and in doing so have made pledges of confidentiality to them not to release their identity.

Intervenor has advised Applicants of various witnesses, the identities of whom it feels bound not to disclose because it has obtained information from them on a confidential basis.

Both i

feel bound by their pledges of confidentiality even

.part es though release of the identities of these individuals may be necessary for the development of a full record.

In view of the foregoing and at the request of the Parties, it is hereby ORDERED that:

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The party who made a pledge of-confidentiality shall reveal 'to the other parties in this proceeding the identity of an individual to whom the pledge was made, provided those parties sign the Statement of Non-disclosure attached to' this Order, or is an NRC employee subject to the internal requirements of NRC Manual Appendix 2101, concerning the treatment of protected.information; 2.

The party on whose behalf a Statement of Non-disclosure is executs_ shall, prior to the execution of that Statement, notify, the party that pledged confidentiality of its intention to execute such a Statement, including in this notice the identity of the individual intending to execute the Statement.

The party so notified shall have the opportunity _to object to the execution of the Statement of Non-disclosure, provided such objection is made as qui =kly as possible, but in any event, no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after receipt of such notice; 3.

The parties to whom disclosure is made shall not disclose the identity of -he individual, unless required by law, except for purposes of preparing their case in this proceeding and then only when the person to whom disclosure is made acknowledges his obligation to be bound by the terms of this Protective Order by executing the at,tached Statement of Non-disclosure; 4.

The parties shall maintain a separ' ate service list identifying the individuals who receive documents subject to this Protective Order.

These documents shall be identified as subject to.this Protective Order; 5.

Persons who receive information subject to this Protective Order shall use it solely in connection l

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Any' person who has reason to believe that do=uments including protected information have been lost or misplaced or any person who has reason to believe that the terms and conditions of this Protective s

Order have been violated shall notify the 3 card.

It ir so ORDERED.

PETER BLOCH e

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STATE?*.ENT OF NON-DISCLO3URE

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, have been inforhed of a Protective I,

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order issued by the Licensing Board in the Cor.anche Peak cperating license pro =eeding (Docket Nos. 50-445 and 50-446).

I understand that this Order guarantees confidentiality to potential witnesses and others who have disclosed information on a confidential basis to Intervenor or Applicants.

I agree to be bound by the terms and conditions of that Protective order once the. identity of any such individual is revealed to me.

A copy of the Order has been provided to me.

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