ML20116N548

Forwards Affidavits of Nondisclosure of Ta Constantine & J Whittel,Per State of Ny Request.Related Correspondence

ML20116N548
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	05/03/1985
From:	Mark Miller KIRKPATRICK & LOCKHART
To:	Bright G, Johnson E, Kelley J Atomic Safety and Licensing Board Panel
Shared Package
ML20116N554	List: ML20116N548 ML20116N557 ML20116N558
References
CON-#285-869 OL-4, NUDOCS 8505070250
Download: ML20116N548 (1)

Text

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% KIRKPATRICK & LOCKHART 1900 M STREET. N.U.

WASHINGTON. D C. 20016 oht nosTcNttAct l nosToN. MA CUM TELEPHONE L2c2) 452 7000 ,ei y engjo 1428 BRX3II.L AVENLE 009 ,744112 May 3, 1985 unus.s. una 'E MY -6 NI :36,m.s.<m. .,, nm 000 4$17022 (412, M54WD Judge James L. Kelley, Judh hyhight Chairman Atomic and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

- Judge Elizabeth B. Johnsan Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830

Dear Administrative Judges:

enertT NUMBER M 00.k UTI M .8 L e d *

• h At the request of Fabian G. Palomino, Esq., counsel for the State of New York in the Shoreham low power remand proceed-ing, we are today filing the attached Affidavits of Non-Disclosure of Thomas A. Constantine and John Whittel. Colonel Constantine and Senior Investigator Whittel are both veteran members of the New York State Police who have thorough knowledge of and actual experience with the activities and operations of terrorists in the New York /Long Island area. See the Affidavit of Thomas i

Constantine'and John Whittel attached to the Response of Suffolk County and the State of New York to LILCO's Petition for Review of ALAB-800, dated March 18, 1985. It is our understanding that Mr. Palomino, on behalf of the State of New York, seeks to have Colonel Constantine and Investigator Whittel designated as

- " authorized persons" according to Paragraph 1(b) of the Miller Board's August 17, 1984 Protective Order.

For the Board's information, the following information regarding Colonel Constantine and Senior Investigator Whittel and their access to safeguards information is provided. It is )

our understanding that such information was required by the i Miller Board's August 17 Protective Order.

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Thomas A. Constantine I New York State Police State Campus Albany, New York 12226 ll 1.

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4 4 KIRKPATRICK & LOCKHART

' Judge James L. Kelley, Chairman Judge Glenn O. Bright

' Judge Elizabeth B. Johnson Page Two May 3, 1985 Was not an " authorized person" under the Brenner Board's Revised Protective-Order Governing Access to Security Plan Information, dated June 9, 1982 Has signed Affidavit of Non-Disclosure in form provided by Miller Board on August 16,

1984.

John Whittel New York State Police

? State Campus Albany, New York 12226 Was not an " authorized person" under the Brenner Board's Revised Protective Order Governing Access to Security Plan Information, dated June 9, 1982 Has signed Affidavit of Non-Disclosure in form provided by Miller Board on August 16, 1984.

l Sincerely, Michael S. Miller'

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• Enclosures cc: Fabian G. Palomino, Esq.

Donald P. Irwin, Esq.

Robert Perlis, Esq.

Docketing and Service

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