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{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of                                          August 2, 2012 NextEra Energy Seabrook, LLC                              Docket No. 50-443-LR (Seabrook Station, Unit 1)
ASLBP No. 10-906-02-LR AFFIDAVIT OF RAYMOND SHADIS CONCERNING MANDATORY DISCLOSURE REQUIREMENT OF 10 C.F.R. § 2.336 I, Raymond Shadis, do hereby state as follows:
: 1. I am pro se representative for Friends of the Coast and New England Coalition (Friends/NEC), in the above captioned proceeding.
: 2. In reviewing documents in my possession and those in possession of intervenors, Friends/NEC, I have not identified any documents upon which Friends/NEC intends to rely at hearing, or which are otherwise relevant to the admitted contention(s) and subject to the disclosure under 10 C.F.R. § 2.336 other than those already provided to the Board and the parties with the Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions, Oct. 20, 2010.
: 3. It is Friends/NECs intention to identify access, obtain, and/or gather such documents and provide them in timely fashion according to the disclosure terms and periodicity delineated in 10 C.F.R. §§ 2.336 and as modified by the Atomic Safety and Licensing Boards Initial Scheduling Order dated April 4, 2011 (as amended Orders, August 23, 2011 and October 3, 2011), and the Boards Memorandum and Order (Granting Joint Motion Regarding Mandatory Disclosures, November 10, 2011.
: 4. Friends/NEC has yet to identify and select an expert witness to provide support for its contention(s) in the hearing phase of the above captioned proceeding.
: 5. I hereby certify that all relevant materials which Friends/NEC is required to disclose as of July 15, 2012 in the captioned proceeding have been disclosed.
: 6. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief.
(signed electronically)
Raymond Shadis Executed in Edgecomb, Maine this 2nd day of August, 2012 Raymond Shadis Friends of the Coast/New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801}}

Latest revision as of 01:13, 12 November 2019

Affidavit of Raymond Shadis Concerning Mandatory Disclosure Requirement of 10 C.F.R. 2.336
ML12215A569
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 08/02/2012
From: Shadis R
Friends of the Coast, New England Coalition
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 23193, 50-443-LR, ASLBP 10-906-02-LR-BD01
Download: ML12215A569 (2)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of August 2, 2012 NextEra Energy Seabrook, LLC Docket No. 50-443-LR (Seabrook Station, Unit 1)

ASLBP No. 10-906-02-LR AFFIDAVIT OF RAYMOND SHADIS CONCERNING MANDATORY DISCLOSURE REQUIREMENT OF 10 C.F.R. § 2.336 I, Raymond Shadis, do hereby state as follows:

1. I am pro se representative for Friends of the Coast and New England Coalition (Friends/NEC), in the above captioned proceeding.
2. In reviewing documents in my possession and those in possession of intervenors, Friends/NEC, I have not identified any documents upon which Friends/NEC intends to rely at hearing, or which are otherwise relevant to the admitted contention(s) and subject to the disclosure under 10 C.F.R. § 2.336 other than those already provided to the Board and the parties with the Friends of the Coast and New England Coalition Petition for Leave to Intervene, Request for Hearing, and Admission of Contentions, Oct. 20, 2010.
3. It is Friends/NECs intention to identify access, obtain, and/or gather such documents and provide them in timely fashion according to the disclosure terms and periodicity delineated in 10 C.F.R. §§ 2.336 and as modified by the Atomic Safety and Licensing Boards Initial Scheduling Order dated April 4, 2011 (as amended Orders, August 23, 2011 and October 3, 2011), and the Boards Memorandum and Order (Granting Joint Motion Regarding Mandatory Disclosures, November 10, 2011.
4. Friends/NEC has yet to identify and select an expert witness to provide support for its contention(s) in the hearing phase of the above captioned proceeding.
5. I hereby certify that all relevant materials which Friends/NEC is required to disclose as of July 15, 2012 in the captioned proceeding have been disclosed.
6. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information and belief.

(signed electronically)

Raymond Shadis Executed in Edgecomb, Maine this 2nd day of August, 2012 Raymond Shadis Friends of the Coast/New England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801