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Category:AFFIDAVITS
MONTHYEARML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20237A0631998-08-0606 August 1998 Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc ML20236M5181998-06-27027 June 1998 Affidavit.* Affidavit of J Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4871998-06-27027 June 1998 Affidavit.* Affidavit of K Conrad Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5091998-06-27027 June 1998 Affidavit.* Affidavit of Sn Haberman Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5231998-06-27027 June 1998 Affidavit.* Affidavit of SA Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4971998-06-27027 June 1998 Affidavit.* Affidavit of D Bogen Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5061998-06-27027 June 1998 Affidavit.* Affidavit of C Nord Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5401998-06-27027 June 1998 Affidavit.* Affidavit of Eh Mecklejohn Re 980506 License Exemption Request from Operator of Seabrook Station ML20216E0351998-04-13013 April 1998 Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station ML20140B9711997-06-0404 June 1997 Affidavit of FW Getman Per 10CFR2.790,re Great Bay Power Corp'S Filing of Suppl to Petition for Partial Reconsideration of Exemption Order ML20073E1641991-04-19019 April 1991 Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc ML20065K3421990-11-0202 November 1990 Affidavit of Cole.* Discusses Issue of Whether Commonwealth of Ma School Teachers & Day Care Ctr Personnel Perform Roles Contemplated in Spmc ML20065K3451990-11-0101 November 1990 Affidavit of Mc Sinclair.* Responds to Questions Posed by Aslab in ALAB-937 Re Whether Spmc Provides Adequate Supervision & Care of Children Evacuated to School Host Facility at Holy Cross College.W/Certificate of Svc ML20062C2781990-10-19019 October 1990 Affidavit of a Callendrello Addressing Issue Re Staffing of Seabrook Plan for Massachusetts Communities School Host Facility as Discussed in Aslab 900918 Decision.W/Certificate of Svc ML20062C2651990-10-18018 October 1990 Affidavit of Ds Mileti Addressing Issue Whether Massachusetts School Teachers & Day Care Ctr Personnel Would Respond to Assignments in Emergency to Escort Children on Buses ML20059M6201990-09-24024 September 1990 Affidavit of GL Iverson.* Responds to Statements Made in Mc Sinclair 900907 Supplemental Affidavit.W/Certificate of Svc ML20059B0021990-08-22022 August 1990 Affidavit of RW Donovan Re Staffing Adequacy for Implementation of New Hampshire Radiological Emergency Response Plan for Plant.W/Certificate of Svc ML20059A9981990-08-21021 August 1990 Affidavit of Jc Dolan Re Adequacy of Staffing for Implementation of New Hampshire Radiological Emergency Response Plan for Plant ML20059B0281990-08-21021 August 1990 Affidavit of GL Iverson Re Position of Governor Media Ctr representative.Twenty-second Initial Vacancy Was New Hampshire Public Utils Commission Lead Engineer ML20059A8911990-08-16016 August 1990 Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc ML20056B2251990-08-0606 August 1990 Affidavit of Mc Sinclair.* Affidavit Re Offsite Radiological Emergency Response Planning for State of Nh & Spmc ML20081E2431990-07-31031 July 1990 Affidavit of a Desrosiers Re Evacuation of Advanced Life Support Patients ML20081E2471990-07-31031 July 1990 Affidavit of B Cohen Re Evacuation of Advanced Life Support Patients ML20081E2401990-07-31031 July 1990 Affidavit of Rl Goble Re Preparation of Advanced Life Support Patients for Evacuation ML20081E2511990-07-31031 July 1990 Affidavit of Sj Plodzik Re Evacuation of Advanced Life Support Patients ML20055G6521990-07-11011 July 1990 Affidavit of T Urbanik Re Licensee Motion for Summary Disposition of Advanced Life Support Patients Issue.* Addresses Issues Re Preparation of Advanced Life Support Patients.W/Certificate of Svc ML20058K8011990-06-25025 June 1990 Affidavit of Am Callendrello.* Addresses Issues Defined by ASLB in LBP-90-12 Re Preparation of Advanced Life Support Patients for Evacuation & Impact on Special Population Evacuation Time Estimates.W/Certificate of Svc ML20058K7811990-06-25025 June 1990 Affidavit of J Bonds.* Addresses Issues Defined by ASLB in LBP-90-12 Re Advanced Life Support Patients & Consideration of Preparation Time for Evacuation Under State of Nh Radiological Emergency Response Plan.W/Certificate of Svc ML20058K7841990-06-25025 June 1990 Affidavit of D Albertson.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20058K7941990-06-25025 June 1990 Affidavit of Kj Callahan.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20012C6701990-03-15015 March 1990 Affidavit of Rd Pollard.* Advises That Deficiencies Cited in INPO & Other Repts Demonstrate No Basis for Finding That Reactor Complies W/Nrc Regulations or Can Be Operated Safely ML20012C7121990-03-13013 March 1990 Affidavit of Be Beuchel.* Addresses Intervenors Allegations & Whether Significant Safety Issue Present Re Rosemount Transmitters.Supporting Info,Including Beuchel Prof Qualifications & Certificate of Svc Encl ML20006G1151990-02-26026 February 1990 Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation ML20011F1291990-02-16016 February 1990 Affidavit of WT Wallace.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan.Supporting Info Encl ML20011F1281990-02-16016 February 1990 Affidavit of GL Iverson.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan ML19351A7051989-12-0606 December 1989 Affidavit of TC Feigenbaum.* Advises That Further Delay in Obtaining Full Power License for Plant & Reaching Commercial Operations Caused by Further Litigation Will Be Very Costly & Unnecessary.W/Supporting Info & Certificate of Svc ML19332F9701989-11-30030 November 1989 Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl ML19332D7011989-11-22022 November 1989 Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc ML20006C4371989-11-21021 November 1989 Affidavit of AA Kelsey.* Discusses Radio Coverage in Merrimac Valley.W/Supporting Info & Certificate of Svc ML19332D5701989-11-17017 November 1989 Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit ML19332D5301989-11-14014 November 1989 Affidavit of Am Callendrello.* Refutes Intervenors Allegations That Util No Longer Able to Provide Emergency Info to Public as Result of Withdrawal of Agreement Between Util & Wcgy.W/Supporting Info ML19332D5441989-11-14014 November 1989 Affidavit of Gr Gram.* Confirms Util Adherence to 870914 Commitment to Provide Certain Svcs & Equipment for Planning & Implementation of Alerting Sys.W/Supporting Info & Certificate of Svc ML19332D5361989-11-13013 November 1989 Affidavit of Gj Catapano.* Denies Intervenors Allegations That Util Incapable of Providing Prompt Emergency Instructions to Public in Light of Withdrawal of Certain Agreements.Supporting Info Encl ML19354D5121989-11-0909 November 1989 Affidavit of R Boulay Re Voiding of Emergency Broadcast Sys Ltrs of Agreement.* Since Wcgy Voided Ltr of Agreement W/ Util & Withdrew from Emergency Plan,Broadcast Sys for Merrimac Valley Cannot Be Activated.Related Info Encl ML19354D5141989-10-30030 October 1989 Affidavit of R Sawyer Re Voiding of Emergency Broadcast Sys Ltr of Agreement.* Marked-up Affidavit Discussing Impact of Wcgy Voiding Ltr of Agreement W/Util & Withdrawing from Participating in Emergency Planning.W/Certificate of Svc ML19327B7021989-10-27027 October 1989 Affidavit of Jf Bassett Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Fact That Applicant Has Never Followed Through on Commitment to Provide Ebs Equipment,Per 870914 Ltr of Agreement.Supporting Info Encl ML19327B7061989-10-26026 October 1989 Affidavit of Dj Rowe Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Applicant Refusal to Live Up to Commitments to Commonwealth of Ma Ebs.W/ Supporting Info & Certificate of Svc 1999-01-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
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DOCKETED DOCKETED USNRC ggge UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .. . . .
before the 1 33 Ec -1 A969 ATOMIC SAFETY AND LICENSING BOARI G OfflCE OF SECRETI#
D 00CKETIMG & SDVIEl ERANCH
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY )
OF NEW HAMPSHIRE, et al. ) November 28, 1983 (Seabrook Station, )
Units 1 and 2) )
)
AFFIDAVIT OF JO ANN SHOTWELL I, Jo Ann Shotwell, being duly sworn, hereby depose and say as follows:
1., I am an Assistani, Attorney General in the Department of the Attorney General for the Commonwealth of Massachusetts and the counsel of record for the Department in this proceeding. I was'present at and participated in the hearings before the ASLB
<fhich were held on August 17 - 19, 23, and 31, 1983.
- 2. During my cross-examination of Applicants' witnesses in the afternoon of August 17, Judge Hoyt began to read from the Department's pre-filed cross-examination p. tan. The transcript of the August 17 hearing does not accurately reflect Judge Hoyt's reading Fro- t3 e plan. That portion of the August 17 transcript-appeccins .c. page 1063, lines 17-18, which reads
- B312020186 831128 PDR ADOCK 05000443 O PDR t
--v , n m, - , , - - - ~ < - , , ,.v4-
,,--r-- +- -- -----v-, , ,...--.v -w - w - , -
e
" Judge Hoyt: I believe we're into adverse weather effect?"
should read " Judge Hoyt: I believe we're into adverse weather affects . . . .
- 3. The transcript of the August 17 hearing is further inaccurate in its trar :cription of a statement made by Judge Hoyt later in the day with respect to her earlier reading from the Commonwealth's cross-examination plan. The transcript, at ,
page 1159, line 21, has Judge Hoyt denying that she had revealed the Commonwealth's " cross-examination status." In fact, Judge Hoyt denied having revealed the Commonwealth's
" cross-examination strategy." This fact is further confirmed by a report of Judge Hoyt's statement which appeared in The Boston Globe on the morning of August 18, 1983. A true copy of that article is attached hereto.
t 4. The transcript of the August 18 hearing is inaccurate in its report of a statement which I made with respect to what arguments relative to the admissibility of the Commonwealth's testimony I had addressed in my arguments the previous day. !
indicated, in response to Judge Hoyt's inquiry, that I had no further response to the arguments made "to date," not "today" as indicated in the transcript, at page 1165, line 7. In fact, no arguments on testimony had even been made on August 18 prior to my statement.
- 5. The transcript of the August 18, 1983 hearing is inaccurate in its record of testimony given by the Commonwealth's witness. That portion of the witness' testimony transcribed at Page 1216, lines 18-20, should read as follows to correctly reflect what was in fact said: "I'm glad Chief Mark is no longer here -- I parked illegally because I was unable to find short-term, available parking. I live-parked."
And that portion of the witness' testimony transcribed at Page 1246, lines 5-7, should read as follows to accurately reflect his testimony: "Yes, with some frequency -- reteorological phenomena, in particular as they relate to storm warning, are an important consideration in land planning work...".
Signed under the pains and penalties of perjury this 28th day of November, 1983.
o Ann Shotwbfl a , DO ~'
COMMONWEALTH OF MASSACHUSETTS Suffolk, ss.
Jo Ann Shotwell, appeared before me and swore that she has read this affidavit and that the statements contained in it are true to the best of her knowledge and belief.
Before me, AsD.%
Notary Pupli4/
My commission expires on [Am . /d /f/ '7
18.1983' '
tgages Mass temporarily ousted at Xplant talks By Chris Chinlund .J
- i cadbecaine evident. -
'" [u y 2 The sparring crupted into open 'debate wher Globe Correspondent y Iloyt in discussing the schedule for cross-ec St01,e DOVER. N.ll. - An angry exchange between ; }
a blassachusetis assistant attorney general and
,) amination, began to reveal the area In whic!
a Nuclear Regulatory Commission administra- g r . Shotwell intended to direct her next round c tivejudge yesterday led to the temporary expul- y questions to witnesses for Public Service Co EPROGRAM .ston of htassachusetts from the first day of hear- p. '
Shotwell jumped up. Interrupting ihe adminis Ings on an operating license for the Scabrook +,
i traltvejudge..and objected that her cross exam 0
' g.
0 LOWER PAYMENTS ' . : nation outline had, like that of other lawyere M. (
nuclear power plant. ? .
j g Judge llelen Iloyt ordered htassachuetts out r been submitted to'the bench with the underr CATION FEE of the proceedings after Jo Ann Shotwell refused q.;;
P. /g j ,) .
- d. standing it would Iloyt ordered be kept Shotwell confidential.
to sit down, bul a balloon or vadable to apologize for her strenuous objections to a {3';f.} g.. .
rate first or second comment from the judge thal. she said, under- d'4,. .M ,
g] 4;@; 3 if Shotwell continued to voice her objections, unt' mortgage to a long tenn mined her cross-examination of utility officials. ' 9A .
!' the court baliff walked to her table and ap fixed rate and payment h[L
- Later in the day of tense hearings. Shotwell .
!) . Peared ready to enforce thejudge's order.
g schedule which can apologized for the tone, but not the substance.
- ' y 4- ,
,Iloyt. saying that "In seven years in admin.
bring peace of nund. of her remarks. That quallfled apology was l' u.d djY lstrative proceedings I've never fun addressed No Lmut-Any Purpose enough to persuade lloyt to reqdmit the state to The Money Store gg.c proceedings, which are bcIng hekt by the /
\7 .dl.1
..in .that tone by counsel." demandext Shotwell
. apologize. Replied Shotwell. "I will not do so.
. makes loans in any NR.'*s Atomic Safety and Licensing Board. Moyt 1, , L, . ! %; madam." With that, she was climinated froni o
tin ate pu os a all, is JO ANN SIIOTWELL I
[ofa a the hottest moment in the
.;S ,f f . Iloyt again demamktl an apol pg ,{oan Info I ftrst f 1I days of technical hearings on whether gers a quaHHed apology .
.i. .; . ogy ar'd Shotwell said: "I will not apologize for the Public Service Company of New Ilampshire ! * < - 1 .
the substance of my objections, although I caid Instant Phone Approval say there was no intent to offend any member of
..g r y " should be granted a license to operate the twin. :liavejoined to question Seabrook's safety.'
owner a d you h e d nuclear reactor it is constructing at Seabrook. In cross-examination. Coalition lawyer . the board. . " Later, in a statement read to to borrow money for The seacoast plant is nehr the borders of both Diane Curran ellcted testimony from a company the court, lloyt answered Shotivell's criticism, any reason at all, a call Afassachusetts and Maine. witness that 20 percent of safety 'related elec.J. denying she has revealerl hfassachusetts to my friends at The Massachusetts entered the case to argue that tronic equipment for Seabrook has not been ; cross-examination strategy." She would not Money Store could save the evacuation plans, submitted by Public Ser- "quallfled." or assured as adequate for the ; discuss the matter with reporters. .
you time and money, vice Co. for use in case of a nuclear accident, are strain it is expected to withstand. She called '. Shotwell, however, said lloyt discriminated
" inaccurate and unre!!able." that a reason for concern but a company law. fagainst Massachusettsin the hearings.She sug-WlE MBHEY STORE- New llampshire has joined the proceedings' yer said most of the necessary assurances are
- gested that the board. which is an appendage of mssemms e.c anmums to question whether Public Service Co.*s plans expected before the first reactor begins operat.. . the NRC, was not interested in hearing chal MMRANDOLPH U!E 986 Torr for notifying state officials of an accident are' ingin 1985.
sufficient. Maine, too. Is a party to the case.
- Ienges to a Scabrook license because the NRC staff has already decided it should be granted.
.BROCKTON 5802550 In addition, two groups skeptical of nuclear. Much of yesterday's proceedings involved _/ She said she decided to offer a partial apology so
. out er Aree can Ton Free
' power - the Scacoast Anti Pollution League and technical arguments, during which the tension she could continue to represent Massach,useti
-me Nu##TsYons ou - the New England Coalition on Nuclear Pollution between lloyt and some of the parties to the in the matter. .
MMMhg Chelsea mayor says he'll resign Sept. 7 .
i
CERTIFICATE OF SERVICE
'883 30-1 A'p:01 I, Jo Ann Shotwell, Esquire, counsel for Massachusetts Attorney General Francis X. Bellotti, hereby certify that ,2 8 , 1983, I
%,d made service of Motion For Reconsideration Of Boa tEdrney November 10, 1983 (Sustaining In Part And Denying General Bellotti's Motion For Correction Of Transcript") and Affidavic of Jo Ann Shotwell by mailing copies thereof, postage prepaid, to the parties named below:
Helen Hoyt, Chairperson Rep. Beverly Hollingworth Atomic Safety and Licensing coastal Chamber of Commerce Board Panel 209 Winnacunnet Road U.S. Nuclear Regulatory Commission Hampton, NH 03842 Washing ton, DC 20555 Dr. Emmeth A. Luebke William S. Jordan, III, Esquire Atomic Safety and Licensing Diane Curran Board Panel Harmon & Weiss U.S. Nuclear Regulatory Commission 1725 I Street, N.W.
Washington, DC 20555 Suite 506 Washington, DC 20006 Dr. Jer ry Harbour Eduard L. Cross, Jr., Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel Dana Bisbee, Esquire U.S. Nuclear Regulatory Commission Assistant Attorney General Washington, DC 20555 Office of the Attorney General 208 State House Annex Concord, NH 03301 Atomic Safety and Licensing Appeal Roy P..Lessy Board Panel Deputy Assistant Chief U.S. Nuclear Regulatory Commission Hearing Counsel Washington, D C 20555 U.S.N.R.C.
7735 Old Georgetown Road Bethesda, Maryland 20814 Guard Call - X27505
Atomic Safety and Licensing Robert A. Backus, Esquire Board Panel 116 Lowell Street U.S. Nuclear Regulatory Commission P O. Box 516 Washington, DC 20555 Manchester, NH 03105 Philip Ahrens, Esquire Dr. Mauray Tye Assistant Attorney General Sun Valley Association Department of the Attorney 209 Summer Street General Haverhill, MA 01830 Augusta, ME 04333 Carole F. Kagan, Esq. Thomas G. Dignan, Jr., Esquire Atomic Safety and Licensing Robert K. Gad, III, Esquire Board Panel Ropes & Gray U.S. Nuclear Regulatory Commission 225 Franklin Street Washington, DC 20555 Boston, MA 02110 Charles Cross, Esquire Ms. Olive L. Tash Shaines, Madrigan, & McEachern Designated Representative of 25 Maplewood Avenue the Town of Brentwood P.O. Box 366 R.F.D. 1, Dalton Road Portsmouth, NH 03801 Brentwood, NH 03833 Roberta C. Pevear Edward F. Meany Designated Representative of Designated Representative of
.. the Town of Hampton Falls the Town of Rye Drinkwater Road 155 Mashington Road Hampton Falls, NH 03844 Rye, NH 03870
, Mrs. Sandra Gavutis Calvin A. Canney Designated Representative of City Manager l
the Town of Kensington City Hall
! RFD 1 126 Daniel Street East Kingston, NH 03827 Portsmouth, NH 03801 Richard E. Sullivan Jane Doughty Town Hall Field Director Newburyport, MA 01950 Seacoast Anti-Pollution League 5 Market Street Portsmouth, NH 03801 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory l
Commission l Washington, DC 20555 i
f i
Brian P. Cassidy Representative Nicholas J. Costellc Regional Counsel 1st Essex District FEMA Region 1 Whitehall Road John W. McCormack Post Office Amesbury, MA 01913
& Courthouse Boston, MA 02109 Mr. Angie Machiros, Chairman Diana P. Randall 2 Ncwbury Board of Selectmen 70 Collins Street Town of Newbury, MA 01950 Seabrook, NH 03874 Patrick J. McKeon Anne Verge, Chairperson Chairman of Selectmen, Rye, Board of Selectmen New Hampshire Town Hall 10 Central Road South Etmpton, NH 03842 Rye, NH 03870 Donald E. Chick Maynard B. Pearson Town Manager Board of Selectmen Town of Exeter 40 Monroe Street 10 Front Street Amesbury, MA 01913 New Hampshire 03833 Selectmen of North Hampton Mr. Daniel Girard Town of North Hampton Civil Defense Director New Hampshire 03862 25 Washington Street Salisbury, MA 01930 Senator Gordon J. Humphrey Senator Gordon J. Humphrey 1 Pillsbury Street U.S. Senate Concord, NH 03302 Washington, D.C. 20510 (Attn: Herb Boynton) (Attn: Tom Burack)
Signed under the pains and penalties of perjury, this 28th day of November, 1983.
^
Ann Shotwelio/
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Assistant Attorney General Environmental Protection Division Public Protection Bureau One Ashburton Place Boston, MA 02108
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