ML20082E474

Affidavit of RW Potter Re Applicant Failure to Serve Public Advocate of Nj W/Fsar & Amends

ML20082E474
Person / Time
Site:	Hope Creek
Issue date:	11/21/1983
From:	Potter R NEW JERSEY, STATE OF
To:
Shared Package
ML20082E462	List: ML20082E454 ML20082E474 ML20082E491
References
ISSUANCES-OL, NUDOCS 8311280208
Download: ML20082E474 (3)

Text

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DOCKETED USHRC

'83 NOV 25 Ai053 UNITED STATES OF AMERICA g77;;g ; 3gggggg 000r.LIWG ^ SEW NUCLEAR REGULATORY COMMISSION EPAllCH Before the Atomic Safetv_and Licensing Board In the Matter of  :

PUBLIC SERVICE ELECTRIC  :

AND GAS CO., et al.,  : Docket No. 50-354 OL (Hooe Creek Generating  :

Station, Unit 1),  :

AFFIDAVIT REGARDING THE APPLICANT'S FAILURE TO SERVE THE PUBLIC ADVOCATE WITH THE FSAR AND AMENDMENTS THERETO I, R. William Potter, of full age, being duly sworn, upon my oath, depose and say that:

1. I am counsel of record in this proceeding for the intervenor, Joseph H. Rodriguez, the Public Advocate of the State of New Jersey. Since February, 1982 I have been the Assistant Commissioner of the Department of the ,

( Public Advocate.

2. On or about November 1, 1983 I asked Roger 4

Camacho, Director of the Public Advocate's Rate Counsel Division to determine if PSE&G had filed the FSAR, and 8311280208 831121 PDR ADOCK 05000354 O PDR

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amendments thereto, at the Rate Counsel office. Rate Counsel is located at 744 Broad Street, Newark almost across the street from PSE&G's headquarters building.

3. Mr. Camacho searched the of fice and conf erred with Theodore Granger, Esq., the attorney who filed the Public Advocate's petition to intervene on September 9, 1983. They determined that PSE&G had not filed the FSAR or any amendments thereto.

4. I then asked Mr. Camacho to inquire through the usual channels at PSE&G as to whether, and if so, He replied when PSE&G intended to file these documents.

that he or his secretary would call Lawrence R. Codey, Esq.,

counsel to PSE&G or his secretary to answer any questions.

5. On or about November 1, Ms. Carol Franciose, secretary to Mr. Camacho, called back to inform me that she had spoken with Mr. Codey's secretary, Ms. Cookie Cortiss, who had informed her that PSE&G was doing its best to asremble a copy of the full FSAR, and that we would be served with it when a copy was available. .

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6. On November 21, I called Mr. Camacho and Ms. Franciose to ask if they had heard anything further J from PSE&G regarding the delivery of the FSAR. They informed me that they would try again.

7 Ms. Francoise called back at about 2:30 P.M. -

EST to report that Ms. Cortiss said that PSE&G was still assembling the FSAR. Ms. Cortiss said it was not likely

, to be ready for hand-delivery in Salem, New Jersey at the November 22 prehearing conference. (I had suggested that method as a practical way to serve the Public Advocate with the full 18-volume report; we could simply transfer it from one auto trunk to the other.)

8. In short, as of November 21, at 2:45 P.M. EST, PSE&G has not yet filed the FSAR and amendments thereto on the only party in this proceeding, the Public Advocate of the State of New Jersey. '

Dated: November 21, 1983 4

, lih R. WILLIAM POTTER Assistant Commissioner /

Assistant Public Advocate Sworn and Subscribed State of New Jersey ,

Department of the Public Advocate to before me thisd/Mday of November, 1983.

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