ML25206A145
| ML25206A145 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 07/25/2025 |
| From: | Perales M - No Known Affiliation, Perales, Allmon & Ice, P.C., San Antonio Bay Estuarine Waterkeeper |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| RAS 57420, 50-614-CP | |
| Download: ML25206A145 (0) | |
Text
July 25, 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: Non-Disclosure Agreements in the Matter of Long Mott Energy, LLC; Long Mott Generating Station; Docket No. 50-614-CP.
Dear NRC:
Enclosed with this letter are the Non-Disclosure Agreements of the following persons associated with the Requestor San Antonio Bay Estuarine Waterkeeper: Marisa Perales, Sidra Hanson, Gwyneth Lonergan, Diane Wilson, Daniel L, 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 July 25, 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
In the Matter of:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens Docket No. 50-614-CP LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Date: -----
NON-DISCLOSURE AGREEMENT I, lj3ri~ rale.,s
, being duly sworn, state:
- 1.
I have read the uu,._\\ ~ 2 2, 2025 Protective Order issued in the above-referenced proceeding and will c mply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNS!) produced in connection therewith. I will protect and keep confidential all SUNS! in accordance with the terms of this Non-Disclosure Agreement (NOA).
- 2.
I will not disclose the SUNS! to anyone except an Authorized Holder as defined in the Protective Order. I will protect documents containing or revealing the SUNS! 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 SUNS! 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 SUNS! (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 SUNS! in accordance with the terms of the Protective Order.
- 5.
I will transmit SUNS! and file documents containing SUNS! only in accordance with the terms of the Protective Order.
- 6.
I will mark each document containing SUNS! in accordance with the terms of the 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 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 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 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 Protective Order.
- 11.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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.
1-14-2025 iYI~ {2Sl Signature Date Executed (Y\\ a__r '~c}.__ Q) tx e.,n VI rO b IA)
- c.o rY'-
E-mail address (may be used to provide electronic access to SUNSI)
Subscribed to and sworn before me this ~ ':{~day of :::ru l:j, 2025.
Notary Public My commission expires:
w~/:Aq
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens In the Matter of:
LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Docket No. 50-614-CP Date: 7/~4 /25 NON-DISCLOSURE AGREEMENT I, ___
S_!..;;..J_~_;;___Ha,u..
, _'l=So~"--=---' being duly sworn, state:
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
I have read the
- C~ 2.1-, 2025 Protective Order issued in the above-referenced proceeding and will co ~ly in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I will protect and keep confidential all SUNSI in accordance with the terms of this Non-Disclosure Agreement (NOA).
I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the 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.
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.
I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Protective Order.
I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Protective Order.
I will mark each document containing SUNSI in accordance with the terms of the Protective Order.
- 7.
I will not publicly reveal any of the identified SUNS! 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 SUNS!.
- 8.
I will destroy any SUNS! I acquire or generate during this proceeding as required by the Protective Order. I will ensure that any SUNS! 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 Protective Order.
- 9.
I will not use any artificial intelligence (A..l.) 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 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 Protective Order.
- 11.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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.
7/24 //)_5 Signature Date Executed s1£:ln1---;)+-1-et'\\...Vlf0la.w- (.D~
E-mail address (may be used to provide electronic access to SUNSI) 11-Subscribed to and sworn before me this ~ t/
day of 'tl°Q\\'::J
, 2025.
Notary Public My commission expires:
t:e,/-;;. /2. '\\
In the Matter of:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens Docket No. 50-614-CP LONG MOTT ENERGY, LLC (Long Mott Generating Station)
NON-DISCLOSURE AGREEMENT I, c:\\ VV~l"'\\.a.+-h-LoY\\01f":8°'--V\\
, being duly sworn, state:
- 1.
I have read the :Tv~'-1 f'L2-
, 2025 Protective Order issued in the above-referenced proceeding and will comply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I will protect and keep confidential all SUNSI in accordance with the terms of this Non-Disclosure Agreement (NOA).
- 2.
I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the Protective Order. I will protect documents containing or revsealing the SUNSI in written or recorded form (including any portions of transcripts of in-cafoera 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 Protective Order.
- 5.
I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Protective Order.
- 6.
I will mark each document containing SUNSI in accordance with the terms of the 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 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 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 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 Protective Order.
- 11.
I acknowledge that any violation of the terms of this Agreement or the 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 vi'Olate the terms of this agreement or the Presiding Officer's 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 foregoi-ng 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.
1-12-~/ 7-5 Date Executed
~ \\N\\{ r--.f E L\\-t ~
I)( E w
\\.J l \\2__0 U\\ v.). Co'('{\\
E-mail address (may be used to provide electronic access to SUNSI)
Subscribed to and sworn before me this :) '1 day of':) t-\\="
, 2025.
,s Notary Public om,z::.o~)Jc/.H Commonwealth of Pennsylvania., toL1ry Seal Ryan W. Graham, Notary Public Montgomery County My commission expires July 20, 2027 Commission number 1433473 Member, Pennsylvania Association of Notaries
UNITED ST ATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens In the Matter of:
LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Docket No. 50-614-CP Date: -----
ON-DISCLOSURE AGREEMENT
__;;;;.__=.41-;...:_::..:_--4,,a~:::s......=-==-u=:...: being duly sworn, state:
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
I have read the ~
~ 2.Z...., 2025 Protective Order issued in the above-referenced proceeding and will corrlply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I will protect and keep confidential an SUNS! in accordance with the terms of this Non-Disclosure Agreement (NOA).
I will not disclose the SU NSI to anyone except an Authorized Holder as defined in the 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 SUNS! contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.
\\/Vhen not under my direct control or the direct control of another Authorized Holder, l will securely maintain all documents containing or revealing SUNS! (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.
I will restrict access to electronic information systems with SUNSI in accordance wittl the terms of the Protective Order.
I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Protective Order.
I will mark each document containing SU NSI in accordance with the terms of the Protective Order.
- 7.
- 9.
- 10.
- 11. I will not publicly re_veal ~ny ?f th_e identified SUNSI during or after this proceeding. 1 underst~nd that this obligation 1s permanent and survives the termination of this proceeding for as long as the information remains designated as SUNSI.
I will d~stroy any SU!'JSI I acquire or generate during this proceeding as required by the Protective ~rder. I will_ ensure t~at any SU NSI contained in electronic form is permanently deleted using appropnate 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 Protective Order.
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 requ*red by the Protective Order.
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 Protective Order.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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. ~I<!'>
solemnly agree to protect and keep confidential such SUNSI as may be cf1Sdosed to me rn this proceeding, in accordance with the terms of this Agreement Bectronic signatures are not allowed for this Agreement
'5J( v,l Jd~Jj_;JI)~
~A~};J.t:J.;tJ Si nature Oat Exealted w ; l ~GYla.l.v,.p h... ~
g fl I, c..e,.. * -
E-mail address (may be~ to provide electronic access to SUNSI)
Subscribed to and sworn before me this.!l 3 day of~
- 2025.
Notary Public OJft~ ~
My commission expires:
l \\le>{~b CATHY EPLEY NotarY ID #124145291 My Commission Expires JanuarY 30, 2026
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens In the Matter of:
Docket No. 50-614-CP LONG MOTT ENERGY I LLC (Long Mott Generating Station)
- 1.
- 2.
- 3.
- 4.
- 5.
- 6.
NON-DISCLOSURE AGREEMENT
, being duly sworn, state:
I have read the :1ul~ a_~, 2025 Protective Order issued in the above-referenced proceeding and willomply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNSI) produced in connection therewith. I will protect and keep confidential all SUNSI in accordance with the terms of this Non-Disclosure Agreement (NOA).
I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the 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.
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.
I will restrict access to electronic information systems with SUNSI in accordance with the terms of the Protective Order.
I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Protective Order.
I will mark each document containing SUNSI in accordance with the terms of the 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 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 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 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 Protective Order.
11.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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 SUNS! 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.
Si~
--z /:-'1 /
- i.s:
DaExefoted
°D/\\N !:c SANAN112NlaaAYW~£~~f'E:~ -0~
E-maildress (may be used to provide electronic access to SUNSI)
Subscribed to and sworn before me this 21-\\ day of ~vi~'-'~l-j--* 2025.
Notary Public Nelow f\\ f~tZ..O..VV\\
My commission expires:
NELOFAR A FARZAM Notary ID #133600129 My Commission Explr~s F~bruary 18, 2026
In the Matter of:
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens I
Docket No. 50-614-CP LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Date: J14 ~
2-vu-NON-DISCLOSURE AGREEMENT I, G,4,., rW l~
being duly sworn, $lie:
- 1.
I have read the, /4~ 2. ~, 2025 Protective Order issued in the above-referenced proceeding and will 7 mply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information {SUNSI) produced in connection therewith. I will protect and keep confidential all SUNSI in accordance with the terms of this Non-Disclosure Agreement {NOA).
- 2.
I will not disclose the SUNSI to anyone except an Authorized Holder as defined in the 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 Protective Order.
- 5.
I will transmit SUNSI and file documents containing SUNSI only in accordance with the terms of the Protective Order.
- 6.
I will mark each document containing SUNSI in accordance with the terms of the 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 SUNSL
- 8.
I will destroy any SUNSI I acquire or generate during this proceeding as required by the 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 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 SUNS! is entered into or otherwise shared with such services, as required by the Protective Order.
- 10.
If I become aware of any actual or suspected loss, breach, or unauthorized access to SUNS!, I will immediately notify the Presiding Officer, NRC Staff counsel, Applicant's counsel, and the affected party, as required by the Protective Order.
- 11.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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.
mi ion expires:
fl/ 2tJZ4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before the Chief Administrative Judge:
E. Roy Hawkens In the Matter of:
LONG MOTT ENERGY, LLC (Long Mott Generating Station)
Docket No. 50-614-CP Date:0v-) l Sr 1o2-S NON-DISCLOSURE AGREEMENT I, 1'~ ~
L * -S v-..J.c::..u:o. being duly sworn, state:
- 1.
I have read the -Y-'--"-\\'::( "2_ 1._, 2025 Protective Order issued in the above-referenced proceeding and will comply in all respects with its terms and conditions regarding the Sensitive Unclassified Non-Safeguards Information (SUNS!) produced in connection therewith. I will protect and keep confidential all SUNS! in accordance with the terms of this Non-Disclosure Agreement (NDA).
- 2.
I will not disclose the SUNS! to anyone except an Authorized Holder as defined in the Protective Order. I will protect documents containing or revealing the SUNS! 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 SUNS! contained therein remains at all times under the control of an Authorized Holder and is not revealed to anyone else.
- 3.
- 4.
- 5.
- 6.
When not under my direct control or the direct control of another Authorized Holder, I will securely maintain all documents containing or revealing SUNS! (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 SUNS! in accordance with the terms of the Protective Order.
I will transmit SUNS! and file documents containing SUNS! only in accordance with the terms of the Protective Order.
""'" **..,,_~,
- 'I I will mark eacn document corilaining$UNSI in accordance with the terms of the 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 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 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 SUNS! content, and I will ensure that no part of the SUNSI is entered into or otherwise shared with such services, as required by the 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 Protective Order.
11.
I acknowledge that any violation of the terms of this Agreement or the 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 Presiding Officer's 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.
7 / 'L? / lA;J2S Date Executed
-S -.r.M -S ~ !'JI Rs. o~~
E-mail address (may be used to provide electronic access to SUNSI)
Subscribed to and sworn before me this ~
ay of JtJLY
, 2025.
Notary Public VINCENT MOODY flt Notary Public, State of New "l'b,1I Qualified In Onondaga County No. 01MO0027348 Commlaalon Expires July 31, 2029