ML20039C977

Amend to Petition to Intervene by Soc for Protection of Environ of Southeastern Nh.Affidavits Encl

ML20039C977
Person / Time
Site:	Seabrook
Issue date:	12/23/1981
From:	Chiesa R AFFILIATION NOT ASSIGNED, WADLEIGH, STARR, PETERS, DUNN & KOHLS
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20039C973	List: ML20039C972 ML20039C977
References
ISSUANCES-OL, NUDOCS 8112310164
Download: ML20039C977 (21)

Text

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r~ u p UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION

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.REFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of )

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PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et a1 ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

i MOTION TO AMEND PETITION TO INTERVENE FI'lD BY THE SOCIETY.FOR THE PROTECTION OF THE ENVIRONMENT OF SOUTHEASTERN NEW HAMPSHIRE PURSUANT TO 10 C.F.R. I 2.714 (a) (3)

NOW COMES The Society for the Protection of the Environment of South-eastern New Hampshire and respectfully requests that the Atomic Safety and Licensing Board allow.it to amend its Petition to Intervene dated November 10, 1981, by filing as a part of its Petition affidavits of members of The Society for the Protection of the Environment of Southeastern New Hampshire who have requested that The Society for the Prote: tion of the Environment of Southeastern New Hampshire act in their behalf.

The Affidavits of:

William A. Carey l'

Frederick H. Anderson, Jr.

James M. Hartwell '

Elizabeth P. Hartwell l Ella J. Currier Donald F. Currier i

Elizabeth A. Currier

Ruth S. Miller Corinne W. Morse

Priscilla J. Coffin William E. Amsler, Jr.

Jane M. Amsler Peter D. Oldak Brenda S. Oldak Jasper 'i. Sewell Brian T. Griset Adela J. Griset

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8112310164 811223 PDR ADOCK 05000443 O PDR

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are hereby submitted and are requested to be incorporated with and made a part of The Society for the Protection of the Environment of Southeas::ern Ncv

. Hampshire's' original Petition.

._ Respectfully submitted, THE SOCIETY FOR THE PROTECTION OF THE

- ENVIRONMENT OF SOUTHEASTEIN NEW HAMPSHIRE By-their Attorneys, WADLEIGH, STAILR, PETERS, DUNN & KOFLS

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By/ aC' d $ /N4A

/ Robert L.- Chiesa-Date: December 23, 1981' At: Manchester, N.H.

I hereby certify that copies of the within Motion have been forwarded to the following: Paul B. Cotter, Jr.,-Esquire; Lynn Chong; Bill'Corkum; Gary McCool; E. Tupper Kinder, Esquire; Robert A. Backus, Esquire; Docketing'

& Service Section, Office of the Secretary, U.S. Nuclear Regulatory Commis-sion; Paula Gold, Assistant Attorney General; Jo Ann Shotwell, Assistant Attorney General; Nicholas J. _Costello; Tomlin P. Kendrick; William S.

Jordan, III, Esquire; Ellyn R. Weiss, Esquire; Rep. Arnie Wight; Paul A.

Fritzche, Esquire; Wilfred J. Sanders, Esquire; Thomas G. Dignan,-Jr.,

Esquire; Atomic Safety and Licensing Appeal Panel; Phillip Ahrens,-Esquire; Donald L. Herzberger, M.D.; Edward J. McDermott, Esquire; Sen. Robert L.

Preston; Atomic' Safety and Licensing Board Panel; Edwin J. Reis Esquire and Stephen M. Leonard, Assistant Attorney General.

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Robert L. Chiesa

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)

PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al~. .) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF WILLIAM A.CAREY I, William A. Carey, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since June 22, 1976. I presently reside at the property known as " Cricket Hill Farm" located on Highland Road in South Hampton.

I am sixty-two years old. -

I have been interested in the~ route of the proposed high voltage transmission lines from the Public Service Company of New Hampshire's Seabrook Station and how it affects the Town of South Hampton and its 1

inhabitants.

In August 1980, a small group of South Hampton residents formed an organization known as "The' Society for che Protection of the Environment of Southeastern New Hampshire." I was elected its chairman.- The purpose of the Society is:

"To foster and encourage in public interest the protection of the environmental values of southeastern New Hampshire as regards it aesthetics, historical sites, air and water quality, the natural environment and public health and safety."

The Society engaged the law firm of Wadleigh, Starr, Peters, Dunn &

Kohls to represent it on September 25, 1980. Since that time, we have been active'in appeals directly to the Public Service Company of New Hampshire

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The State of New Hampshire Site Evaluation Committee and the State of New Hampshire Supreme Court petitioning to have' the proposed transmission lines through South Hampton rerouted to another more suitable course.

We are now making this appeal to the Nuclear Regulatory Commission.

I am the spokesman for the Society representing more than three hundred voting citizens of the Town. I have been' authorized by them to speak on their behalf and to assist the Nuclear Regulatory Commission in every way ~

possible.

I hereby authorize the Society to represent me in the hearings before the Nuclear Regulatory Commission. ,

The scope of our interest and the limits of our concert are the routing of the high voltage transmission lines through South Hampton.

Witness: ,

William A. Car &y Date: December , 1981.

Subscribed and sworn to, before me, this day of December, 1981.

i Justice of the Peace / Notary'Public 4

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE ~ COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Un:ts 1 and 2) )

AFFIDAVIT OF FREDERICK H. ANDERSON, JR.

I, Frederick H. Anderson, Jr., being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and that I have been so since February 29, 1976. I presently reside on Jewell Street in the Hilltop Historic District in South

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Hampton. I am. thirty-six years old.

I have been interested in the route of the proposed high voltage

• transmission lines from the Public Service Company of New Hampshire's Seabrook Station and how it affects the Town of South Hampton and its inhabitants. At the South Hampton Town Meeting in March of 1979 I sponsored an ordinance which was passed and required that the lines be buried. In January,1980 the New Hampshire Supreme Court ruled that towns

" lack the power to require underground lines."

In August 1980, a small group of South Hampton residents formed an organization known as "The Society for the Protection of the Environment of Southeastern New Hampshire." I was elected its vice chairman. The purpose of the Society is:

"To foster and encourage in public interest the protection of the environmental values of southeastern New Hampshire as regards its aesthetics,_ historical sites, air and water quality, the natural environment, and public health and safety."

I -

The Society engaged the law firm of Wadleigh, Starr, Peters, Dunn &

Kohls to represent it on September 25, 1980. Since that time we have been active in appeals directly to Public Service Company of New Hampshire, the State of New Hampshire Site Evaluation Committee and the State of New Hampshire Supreme Court petitioning to have the proposed transmission lines through South Hampton rerouted to a more suitable course or buried.

We are now making this appeal .co the Nuclear Regulatory Commission.

I am a spokesman for the Society representing more than three hundred voting citizens of the Town. I have been authorized by them to speak on their behalf and to assist the Nuclear Regulatory Commission in every way possible.

. I hereby authorize the Society to represent me in the hearings before the Nuclear Regulatory Commission.

The scope of our interest and the limits of our concern are the routing of the high voltage lines through South Hampton.

Witness:

i Frederick H. Anderson, Jr.

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! Date s December , 1981.

Subscribed and sworn to, before me, this /7 y of December,1981.

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• U5h Justice of The Peace / Notary Public 9ny c%. t'gj.i. J ->Hf l-

UNITED STATES OF AMERICA'

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD .y p: q. g In the Matter of )

)

PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF JAMES M. HARTWELL I, James M. Hartwell, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since September 3, 1977. I presently reside on Main Avenue in South Hampton. I am fifty-six years old.

My property abuts the right-of-way acquired by Public Service Company in the late 1950's but which has never been used. Any effort by PSC t) enlarge the right of way from the original 150 feet vidth to the State of New Hampshire-mandated 170 feet might involve the taking of my property.

When construction of our home was started in 1976 I had no knowledge of 1.

the PSC right-of-way.

I hereby tuthorize the Society for the Protection of the Environment of Souchesstern New Hampshire Inc. to represent me in the hearings before l the Nuclear Regulatory Commission.

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Witness:

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James M. Hartwell Date: December , 1981 Subscribed and sworn to, before me, this /[, day of December, 1981 Y.($w h hltJf.4s.-

Justice of the Peace / Notary 96blic dstiy .$-)?" W i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M  : 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,%.3 -. !. y . :. ;)-

In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF ELIZABETH P. HARTWELL I, Elizabeth P. Hartwell, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since September 3,1977. I presently reside on Main Avenue in South Hampton. I am fifty-two years old.

My property abuts the right-of-way acquired by Public Service Company in the late 1950's but which has acver been used. Any effort by PSC to enlarge the right of way from the original 150 feet width to the State of New Hampshire-mandated 170 feet might involve the taking of my property.

When ccanstruction of our home was started in 1976 I had no knowledge of the'PSC right-of-way.

I hereby authorize the Society for the Protection of cne Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

Elizabeth P. Hartwell Dates December , 1981 Subscribed and sworn to, before me, this ,

ay of December, 1981

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UNITED STATES'0F AMERICA NUCLEAR REGULATORY COMMISSION qq .,3 6

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF ELLA J. CURRIER I, Ella J. Currier, being duly ' sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since September,1894. I presently reside on Main Avenue in South Hampton. I am eighty-seven years old.

My property includes the right-of-way acquired by Public Service Company in the late 1950's but which has never been used. Any effort by PSC to enlarge the right of way from the original 150 foot width to the State of New Hampshire-mandated 170 feet would involve the taking of more of my property and bringing the edge of the right of way closer to my home and those of my neighbors.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness Ella J. Currier Date s December , 1981 Subscribed and sworn to, before me, this ' day of December, 1981 3

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Justice of the Peace /Norary Public

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,,, , :F UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . . .,i 3

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

y AFFIDAVIT OF DONALD F. CURRIER I, Donald F. Currier, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since October 1934. I presently reside on Main Avenue in South Hampton. I am forty-seven years old.

My property is near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Comission.

Witness:

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Donald F. Currier Dates December , 1981 Subscribed and sworn to, before me, this day of December, 1981 e i . . 1.

Justice of the Peace / Notary Public I - .

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION , , ,3

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF ELIZABETH A. CURRIER I, Elizabeth A. Currier, being duly sworn, depose and say that I am'a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since May,1961. I presently reside on Main Avenue in South Hampton. I am forty years old.

My property is near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

Elizabeth A. Currier Dates December , 1981 Subscribed and sworn to, before me, this ~ day of December,1981

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Justice of the Peace / Notary Public

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

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'31 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT'0F RUTH S. MILLER I, Ruth S. Miller, being duly sworn, depose and say that I am a t resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since July,1946. I presently reside on Whitehall Road in South Hampton. I am eighty-three years old.

My property is in the Jewe11 town Historic District and is near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used. ,

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

Ruth S. Miller Dates December , 1981 Subscribed and sworn to, before me, this /h ay of December,1981

. Y A so.c w Justice of the Peace /Notdry Public

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 71, 9. .

• BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF CORINNE W. MORSE I, Corinne W. Morse, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockin4 am,h State of New Hampshire and have been so since September 1,1943. I presently reside on Whitehall Road in South Hampton. I am seventy-six years old.

My property is in the Jewelltown Historic District and is ' near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

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r. . s < w Corinne W. Korse Dates December , 1981 i

Subscribed and sworn to, before me, this /(/4-day of December,1981 Ydby N) 024wy .

l Justice of the Peace / Notary' Public

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. 1 UNITED STATES OF AMERICA i NUCLEAR PJGULATORY COMMISSION

. , - - ep :14" BCFORE THE ATOMIC SAFETY AND LICENSING IHkRD "i U<

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In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF PRISCILLA J. C0FFIN I, Priscilla J. Coffin, being duly sworn,'de' pose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since July 7,1965. I presently reside on Jewell Street i

in South Hampton. I am sixty-three years old.

My property is in the Jewe11 town Historic District and is near the 4

right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

Priscilla J. Coffin Dates December , 1981 N

Subscribed and sworn to, before me, this /4 ' day of December,1981 t?&n . N blL%

Justice of the Peace / Notary /Public d=-

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UNITED STATES OF AMERICA . . . .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL 50-444 OL

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(Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF WILLIAM E. AMSLER JR.

I, William E. Amsler Jr.,' being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since November 15, 1970. I presently reside on Jewell Street in South Hampton. I am fifty-two years old.

My property is in the Jewelltown Historic District and is near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

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William E. Amsler Jr.

Date s December /', , 1981 Subscribed and sworn to, before me, this /4

$day of December, 1981 Y (br b)- Ylk?,

Justice of the Peace /Nothry PublIc'

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UNITED. STATES OF AMERICA . . .

. NUCLEAR REGULATORY COMMISSION REFORE THE ATOMIC SAFETY AND LICENSING BOARD ,3j ;- 7 p T):1 (, ~

In the Matter of )

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PUBLIC' SERVICE COMPANY OF )

i NEW HAMPSHIRE, et.al. ) Docket Nos. 50-443 OL

) .50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF JANE M. AMSLER I, Jane M. Amsler, being duly sworn, depose and say that I am a i

resident of South Hampton, County of Rockingham, State of!New Hampshire and have been so since November 15, 1970. I presently reside on Jewell Street in South Hampton. I am forty-seven years old.

My property is in the Jewelltown Historic District and is near the right-of-way acquired by Public Service Company in the late 1950's but which has never been used.

I hereby authorize the Society for the Frotection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before

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the Nuclear Regulatory Commission.

Witness: ,

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l Jane M. Amsler -

Date s December . , 1981 l

Subscribed and sworn to, before me, this /[ day of December,1981 Yff&u h$

Justice of the Peace /Not@ Public i

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UNITED STATES OF AMERICA ~ ~

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y 7. eg c, g g In the Matter of )

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PUBLIC SERVICE COMPANY OF ) ,

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT GF PETER D. OLDAK I, Peter D. Oldak, being duly sworn, depose and say that I am a resident of South E2mpton, County of Rockingham, State of New Hampshire and have been so since Deceraber 7,1977. I presently reside on Jewell Street in South Hampton. I am thirty-nine years old.

My property lies in the Jewelltown Historic District along the Pow Wow River and the proposed right of way would pass through my property and this district.

I hareby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission. '

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Witness .T .

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8) lW}YS l Peter D. Oldak l

Dates December J , 1981 l

Subscribed and sworn to, before me, this /[ $' day of December,1981 5$bw h U&

l Justice of the Peac,e/Nafary Public_

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

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',\ t i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD *N I

In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF BRENDA S. OLDAK +

I, Brenda S. Oldak, being duly swo'en, depose and say that I am 'a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since December 7,1977. I presently reside on Jewell Street in South Hampton. I am twenty-nine years old.

My property lies in the Jewelltown Historic District along the Pow Wow River and the proposed right of way would pass through my property and this district.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before

'the Nuclear Regulatory Commission.

Witness: r *

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Brenda S. Oldak

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Dates Decemberic ,' 1981 ft Subscribed and sworn to, before me, this // ~ day of December, 1981 diw $h. htt%-

Justice of the Peace / Notary dublic G C.j,c j. J -)f-)* O'

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD y {-: , ,3; 0}'l *,* 5 In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF JASPER W. SEWELL I, Jasper W. Sewell, being duly sworn, depose and say that I am a ,

resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since May, 1961. I presently reside on Main Avenue in South Hampton. I am sixty-four years old.

My property includes the right-of-way acquiree' by Public Service Company in the late 1950's but which has never been used. Any effort by PSC to enlarge the right of way from the original 150 foot i-idth to the State of New Hampshire-mandated 170 feet would involve the taking of more of my property and bringing the edge of the right of way closer to my home and those of my neighbors. . .

I hereby authorize the Society for the Protection of ths Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness

.0.3.L u r <_; ', .Li Jasper W. Sewell Dates December , 1981 Subscribed and sworn to, before me, this ~ day of December, 1981 Justice of the Peace / Notary Public h, .. 5, -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,SI [E' pj?2];;j In the Matter of )

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PUBLIC SERVICE COMPANY OF )

NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabroo'r Station, Units 1 and 2) )

AFF' DAVIT OF BRIAN T. GRISET I, Brian T. Griset, being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of 1:ew Hampshire and have been so since November 6,1978. I presently reside on Main Avenue in South Hampton. I am twenty-seven years old.

My property includes the right-of-way acquired by Public Service Company in the late 1950's but which has never been used. Any effort by PSC to enlarge the right of way from the original 150 foot width to the State of New Hampshire-mandated 170 feet would involve the taking of more of my property and bringing the edge of the right of way closer to my home and those of my neighbors.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness: ,

Brian T. Griset Date s December , 1981 Subscribed and sworn to, before me, this day of December, 1981

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Justice of the Peace / Notary Public

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING k AR5) bl $ ~!$

In tha Matter of )

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PUBLIC SERVICE COMPANY OF ) l' NEW HAMPSHIRE, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF ADELA J. CRISET I, Adela J. Griset., being duly sworn, depose and say that I am a resident of South Hampton, County of Rockingham, State of New Hampshire and have been so since April,1979. I- presently reside on Main Avenue in South Hampton. I am thirty-one years _old.

My property includes the right-of-way acquired by Public Service Company in the late 1950's but. which has never been used. Any effort by PSC to enlarge the right of way from the original 150 foot width to the State of New Hampshire-mandated 170 feet would involve the taking of more of my property and bringing the edge of the right of way closer to my home and those of my neighbors.

I hereby authorize the Society for the Protection of the Environment of Southeastern New Hampshire Inc. to represent me in the hearings before the Nuclear Regulatory Commission.

Witness:

Adela J. Griset Dates December , 1981 Subscribed and sworn to, before me, this day of December,1981 Justice of the Peace / Notary Public

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