ML25338A339

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Waterkeeper Amended Non-Disclosure Agreements
ML25338A339
Person / Time
Site: 05000614
Issue date: 12/04/2025
From: Perales M
Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper
To:
NRC/SECY
SECY RAS
References
RAS 57547, ASLBP 25-991-01-CP-BD01, 50-614-CP
Download: ML25338A339 (0)
v • d • e


Text

December 4, 2025 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemakings and Adjudications Staff Via Electronic Information Exchange System RE: Amended Non-Disclosure Agreements in the Matter of Long Mott Energy, LLC; Long Mott Generating Station; Docket No. 50-614-CP, ASLBP No. 25-991-01-CP-BD01.

Dear NRC:

Enclosed with this letter are the Amended Non-Disclosure Agreements of the following persons associated with the Requestor San Antonio Bay Estuarine Waterkeeper:

Marisa Perales, Sidra Hanson, Gwyneth Lonergan, Diane Wilson, Dr. Edwin Lyman, and Timothy Judson.

Respectfully submitted, Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.

1206 San Antonio St.

Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)

Counsel for San Antonio Bay Estuarine Waterkeeper

2 CERTIFICATE OF SERVICE Pursuant to 10 C.F.R. § 2.305, I hereby certify that, on December 4, 2025, copies of the foregoing letter were served upon the Electronic Information Exchange (the NRCs E-Filing System), in the above-referenced docket.

Signed (electronically) by Marisa Perales Marisa Perales Texas Bar No. 24002750 marisa@txenvirolaw.com PERALES, ALLMON & ICE, P.C.

1206 San Antonio St.

Austin, Texas 78701 512-469-6000 (t) l 512-482-9346 (f)

Counsel for San Antonio Bay Estuarine Waterkeeper

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL In the Matter of LONG MOTT ENERGY, LLC (Long Mott Generating Station)

Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 Date: ------

AMENDED NON-DISCLOSURE AGREEMENT I, Ha r-l':,ol-., ~--C.,I" ~ \\LS

' being duly sworn, state:

1.

I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I also have read the December 1, 2025 Amended Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SUNSI in accordance with thy terms of the Non-Disclosure Agreement (NOA) that I previously executed on::f'u.ld ';;l '-t, 2025 and I will continue to protect and keep confidential all SUNSI in accordanc with the terms of this Amended NOA.

2.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

3.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNSI. I will only transmit using facsimile when there are no other forms of electronic transmission available.

4.

I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Amended Protective Order.

Attachment 1

5.

I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. I understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electronic form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence {A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Officer may deem to be appropriate. I also acknowledge that if I am involved in the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

, 2eftr_oniq sign~es r?J not allowed for this Agreement.

v;;_Bf----tt" ~

J l- ~ - ~tJ J,S Signature Date Executed fY\\ ~ r i sa._6) +x-e.n \\/L r-o law. CJ) rt'--"

E-mail address (may be used to provide electronic access to SUNSI)

Subscribed to and sworn before me this q+b day of D e...c e,nb I?-;

, 202 5.

Notary Public

/

/

My commission expires: _....,(.... o_,'-:i._,_-==i_~ v),___ ____________ _

In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros Docket No. 50-614-CP LONG MOTT ENERGY, LLC ASLBP No. 25-991-01-CP-BD01 Date: !-Z./ '3 /'25 (Long Mott Generating Station)

AMENDED NON-DISCLOSURE AGREEMENT I, ___

..oc'S;:::i.~c..:J,,.c:...:.o1....::_-'--'l-h::..:::...f\\$:::_o::..:l'L=---* being duly sworn, state:

1.

I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNS!) produced in connection therewith. I also have read the December 1, 2025 Amended Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SUNSI in accordance with the terms of the Non-Disclosure Agreement (NOA) that I previously executed on ::r_,~ '.Z-'::t

, 2025 and I will continue to protect and keep confidential all SUNS! in accordan with the terms of this Amended NOA.

2.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

3.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNSI. I will only transmit using facsimile when there are no other forms of electronic transmission available.

4.

I will restrict access to electronic information systems with SUNS! in accordance with the terms of the Amended Protective Order.

" 2 "

5.

I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. I understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electronic form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence (A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Officer may deem to be appropriate. I also acknowledge that if I am involved in the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

Electronic signatures are not allowed for this Agreement.

~~ /2./ 3 /15 Signature D9te Executed E-mail address (may be used to provide electronic access to SUNSI)

Notary Public My commission expires: _l,/.Ll-.L.-1-c5.-'-'--------------

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL In the Matter of LONG MOTT ENERGY, LLC (Long Mott Generating Station)

Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 AMENDED NON-DISCLOSURE AGREEMENT I, GivJ"(O.,e_,,,:fu Lof\\.eJt0iM, being duly sworn, state:

1.

I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNS!) produced in connection therewith. I also have read the December 1, 2025 Ame.nded Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SUNSI in accordance with the terms of the Non-Disclosure Agreement (NOA) that I previously executed on "J:vb-4 2-3

, 2025 and I will continue to protect and keep confidential all SUNS! in accordance with tlJe terms of this Amended NOA.

2.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

3.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNS!. I will only transmit using facsimile when there are no other forms of electronic transmission available.

4.

I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Amended Protective Order.

Attachment 1

5.

I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. I understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electronic form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence (A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Qfficer may deem to be appropriate. I also acknowledge that if I am involved iri the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

Electronic signatures are not allowed for this Agreement.

<ti

&£ s!~~ Date Executed E-mail address (may be used to provide electronic access to SUNSI)

S.Libscribed to and sworn be Nol::ary Public

  • . My commission expires:

Commonwealth of Pennsylvania - Notary Seal Justin J. Scheuering, f\\lotary Public My commission expires February 26, 2029 Commission number 1456719 Member, Pennsylvania Association of Notaries

UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros In the Matter of Docket No. 50-614-CP LONG MOTT ENERGY, LLC (Long Mott Generating Station)

ASLBP No. 2~991-01-CP-8001 Date: k

'ij 2 e:;, -;i_i;-

1.
2.
3.
4.

ON-DISCLOSURE AGREEMENT I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all, respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I also have read the December 1, 2025 Amended Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SU NSI in accordance with the terms of the Non-Disclosure Agreement (NOA) that I previously executed on *:su Iii 2 ~

2025 and I will continue to protect and keep confidential all SUNSI in accordance with the terms of this Amended NOA.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNS!),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNS!. I will only transmit using facsimile when there are no other forms of electronic transmission available.

I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Amended Protective Order.

Attachment 1

5.

I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. t understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNS!.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electroo.c form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence (A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer. NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Officer may deem to be appropriate. I also acknowledge that if I am involved in the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

E-mail address (may be use to provide electronic access to SUNSI)

Notary Public My commission e CYNTHIA JOYCE ALFORD Notary ID #12563)714 My Commission Expires April 3, 2026 4~ayo~

~

, 2026.

In the Matter of UNITED STATES OF AMERICA NUCLEAR REGULA TORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros Docket No. 50-614-CP LONG MOTT ENERGY, LLC ASLBP No. 25-991-01-CP-BD01 Date:

/2-- / i J ~_s--

(Long Mott Generating Station)

AMENDED NON-DISCLOSURE AGREEMENT L ! lvlettt being duly swam, state:

J

1.

I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I also have read the December 1, 2025 Amended Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SUNSI in accordance with the terms of the Non-Disclosure Agreement (NOA) that I previously executed on ':Jl<-lj-1... 3, 2025 and I will continue to protect and keep confidential all SUNSI in accordance with the terms of this Amended NDA.

2.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

3.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNSI. I will only transmit using facsimile when there are no other forms of electronic transmission available.

4.

I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Amended Protective Order.

Attachment 1

5.

I will transmit SUNS! and file documents containing SUNS! only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. I understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electronic form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence (A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Officer may deem to be appropriate. I also acknowledge that if I am involved in the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

Ele re not allowed for this Agreement.

/2- /y /2-J--

Date Executed

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL In the Matter of LONG MOTT ENERGY, LLC Before Administrative Judges:

Stefan R. Wolfe, Chair Dr. David A. Smith Nicholas G. Trikouros Docket No. 50-614-CP ASLBP No. 25-991-01-CP-BD01 (Long Mott Generating Station)

Date: U ~ c.e.,_\\o~ '--\\, c c:S2S AMENDED NON-DISCLOSURE AGREEMENT I,

\\"i.l"'V'-0tL,'1" L:-:fCA.J.S,:.,A.being duly sworn, state:

1.

I have read the July 22, 2025 Protective Order issued in the above-referenced proceeding and certify that I have complied in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I also have read the December 1, 2025 Amended Protective Order issued in the above-referenced proceeding and will continue to comply in all respects with its terms and conditions, including any future amendments thereto. I certify that I protected and kept confidential all SUNSI in accordance with the terms of the Non-Disclosure Agreement (NOA) that I previously executed on T.,.,..':r; 2-5, 2025 and I will continue to protect and keep confidential all SUNSI in accordance ith the terms of this Amended NOA.

2.

I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Amended Protective Order. I will protect documents containing or revealing the SUNSI in written or recorded form (including any portions of transcripts of in-camera hearings, filed testimony, or any other documents that contain or reveal such SUNSI),

so that the SUNSI contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.

3.

When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNSI (including, without limitation, transcripts, pleadings that I may generate, and any notes and copies that I may make). I will not transmit by unsecured methods any material containing SUNSI. I will only transmit using facsimile when there are no other forms of electronic transmission available.

4.

I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Amended Protective Order.

Attachment 1

5.

I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Amended Protective Order.

6.

I will mark each document containing SUNSI in accordance with the terms of the Amended Protective Order.

7.

I will not publicly reveal any of the identified SUNSI during or after this proceeding. I understand that this obligation is permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.

8.

I will destroy any SUNSI I acquire or generate during this proceeding as required by the Amended Protective Order. I will ensure that any SUNSI contained in electronic form is permanently deleted using appropriate deletion tools and not merely placed in a recycle bin or trash folder. If requested, I will certify such deletion or provide evidence of destruction in accordance with the Amended Protective Order.

9.

I will not use any artificial intelligence (A.I.) tools, large language models, or machine learning services to process or analyze any SUNSI content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the Amended Protective Order.

10.

If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNSI, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the.affected party, as required by the Amended Protective Order.

11.

I acknowledge that any violation of the terms of this Agreement or the Amended Protective Order, which incorporates the terms of this Agreement, may result in the imposition of such sanctions on me that the Presiding Officer may deem to be appropriate. I also acknowledge that if I am involved in the actual or anticipated disclosure of the SUNSI or otherwise violate the terms of this agreement or the Amended Protective Order, then the entity or person that produced the information or*

another affected entity or person might pursue legal or equitable remedies against me personally, and this includes, but is not limited to, potential civil or criminal penalties under applicable law.

WHEREFORE, I do certify under penalty of perjury that the foregoing is true and correct, and I do solemnly agree to protect and keep confidential such SUNSI as may be disclosed to me in this proceeding, in accordance with the terms of this Agreement.

s are not allowed for this Agreement.

{'2.. / 61: /2-o 2-S' Date Executed E-mail address (may be used to pro'de electronic access to SUNSI)

Subscribed to and sworn before me this !i!!}_ day of J)te£/J.J5 r~, 202.E_.

Notary Public My commission expires: -"-0~lJ~l--l_.,j __ 3~)-+1_2._o_-z.B~-------------

VINCENT MOODY Ill Notary Public, Stata of Naw York Qualified In Onondaga '.Cll.lJDW-----;-:2/'

~11=-.-+=--#------

No. 01MO0027346 Commission Expires July 31, 20211

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