ML19350B480
| ML19350B480 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/13/1981 |
| From: | Gold P, Leonard S, Shotwell J MASSACHUSETTS, COMMONWEALTH OF |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19350B478 | List: |
| References | |
| NUDOCS 8103200637 | |
| Download: ML19350B480 (19) | |
Text
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] UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION TO: HAROLD R. DENTON DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION RE: CONSTRUCTION PERMITS CPPR-135 CPPR-136
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos.
NEW HAMPSHIRE, et al. ) 50-443
) 50-444 (Seabrook Station, Units 1 and 2) )
)
ME40RANDUM OF THE COMMONWEALTH OF MASSACHUSETTS IN SUPPORT OF SEACOAST ANTI-POLLUTION LEAGUE' S REQUEST FOR AN ORDER TO SHOW CAUSE DATED JUNE 30, 1980.
INTRODUCTION The Commonwealth of Massachusetts (" Commonwealth")
participated in the construction permit licensing proceedings for the Seabrook Station in an effort to protect the interests of its residents who either reside in comrunities or frequent beaches in the vicinity of that station. Because of these interests, the Commonwealth remains concerned about the issue of emergency evacuation at Seabrook.
On June 30, 1980, the Seacoast Anti-Pollution League
( " SAPL" ) filed with the NRC a request that the Commissioners review a decision rendered ~ by the Director of the Of fice of Nuclear Reactor Regulation (" Director") on February 11, 1980.
In that decision the Director had denied a petition filed by
- 810 320 il N m . _ .
. i SAPL on May 2,1979, pursuant to 10 C.F.R. 52.206 seeking an Order to Show Cause why construction permits for the proposed nuclear power plant at Seabrook should not be suspended or revoked. As grounds for its petition SAPL cited, inter alia, the failure of the licensee, Public Service Company of New Hampshire, to demonstrate during the construction permit process the f easibility of evacuation beyond the low population zone.
The Commission, in October, 1980, decided not to review the Director's denial of SAPL's petition, but directed the staff to treat the June 30th SAPL request for Commission review as a new petition for a Show Cause Order under 52.206.
The Commonwealth supports the current SAPL request fcr an Order to Show Cause why the Seabrook construction permits should not be suspended or revoked 1/ for the following reasons:
- 1. The Director denied SAPL's May, 1979 petition on the basis that it was premature to reopen the Seabrook construction permit proceedings until certain events had transpired. Those events having transpired, the Director should now approve the reques'c f or =n Order to Show Cause.
- 2. There has been no determination of the feasibility-of safely evacuating the-population within the 10-mile plume exposure Emergency Planning Zone of the Seabrook Station. Present evidence suggests that such evacuation may not be feasible.
- 3. It is in the interest of all parties that the feasibility of evacuation be assessed now, rather than at the operating license stage of review. If the present evidence suggesting that evacuation is 1/ The Commonwealth also filed a Memorandum in support of SAPL's May,1979 request.
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not f easible is later confirmed, the applicant faces the loss of hundreds of millions, perhaps billions, of dollars of wasted invesenent. At the same time, residents of and visitors to the EPZ face the possibility that the Licensing Board, moved by the expenditure of these sums, will permit operation despite the absence of truly adequate means of evacuation.
I. THE PRE-CONDITIONS TO ISSUANCE OF THE ORDER SET FOR3 'BY WE DIRECTOR HAVE BEEN MET In his February 11, 1980 denial of SAPL's petition for an Order to Show Cause, the Director concluded that it would be a " premature" to reopen the Seabrook construction permit
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proceedings pending (1) the receipt and evaluation of evacuation time estimates prepared by the licensee; (2) adoption of the then proposed rules amending 10 C.F.R. Part 50 regarding emergency planning;2'/ and (3) " guidance from the Commission" on reconsideration of construction permits.3/
l In August of last year Public Service Company of New Hampshire submitted its evacuation time estimates to the Commission. In December, 1980, the Commonwealth received notice that the Commission had completed an analysis of a.1 evacuation time estimates which it had received. On August 19, 1980 the Commission published its final regulations on 4
emergency planning, ' am ending 10 C.F.R. Part 50, which regulations took effect on November 3, 1980.5/
2/_ 44 Fed. Reg. 75167 (December -19, 1979) .
3/ Public Service Co=oany of New Hampshire, et al., DD 80-6, 11 NRC-371, at 373 (Feoruary 11, 1980).
4/ 45 Fed. Reg. 55402'(August 19, 1990).
--*-+e, w w ., -w-- , e -~ , .-e ee -m - -e m o < n - w--
Thus, the first two events which, in the opinion of the Direc tor , had to occur before consideration of th' emergency '
planning issue would be timely have, in fact, occurred. Eince the Commission has issued its final regulations on emergency planning, there is no reason to expect further formal
" guidance" from the Commission regarding the reconsideration of construction permits. The Commission has not, to far as we are aware, given notice of any intention to issue further formal guidelines in this area. The Director should, therefore, now grant SAPL's petition fer an Order to Show Cause.
II. THERE HAS BEEN DO DETERMINATION OF THE FEASIBILITY OF EVACUATION WITHIN THE SEABROOK EPZ In its Final Regul?tions on Emergency Planning, amending 10 C.F.R. Part 50,E/ the Commission now requires appropriate emergency planniac for the evacuation of persons beyond the low population zone of all light-water nuclear power plants, such as the Seabrook facility. A plume exposure Emergency Planning Zone having a radius of about ten miles must now be established around each such plant, with the exact size and shape of the EPZ to be decided on the basis of specific conditions at the-site. Licensees must submit emergency plans providing for S/ 45' Fed. Reg. 55402 (August 19, 1980).
evacuation within the plume exposure EPZ's as part of their final safety analysis reports, and those plans must be approved prior to issuance of operating licenses.
While the Final Regulations on Emergency Planning do not require that cperators already holding construction permits demonstrate compliance with the new requirements before the
- operating license stage of review, the Commission expressly noted in a statement J.ccompanying its publication of the pror sed rules which preceded those final regulations 5/ that it was "considering whether construction permits which have '
already been issued should be reccissidered because of the emergency planning considerations of the [ proposed rules]."
The Director quoted this Commission statement in his decision denying the May,1979 SAPL petition and further observed that in December,1979 the NRC staff requested all licensees of plants under construction to submit evacuation time estimates so that the Commission would be in a position to identify those plants where " unusual evacuation constraints exist and special planning measures should be considered."1/
Such " unusual evacuation constraints exist" in the case of the Seabrook plant. It is therefore one of the instances i
f/ 44 Fed. Reg. 75167, (December 19, 1979).
t 7/ 11 NRC 371, at 373 (1980).
, anticipated by the Staff where construction permits should be reconsidered and, if necessary, special planning measures ordered.
From the beginning of the Seabrook construction permit proceedings, the NRC Staff has maintained that it has the authority to require a demonstration of the feasibility of evacuating persons beyond the LPZ because of the proximity of the Seabrook units to coastal beaches, the inadequacy of sheltering f acilities along the coast, and the limited road networks serving the beaches.S/ This position has been suppor ted by NBCNP, the Attorney General of New Hampshire, and the NRC Advisory Committee on Reactor Safety.E! There is thus a clear recognition of the unusual difficulties associated with evacuation of the beaches near the Seabrook facility.
Within about a five-mile radius ^f the Seabrook units there is an estimated summer peak population of approximately 100,000- persons, with the-majority being clustered in the beach areas lying from' northeast to south-southeast of the site.1SI It is undisputed that even-when the seasonal population is 8/ See Public Service Company of New Hampshire ALAB - 390, 5 NRC 733, at 735-36-(1977).
9/ See Id.; Letter from the Chairman of the ACRS to the Chairman of the AEC reviewing Seabrook application (December 10,-1974) [ Relevant language quoted at 5 NRC 751] .
10/ Public Service Company of New Hampshire, et al.,
LBP-76-26, 3 NRC 857, at 871-72 (June 29, 1976).
, time-weighted, population densities at the Seabrook site exceed the " trip points" of Regulatory Guide 4.7 for both plant start-up and retirement.11/ And the Licensing Appeal Board has determined that the beach area located just over one and
, one-half miles from Seabrook is the nearest population center to the site, since it will "at times be the most densely populated area in 'he state."12/
SAPL has filed affidavits prepared by civil defense directors and other officials of New Hampshire towns in the vicinity of the Seabrook facility. Attached hereto are similar affidavits prepared by municipal officials in Massachusetts. ,
Based on their past experiences with large beach crowds and J
their. knowledge of the limited access roads and traffic " choke"
, points.which exist in their areas, these local officials have l serious concerns about the feasibility of evacuating their communities in a timely fashion.
In June of 1975, extensive evidentiary hearings were conducted, over the objection of the Applicant, before the Atomic Safety and Licensing Board on the issue of the i
feasibility of evacuating persons beyond the Seabrook LPZ, and particularly from Hampton Beach. There was conflicting 11/ See Seabrook Alternative Site Study, NUREG-0501, at A-60 (December, 1978).
12/ See Public Service Company of New Hampshire, ALAB-422, 6 NRC 33, at 51 (1977).
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testimony on the issue, which testimony was never resolved by the Licensing Board since it determined that emergency plans need not be developed for areas beyond the LP?.13/ The conflicts in that teatimony give further reason to question the feasibility of evacuation beyond the LPZ.
Moreover, the licensee's own evacuation time estimates
, leave substantial doubt as to the feasibility of evacuation. <
Public Service estimates that, on a summer weekend, it will take four hours and 20 minutes to evacuate a 180 degree sector to the north of the plant having only a two-mile radius.1S/
That sector includes only one beach area, Hampton Beach, and accounts for only 5,247 of the 9,177 estimated vehicles associated with that beach population.15/ Public Service provides a similar estimate -- 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 30 minutes--for evacuation of the ten-mile 90 degree northeast sector containing Hampton Beach.15!
Neither of these estimates includes the time required for compe tent authorities to make decisions about the need for i
evacuation or to notify officials and the public of that need.
13/ .Public Service Company of New Hampshire, LBP-76-26, 3 NRC 857, 922-26 (1976).
14/ Public Service Company of New Hampshire, Preliminary Evacuation Clear Time Estimates forJ Areas Near Seabrook i Station, August 4, 1980, Table 4.
15/ Id., Table 2.
~ 16/ d . , . Table 4 . .
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4 Nor do they include the time required for individuals to prepare to evacuate or for officials to confirm that evacuation has been completed.12! A recent NRC study , NUREG/CR-17 45, attests to the significance of these omissione:
It is important to understa".5 that estimates of the length of the time period f rom the decision to evacuate through clearances of the evacuation zone is
[ sic.] significantly aff ec ted by the time required for both notification and preoaration. That is to say, the length of time that 5t takes to clear the area cannot be calculated with any degree of certainty without knowing how long it takes to notify the populace of an impending evacuation, and how long each person will' consume in preparation.ll/
Even without accounting for decision, notification, preparation, or confirmation time, the licensee's estimates exceed the time period during which f atalities and injuries will result from exposure to radionuclides on the ground in the event of an " atmospheric" Class 9 - accident, according to NUREG-0396.1E/ That document reveals that, assuming a unif orm population density of 100 persons per square mile and plume speed of 10 m.p.h., an evacuation time of only tL ee hours will result in approximately three deaths and twelve 17/ Id. at 11.
18/ Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, NUREG/CR-1745, at 3-4 ' (November ,
1980).
19/- Planning Easis; for the Development of State and Local Government Radiological Emergency Response Plans In Support of
?
Light Water Nuclear Power Plants , NUREG-0396, EPA 52011-78-016, December, 1978, Figu res I-17 and I-18.
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- early injuries in the 0-5 mile range of the plant and approximately five early injuries in the 5-10 mile range.z 70 /
If evacuation time reaches five hours (with, for example, the addition of notification time) , the results are approximately six deaths and twenty-eight early injuries in the 0-10 mile range.2 1/ Of course, NUREG-0396 makes no attempt to estimate the lcag-term genetic or other health eff ects associate # with such evacuation times.
Thus, even if evacuation can be accomplished within the times estimated by Public Service, there will be a significant number of early injuries and deaths in the event of an atmospheric Class 9 accident at Seabrook. And there is reason to suspect that actual evacuation times would be much longer.
The licensee's most recent evacuation time estimates are defective in several ways. As we have already mentioned, Public Service has failed to include in its estimates the time l required for decision, notificatic., preparation, and confirmation. Even more importantly, it has failed to provide 20/ Id.
! 21/ Id. The population density in the beach area near the Seabrook site is much g reater than the 100 persons per square mile assumed in NUREG-0396. As the Licensing Appeal Board has noted, "there is no doubt that, at peak periods . . . in excess.
- of 25,000 people will be found in [that] densely populated area." Public Service Company of New Hamoshire, ALAB-422, 6 NRC.33, at 51 (1977).- Thus, all of the health and fatality figures contained in NUREG-0396 are understated so f ar es t5e Seabrook site is concerned.
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estimates based on simultaneous evacuation during the peak summer season of all of the beach areas lying from NE to SSE of the site or even simultaneous evacuation of Hampton Beach and either of the other two beach areas, Seabrook Beach and Salisbury State Beach. This defeats the purpose of licensee evacuation time estimates, as stated in NUREG/CR-1745--namely, "to present time estimates in a f ormat that will aid a realistic assessment of the options."22/ The licensee has also failed to provide a time estimate for evacuation of the entire 10-mile EPZ, as required by NUREG-0654.21/ And it has assumed that approximately one vehicle per household would be used in the evacuation. This assumption, according to NUREG /CR-1745, results in a low estimate of the number of automobiles being evacuated.SS/
Other significant deficiencies in the licensee's estimates
, include the following:
(1) admitted failure-to account in its off-season estimates for evacuation of the forty schools and in any of its estimates for evacuation of the three t
22/ Analysis of Techniques for Estimating Evacuation Times for
[ Emergency Planning Zones, NUREG/CR-1745, at 13 (November, 1980). That document indicates that cwo evacuation times should be reported for each evacuation zone--one reflecting evacuation of that zone alone and one reflecting simultaneous evacuation of all contiguous zones. Id. at 14.
23/ See Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of N'1 clear Power Plant, NUREG-0654, FEMA-REP-1, Rev. 1 (November,1980) , App. 4, at 4-4.
24/ Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, NUREG/CR-1745, at 10' (November,1980),
e hospitals and other institutions 25/ located within the ts1-mile EPZ;2{/
(2) failure to account for the public transporation-dependent population; (3) failure to include major employers in its estimates of summer transient automobile demand; and (4) failure to consider the eff ect of voluntary evacuation beyond the ten-mile EPZ.
Given these deficiencies, it seems likely that the licensee's current evacuation time estimates are too low. This is especially so in view of the Federal Emergency Management Agency's estimates that there are 7,180 people in the non-au tomobile owning popu:.ation and 3,500 people in institutions, togerner constituting 10% of the total resident population witnin the Seabrook EPZ.S1!
It is also noteworthy that the evacuation time estimates provided by the licensee in its PSAR S! are significantly 25/ .See Seabrook Preliminary Safety Analysis Report ("PSAR"),
at 2.1-8 and Tables 2.1-5 and 2.1-6.
26/ NUREG/CR-1745 concludes that evacuation times for large special f acilities, such as hospitals, may well be longer than the evacuation time for the general public. See Analysis of Techniques for Estimating Evacuation Times for Emergency Planning Zones, NUREG/CR-1745, at 15 (November, 1980).
21/ The Dynamic Evacuation Analyses: Independent Assessment of Evacuation Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear ' Power Stations, FEMA-REP-(number not yet assigned), at 46.
.28/ Seabrook PSAR, Amendment 23, July, 1974, at S13 S13-16.
higher than its current estimates, even though the earlier estimates relate to 22.5 degree sectors (rather than 90 degree or 180 degree sectors) and cover only a five-mile radius.21/
In its PSAR, the licensee estimates that it will take eight hours from the occurrence of the accident to clear three of the six beach sectors to the five-mile radius ano that the other three sectors will require five and one-half to six hours.SS/
A FEMA study estimates that a minimum of six hours and 10 minutes will be needed to evacuate the entire EPZ on a summer Sunday, even if notification is completed within 15 minutes.21/ That study further concludes that The behavior of drivers who are caught in congestion within direct sight of the Seabrook Station can only be guessed at this time. Any breakdown in orderly evacuation traffic flow will result in evacuation times greater than the ones estimated above. Total evacuation times could range from 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> 30 minutes to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 40 minutes for an evacuation in which traffic control is generally ineffective.12/
FEMA estimates, then, are also considerably higher than the licensee's current estimates. The early deaths and 29/ The earlier figures do purport to include notification time.
30/ Seabrook PSAR, at S13-16.
i 31/ -The Dynamic Evacuation Analyses: Independent Assessment iEE Evacuation-Times from the Plume Exposure Pathway Emergency Planning Zones of Twelve Nuclear' Power Stations, FEMA-REP-(number not yet assigned), at 46.
32/ Id.
, n . -
injuries resulting f rom a Class 9 accident would, of course, be significantly higher than the figures recited above if the longer times estimated by FEMA or by the licensee in the 1974 amendment to its PSAR are actually required for evacuation.
III. THE FEASIBILITY OF EVACUATION SHOULD BE ASSESSED IMMEDIATFEV Th: foregoing discussion demonstrates that there are indeed " unusual constraints" associated with evacuation of the Seabrook EPZ'and serious questions about the feasibility of safe evacuation of the area. That being the case, Seabrook is an appropriate instance for immediate examination of the feasibility issue.
Both the "Moffett Report"22! and the Report of the Prcsident's Commission on the Accident at Three Mile Island have roundly criticized the NRC's past practice of postponing full consideration of emergency planning issres until the operating license stage. The President 's Comn ission wrote ,
The construction permit stage does not require complete design plans, and therefore the full safety review does noc occur until the operating license stage. By then, hundreds of millions of dollars have been spent or r c ammitted in the construction process. -
Therefore, th* ultimate safety review may be influenced ', economic considerations that can lead i 33/ Emergency Planning Around U.S. Nuclear-Powerolants:
Nuclear Regulatory Commission Oversight, Fourth Report by the Committee on Government Operations, 96th Congress, 1st Session, House Report No.96-413 - (August 8, 1973) ["Moffett Report"].
l l
l to a reluctance to order ma operating license stage.21/jor changes at the Similarly, the Moffett Report observed that
[ilt is not until the plant is nearly built and the utility applies for an operating license that it must come forward with a fullblown emergency plan. By
[
then, of course, the Commission may find itself in
' the untenable position of having to choose between scrapping a multi-billicn dollar investment or allowing the welfare of area residents to be jeopardized.25/
i The Government Operations Ccamittee concluded in the ;
Moffett Report that there is " considerable doubt" about the feasibility of conducting evacuations in any der.<3ly populated areas 36/ and that evacuation of a sufficient area around a number of U.S. piants is clearly not feasible.21/ In an exchange, recounted in the Moffett Report, between Congressman Moffett and then Chairman Hendrie, Congressman Moffett, l
speaking on behalf of the Environnent, Energy and Natural l Resources' Subcommittee of the Government Operations Committee, i
called on the NRC tct "take a hard look at the feasibility of 1
. evacuation in the case of plants located near major population areas and treat '. hat examination as a " priority."20/ The Commission certainly does not fulfill this legislative mandate !
34/ Report of the President's Commission on the. Accider.t at Three Mile Island, at 52.
35/ Id. at 30.
36/ Id..at 8.
37/: Id. at 48.
l 38/ Id. at 46-47.
l l
or meet the criticisms of the Committee on Government Operations and the President's Commission by postponing consideration of emergency planning at Seabrock.
Cases arising under the National Fr.vironmental Policy Act, 42 U.S.C. Section 4331 et seo., provide a useful parallel to this situation. Confronted with the problem of " sunk costs",
courts insist cn early review of significant environmental issues. Thus, in upholding the grant of a preliminary injunction enjoining further construction of a bridge, the Second Circuit found in Steubing v. Brinegar, 511 F.2d 489, at 497 (2nd Cir. 1975), that "[wl ithout preliminary injunctive relief construction might well reach the stage of completion where for economic and other reasons it would be impossible to turn back or alter the prc iect in light of what an Environmental Impact Stater. int revealed, and thus the environment might thereby be irreparably damaged."39 Similarly, the Fourth Circuit noted, in halting construction of an interstate highway pending a NEPA review by the Secretary of Transportation, that
[flurther investment of time, effort, or money in the
. proposed route would make alteration or abandonment of the route increasingly less wise and, therefore, increasingly unlikely. If investment in the proposed route were to continue prior to and 'during the Secretary's consideration of the environmental 39/ See also National Wildlife Federation v. Andrus, 440 F.
Supp.1245,; at 1256 (D.D.C. 1977).
6 report, the options open to the Secretary would diminish, . and at some coint his consideration would become a meaningless of'rmality.40 i The Commission clearly has the authority to require that 1
Public Service Company demonstrate the feasibility of ;
evacuating the Seabrook EPZ now. At the time when emergency -
planning was limited to the low population zone, Commission i
decisions required a determination during construction permit proceedings that " timely ecacuation (of the LPZ] is reasonably '
assured."$1/ The Commission's Final Regulations on Emergency
. Planning , whi.le extending emergency planning requirements to Emergency ' Planning Zones, maintain the requirement that a '
determination of feasibility be made at the construction permit
- stage for new plants. The Regulations state that
. The Preliminary Safety Analysis Report shall contain sufficient information to ensure the compatibility of proposed -emergency plans for both onsite areas and i i
the EPZ's with facility design features, site layout, and site location with respect ~ 'o such considerations as access routes, surrounding population
. d istr ibutions, land use, and local jurisdictional
-boundaries . . .12/
40/ Arlington Coali tion on Transportation v. Volpe,458 F.2d
- 1323, 1333-(4th Cir. 1972), cert. denied,409 U.S. 1000 (1972).
,' See also Environmental-Defense Fund v. Tennessee Valley 468 F.2d 1164, 1183-84 (6th Cir.-1972). Latham v.
7 Authority Volpe, 45 $ F.2d 1111, 1121 (9th Cir .-1971).
'41/ . Consumers Power - Company, '(Midland Plant Units 1 and 2)
. ELAB-123,.6 AEC 331, at 342. (1973). See also' Southern -
, Calif ornia Edison Company, et al., (San Onofre Nuclear Generating Station-Units 2 and 3), ALAB-248, 8 AEC 957, 961-63
, (1974).
42/ 10 C.F.R. Part'50,- Appendix E,Section II.
Thus, the Commission cannot now issue construction permits without determining that timely evacuation of the EPZ for the particular plant is feasible.
Section 136(a) of the Atomic Energy Acti3/ authorizes the NRC to suspend or revoke "[a]ny license . . . because of conditions revealed . . . which would warrant the Commission to refuse tt grant a license on an original application." The U.S. Court of Appeals for the District of Columbia Circuit has i
held that-this clause applies to all licensing matters, including health, safety, and environmental considerations . . . [and]
reflects a deliberate policy choice on the part of Congress when it enacted section 186(a) to render licenses for nuclear facilities subject to post-licensing review under evolving licensing standards, rather than under those standards applicable at the
- time the license in question was issued.4d/
It is clear, then, that the emergancy plan for the Seabrook
! environs is now subject to post-licensing review under the new emergency planning standards.
In light of the gravity of the issue of safe evacuation, it is the responsibility of the Director to issue the show cause order requested by SAPL. Deferral of this major out-standing safety question to -the operating license stage would be inconsistent with the primary obligation of the Commission and Staff to protect public health and safety.
43/ 42 U.S.C. 52236(a).
44/ Ft. Pierce Utilities Authority of the City of Pt. Pierce v7 U.S.A. and the NRC, Nos. 77-1925 and 77-2101, slip opinion at 19-20 (D.C. Cir., March 23, 1979).
Dated:- March 13, 1981 Respectfully submitted, Paula Gold, Assistant Attorney General Chief, Public Protection Bureau Stephen P T.eonard, Assistant Attorney General Chief, Environmental Protection Division 5 -W' e -L _,&
Jo, Ann Shotwell "
A'ssistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265