ML20043E495
| ML20043E495 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/07/1990 |
| From: | Tompkins B NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| To: | MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, NRC OFFICE OF THE GENERAL COUNSEL (OGC), SEACOAST ANTI-POLLUTION LEAGUE |
| References | |
| CON-#290-10442 ALAB-933, LBP-90-12, OL, NUDOCS 9006130052 | |
| Download: ML20043E495 (20) | |
Text
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I'0Ca[RD UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING APPEAL BOARD E M ~0 N N Administrative Judges:
tUect y ncutAe1Y uGCKlTiG A "JuvW.I.
G. Paul Bollwerk, III, Chairman June 7, 1996ELEH Alan S. Rosenthal (ALAB-933)
Howard A. Wilber
' M & ~\\ W
)
In the Matter of
)
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PUBLIC SERVICE COMPANY OF
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Docket Nos. 50-443-OL NEW HAMPSHIRE, ~et al.
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50-444-OL
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(Offsite Emergency (Seabrook Station, Units 1
)
Planning Issues) and 2)
)
)
Thomas G. Dignan, Jr., George H. Lewald, Kathryn A.
Selleck, and Jeffrey P.
Trout, Boston, Massachusetts, for the applicants Public Service l
Company of New Hampshire, et al.
Edwin J.
Reis, Elaine I. Chan, and Lisa B. Clark for l
the Nuclear Regulatory Commission staff.
John Traficonte, Boston, Massachusetts, for the intervenor James M. Shannon, Attorney General of Massachusetts.
Diane Curran, Washington, D.C.,
for the intervenor New l
England Coalition on Nuclear Pollution.
Robert A. Backus, Manchester, New Hampshire, for the intervenor Seacoast Anti-Pollrtion League.
MEMORANDUM AND ORDER Before us are motions of both the applicants and the,
NRC staff seeking either'to strike or to dismiss appeals j
taken by intervenors Attorney General of Massachusetts l
(MassAG), New England Coalition on Nuclear Pollution i
1 (Coalition), and Seacoast Anti-Pollution League (SAPL) from 900613005290060}
DR ADOCK 0D000 p
y*
2 the Licensing Board's May 3, 1990 memorandum and order in this operating license proceeding involving the Seabrook nuclear power facility.1 For the reasons stated below, we grant the motions in part.
I.
A.
The May 3 memorandum and order addressed four issues that we remanded to the Licensing Board in ALAB-924,2 as well as two motions filed by intervenors to reopen the record.3 The remanded issues all involved aspects of the New Hampshire Radiological Emergency Response Plan, i
applicable to the portion of the Seabrook plume exposure pathway emergency planning zone (EPZ) located in that State.4 More specifically, the Licensing Board was called upon to consider further (1) the necessity for letters of I LBP-90-12, 31 NRC (1990).
2 30 NRC 331 (1989).
3 Those motions, dated February 6 and February 28, 1990, respectively, originally had been submitted to us by the MassAG, Coalition, and SAPL.
Thereafter, we referred them to the Licensing Board in an unpublished March 1, 1990 a
order.
4 ALAB-924 was rendered on a portion of the appeals taken from the Licensing Board's partial initial decision concerned with the acceptability of that plan.
See LBP-88-32, 28 NRC 667 (1988).
We recently ruled on the remaining issues raised in the appeals concerning the New Hampshire plan.
See ALAB-932, 31 NRC (May 31, 1990).
i
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3 i
I agreement (LOA) embracing school personnel having an assigned role under the New Hampshire plan; (2) the sufficiency of a 1986 Special Needs Survey designed to ascertain the persons within the New Hampshire portion of the EPZ who would have special transportation requirements in the event of a Seabrook radiological emergency; (3) the effect that the period necessary to prepare advanced life support (ALS) patients for evacuation would have upon evacuation time estimates for those patients; and (4) the adequacy of the provisions in the New Hampshire plan with regard to implementation of the sheltering option for the transient beach population.
For their part, the j
intervenors' reopening motions similarly focused upon sheltering matters, t
At the outset of its May 3 ruling, the Licensing Board l
announced that it was granting " leave" to SAPL "to withdraw from the proceeding before this Board."5 This action had its roots in a series of filings beginning with a January 19, 1990 letter from SAPL counsel to the Board.
That letter was in response to a January 11, 1990 Board order seeking l
the advice of the parties respecting how to proceed on the issues remanded in ALAB-924.
In its letter, SAPL counsel '
informed the Board that it "could not expect SAPL to have 5 LBP-90-12, 31 NRC at (slip opinion at 2).
t i
o 4
the least interest whatsoever in any further proceedings before the Board, given the fact that the Board has decided the issue in the case by directi:g the 'immediate authorization' for a full power nuclear license."6 SAPL's pronouncement prompted a motion from the applicants seeking to have the Board dismiss the remanded LOA, Special Needs Survey, and ALS Patients issues as abandoned for the reason that "SAPL, the sponsor and (except for the LOA issue) sole advocate of these three issues, has abandoned them."7 Responding to the motion, SAPL stated that it had never manifested an intent to " abandon" the remanded issues but, rather, had indicated in the January 19 letter simply that it did not " intend to participate in
(
6 Letter from Robert A. Backus to Administrative Judge Ivan W. Smith et al. (January 19, 1990) at 1.
Mr. Backus
'was referring to tee Board's November 9, 1989 decision on, inter alia, the radiological emergency response plans for the Massachusetts portion of the Seabrook EPE, which decision concluded with an authorization for the issuance of a full-power operating license.
See LBP-89-32, 30 NRC 375, 651 (1989), appeals pending.
That authorization required Commission endorsement of an "immediate effectiveness" review (see 10 C.F.R. $ 2.764), which endorsement was
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forthcoming on March 1, 1990.
See CLI-90-3, 31 NRC 219 (1990).
I 7 Applicants' Motion to Dismiss Abandoned Remand Issues
'(January 26, 1990) at 3-4.
The applicants pointed to SAPL contentions 15, 18, and 25 as the genesis of those issues, j
Id. at 1-2.
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I litigation on any issues that are unrelated to licensing."8 Asserting that the Board had made clear that it' considered
)
the remanded issues " irrelevant to licensing" because they j
are not " safety significant," SAPL maintained that, so long an that determination remained in effect, it had "no reason to participate in further proceedings before the Board."9 The Licensing Board took this explanation of SAPL's purpose to mean that, once the commission approved the issuance of a full-power license for Seabrook, there would no longer be any possible issue "relai;ed to licensing" on which SAPL might participate.10 That approval having occurred on March 1,11 and the license having issued shortly 9 Seacoast Anti-Pollution League's Objection to Applicants' Motion of January 26', 1990 (February 1, 1990) at 1.
9 Id. at 1-2.
As the source of the view it attributed to the IIcensing Board, SAPL cited both LBP-89-32, 30 NRC 375, and LBP-89-33, 30 NRC 656 (1989), appeals pending.
By
" unrelated" or " irrelevant" to licensing, SAPL spparently had in mind issues that, as the Licensing Board saw it, were not crucial to a determination on whether an operating license should be authorized, notwithstanding the prospect of further administrative review.
10 LBP-90-12, 31 NRC at (slip opinion at 5).
II As earlier noted, in CLI-90-3 issued on that date the Commission provided immediate effectiveness to the Licensing Board's decision (LBP-89-32) authorizing the issuance of a full-power license.
See supra note 6.
e s-m
1 6
thereafter (on March 15),12 the Board concluded that SAPL had effectively elected to withdraw and, accordingly, dismissed the intervenor from the proceeding before it.13 On the strength of that action, the Licensing Board undertook also to dismiss both the LOA and Special Needs survey issues as abandoned by SAPL, their sponsor. 4 The Board nonetheless went on to confront the merits of those issues and to hold that the concerns that had prompted our remand of them in ALAD-924 had been satisfactorily resolved.15 Moving on to the ALS Patients issue, the Board i
determined that, as remanded in ALAB-924, that issue was
(
" distinct from the contentions SAPL litigated" and, thus, was not "SAPL's to abandon. 16 On an analysis of the i
12 See letter from Mitzi A. Young, staff counsel, to members of this Board (April 26, 1990) at 2.
13 LBP-90-12, 31 NRC at (slip opinion at 5).
14 Id. at (slip opinion at 2, 8),
15 In the case of the LOA issue, the Board referred to i
the discussion in LBP-89-33, 30 NRC at 659-62.
The Special L
Needs Survey issue was found subject to summary disposition against SAPL's claims on the basis of the record before the Board in 1986.
See LBP-90-12, 31 NRC at (slip opinion-at 8-13).
16 LBP-90-12, 31 NRC at (slip opinion at 14).
. - - ~
,n-
l l
ingredients of the issue, the Board identified the subissues that required its further consideration.17 Finally, the Licensing Board tackled the remanded Beach Sheltering issue, together with the intervenors' motions to reopen the record on aspects of that issue.
Following an extended discussion, the Board rejected the motions.
The first was found to be moot or, at the least, superseded by 8
the second.
The latter motion was denied on the ground that it was untimely and, moreover, did not meet the other i
reopening criteria set forth in the Rules of Practice.II Turning then to our remand, the Board asked us for further guidance in the form of both answers to certain specific questions and a response to two referred rulings.20 B.
On May 11, the MassAG, Coalition, and SAPL noted an appeal from the May 3 memorandum and order. 1 The notice bore the signature of only counsel for the MassAG, who i
17 M. at (slip opinion at 22-33).
18 Id. at (slip opinion at 30).
18 Id. at (slip opinion at 32-40).
Those criteria are set Torth in 10 C.P.R. $ 2.734.
20 Id. at (slip opinion at 41-55).
The Licensing' Board steed that it would proceed with the remand while l
awaiting the requested guidance.
M. at (slip opinion l
at 55).
21 In that filing, the intervenors sought other and immediate relief, which we denied in a May 18 unpublished order.
l i
8 indicated that it was being submitted "on behalf of" the other intervenors as well (whose counsel of record were identified by name, address, and telephone number).
On May 16, SAPL filed a separate notice of appeal, signed by its counsel, that was directed exclusively to the portion of the May 3 order related to its purported withdrawal and dismissal from the proceeding.
On May 17, the applicat.ts moved to strike the May 11 notice of appeal.
According to the applicants, none of the Licensing Be,.t a rulings on the remanded issuas has achieved th; 2squisite finality to support appellate review at this time.
In addition, treating the May 11 notice as being that of the Mas 8AG alone, the applicants maintain that that intervenor lacks standing to complain of the disposition of the two issues that the Board determined had been raised and presented by SAPL.
Similarly, the applicants assert, the MassAG is not in a position to complain of the dismissal of SAPL from the proceeding, an 22 In justification of such treatment, the applicants point to decisions of this Board, rendered in quite
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different contexts, that are said to hold that one party to a NRC proceeding is not entitled to speak on behalf of another party.
Licensees' Response to Appeal Board Order of May 14, 1990, and Motion to Strike Notice of Appeal (May 17, 1990) at 18.
9 i
occurrence that the applicants acknowledge is now ripe for appeal by SAPL.23 For its part, the staff asks us to dismiss both notices I
of appeal.
Observing that it " generally supports" the i
position taken by the applicants in their motion to strike the May 11 notice, the staff goes on to insist that, in the circumstances, the Licensing Board correctly dismissed SAPL from the proceeding and therefore that party's May 16 notice should be rejected as well.24
)
II.
A.
As we have had occasion to observe in several recent rulings in this proceeding,25 since our Davis-Besse decision in 1975 it has been settled that:
The test of " finality" for appeal purposes before this agency (as in the courts) is essentially a practical one.
As a general matter, a licensing board's action is final for appellate purposes where it either disposes of at least a major segment of the case 23 Id. at 21-22.
Apparently, on May 17 the applicants had not as yet received SAPL's May 16 notice of appeal challenging its dismissal.
24 NRC Staff's Motion to Dismiss Notices of Appeal from LBP-90-12 (May 25, 1990) at 1-6.
In its filing, the staff also explains why it believes the question of SAPL's status
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in the proceeding should be resolved now on motion, rather than after a full briefing of the SAPL appeal on that matter.
Id. at 2 n.1; see infra p. 11.
25
- See, e.g., ALAB-920, 30 NRC 121, 124 (1989);
ALAB-917, 29 NRC 465, 468 (1989); ALAB-906, 28 NRC 615, 619 (1988); ALAB-894, 27 NRC 632, 636 (1988).
6
d 10 or terminates a party's right to participate rulingg which do neither are interlocutory Thus, as the Licensing Board stated,27 the applicants expressly recognize,28 and the staff does not dispute, so much of the May 3 order as dismissed SAPL from the proceeding possesses sufficient finality to be appealable at this juncture.
That being so, there manifestly is no basis for rejection at the threshold of the appeal taken by SAPL from that dismiscal.29 Whether the Board was right in its conclusion that SAPL had voluntarily withdrawn is a question that must abide the event of a full briefing of the appeal.
20 Toledo Edison Co. (Davis-Besse Nuclear Power Station), ALAB-300, 2 NRC 752, 758 (1975) (footnotes omitted).
27 LBP-90-12, 31 NRC at (slip opinion at 55).
28 See supra pp. 8-9.
29 Given SAPL's separate May 16 notice of appeal, it is
[
not necessary to decide whether the notice of appeal filed on May 11 by the MassAG on behalf of, inter alia, SAPL would have sufficed to put the status question before us.
We nonetheless are constrained to observe that the applicants' view that the May 11 notice must be deemed that of the MassAG alone rests on a hypertechnical foundation enjoying little, if any, support in our precedents.
Nevertheless, to avoid a resurrection of the applicants' reasoning on the -
point, we suggest that,'in future filings in which his co-intervenors join, the MassAG list those intervenors and their counsel as joint submitters and, assuming he has been given authorization, sign it for them.
This procedure should forestall the line of argument that the applicants employed here, which appears to be bottomed wholly upon the use of the "on behalf of" phraseology.
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l 11 In endeavoring to bypass the briefing process that ordinarily accompanies any properly taken appeal, the staff insists that resolution now of the matter of SAPL's status is necessary to decide the question whether an appeal lies with regard to the Licensing Board's treatment in the May 3 order of the LOA and Special Needs Survey issues.30 y,
disagree.
For one thing, although dismissing SAPL's contentions on those issues because of its purported withdrawal from the proceeding, the Licensing Board nonetheless went on to addreso the issues on the merits.
Second, as shortly will be seen, irrespective of SAPL's current status with respect to its intervention in this proceeding, none of the substantive rulings in the May 3 order is appealable at this time.
By the time those rulings become ripe for appellate review, we will likely have decided the status question following the briefing that is now in progress.31 i
'O See supra note 24, 31 Our unpublished May 18, 1990 order tolled the running of the time for the filing of briefs in support of the apper41 from the May 3 memorandum and order taken by the interver. ors collectively on May 11.
No like action was taken with regard to SAPL's May 16 notice of appeal in our May 29 unpublished order addressed to that notice.
(There appeared at the time to be little room for doubt that (as we now hold) SAPL's independent appeal reflected by the May 16 notic,e was not subject to summary dismissal as premature.
This being so, we discerned no reason to put the briefing of (Footnote Continued)
1 12
)
i B.
Applying the Davis-Besse standard to the intervenors' appeal from the portions of the May 3 order l
I concerned with the remanded issues and the motions to reopen, we conclude that the appeal is premature.
To be i
sure, "[wje are aware of no litmus paper test for determining what constitutes a ' major segment' of a particular case"3 and it is sometimes a "close call" on that score.33 In this instance, however, we encounter no difficulty in resolving the question agaAnst finality.
To begin with, it appears on the face of the May 3 order that the ALS Patients and Beach Sheltering issues remain before the Licensing Board -- i.e.,
everything that (Footnote Continued) that appeal on hold while we examined the question whether the other portions of the LBP-90-12 covered by the May 11 notice of appeal were amenable to appellate review at this juncture.)
Thus, as matters now stand, SAPL's brief in support of its separate appeal is due on June 15.
See 10 L
C.F.R. S 2.762 (b).
It is our impression that SAPL is l
prepared to meet that deadline.
See SAPL's Response to j
Appeal Board Order of May 29, 1990 (May 31, 1990) at 2.
It might be added that, even had there been substance to the staff's belief that the matter of SAPL's status I
required immediate resolution, the " motion to dismiss" the appeal addressed to that matter would still have been improvident.
We are not aware of any circumstance in which an appeal might be subject to dismissal without briefing on the ground that it " lacks merit."
Rather, the appropriati vehicle for seeking a speedy merits disposition of an assertedly insubstantial appeal is a motion for " summary affirmance."
ALAB-894, 27 NRC at 638.
33 See, e.g., ALAB-920, 30 NRC at 124.
w 4 m e
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13 the Board had to say on those issues in the order was wholly interlocutory in character.
Accordingly, in all events, any further appellate review with respect to them clearly should await their ultimate disposition below.34 And, because the denied motions to reopen likewise were addressed to beach sheltering matters, it seems equally appropriate to defer our consideration of them until we have in hand the Licensing Board's final word on that subject.
Among other things, it is at least possible that that word will either moot the challenge to the denial of the motions or cast the challenge in a different light.
That leaves the LOA and Special Needs Survey issues.
I Given our determination last month that the record evidence 4
establishes that it is not necessary that teachers accompany the school children to reception centers in the event of a l
l 34 In this connection, the intervenors appear to concede that the Beach Sheltering issue remains in an l
interlocutory posture but insist that we should invoke here our discretionary authority to review interlocutory orders by way of directed certification under 10 C.F.R. S 2.718(i).
See Intervenors' Opposition to Motions to Strike Notice of Appeal of LBP-90-12 (June 4, 1990) at 6 [ hereinafter Intervenors' Oppositibn).
No motion explicitly seeking tHat i
relief, however, is before us; all that the intervenors filed was a notice of appeal.
Indeed, the intervenors have not satisfactorily demonstrated that either of the established tests for the sxercise of our directed certification authority is met.
See Public Service Co. of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-405, 5 NRO 1190, 1192 (1977).
D' l
14 l
Seabrook radiological emergency,35 it is unclear that the LOA issue retains much, if any, vitality.36 Be that as it may, neither alone nor in combination can the Licensing Board's resolution of these two issues be regarded so clearly disposing of "a major segment" of this case as to warrant our examination of that resolution in advance of the i
Board's determination of the other remanded issues simillarly concerned with aspects of the New Hampshire plan.
Our conclusion in this regard is fortified by the fact that, in their opposition to the motions of the applicants and staff, the intervenors merely state their belief that the " finality" standard has been satisfied.37 Not only are we given scant elaboration of the underpinnings of that belief but the intervenors stress that, "in any event, their notice of appeal was protective."38 In short, the 35 See ALAB-932, 31 NRC at (slip opinion at 62-63).
36 In ALAB-924, 30 NRC at 342-43, we noted our agreement with the Licensing Board that "by performing their usual role as the custodians of the students in their charge, at least so long as those students remain on the grounds of the school, school personnel do not become
' providers' of services for which letters of agreement wauld be necessary."
37 See Intervenors' Opposition at 8.
38 Id.
In context, it appears that the intervenors had in mind our previous indication that a protective notice of appeal is appropriate when there is any room for question L
respecting the finality for appeal purposes of a Licensing (Footnote Continued)
t 15 intervenors themselves have manifested a decided lack of conviction that this is the time to return to us, by way of an appeal, any of the issues that were remanded to the Licensing Board in ALAB-924.
For the foregoing reasons, except insofar as concerns the dismissal of SAPL from the proceeding, the pending appeals from the Licensing Board's May 3, 1990 memorandum and order, LDP-90-12, 31 NRC
, are dismissed as premature.39 I
(Footnote Continued) i Board order.
See ALAB-906, 28 HRC at 619.
There is, however, another reason (having nothing to do with the finality question) why the intervenors deem their appeal to be protective in character.
See infra note 39, 38 In the May 11 notice of appeal, intervenors l
reiterated their conviction, set forth in earlier filings, l
that the Commission and its adjudicatory boards no. longer l
possess any jurisdiction to act in this proceeding because of the intervenors' petitions for review of various agenef actions relating to full-power Seabrook operation, which now are pending in the United States Court of-Appeals for the District of Columbia Circuit.
To date, the intervenors have not succeeded in obtaining a judicial endorsement of their position.
We recognize, however, that the intervenors have not abandoned that position and that they filed their l
appeals with us simply out of an abundance of caution.
16 l
It is so ORDERED.40 FOR THE APPEAL BOARD l
- 1. - _ ).
W,.A:
Barbara A. Tompkins Secretary to the Appeal Board 40 The rulings referred to us in LBP-90-12, as well as possibly the. questions posed in that order, will be addressed in a separate order.
UW11ED S1 ATES OF AMERICA NUCLEAR REGULATORY COMMISS10N i
In the Matter of I
PUBLIC SERVICE COMPANY OF NEW i
Docket No. (s) 50-443/444-OL HAMPSHIRE, ET AL.
1 (Seacrook Station, Units 1 and 2) i I
I CERTIFICATE OF SERVICE I hereby certify that copies of the foregeing AB MEMD L ORDER (ALAl-933)-6/7 have esen served uoon the following persons by U.S. mail, first class, except as otherwise noted and in accoreance with the recuirements of 10 CFR Sec. 2.712.
Aestnistrative Judoe Administrative Judge G. Paul Bollwerk. !!!
Thomas S. Moore, Chairman Atomic Safety and Licensino Aepeal Atomic Safety and Licensinc Acceal 1
Boaro Board U.S. Nuclear Peculatory Commission U.S. Nuclear Regulatory Ccemission Washin; ton, DC 20555 Wasnington, DC 20555 Administrative Judce Howarc A. Wilber Aaministrative Law Jucce Atomic Safety and Licensing Appeal Ivan W. Smith, Chairman Boarc Atomic Saf ety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washincton, DC 20555 Washington, DC 20555 Administrative Judge Robert R. Pierce Escuire Richarc F. Cole Atomic Safety and Licensing Board Atomic Safety anc Licenstnc Board U.S. Nuclear Regulatory Cetmission U.S. 'uclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Aeninistrative Judge Edwin J. Reis Esc.
Kenneth A. McCollem Office of the General Counsel 1107 sett Vnaop Etreet U.C. Nuclear Regulatory D.mmission Stil!=ater, OK 74075 Washincton, DC 20555 Mitti A. Young Diane Curran, Esq.
Attorney Harmon, Curran & Tousley Office of the Beneral Counsel 2001 S Street, N.W., Suite 430 U.S. Nuclear Regulatory Commission Washincton, DC 20009 Wasni r:t on. DC 20555
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J Docket No.(s)50-443/444-OL q:
AB MEMD & ORDER;(ALAB-433)-6/7 rh ll Thomas G. Dignan, Jr., Esc.
Robert A. Backus, Esc.
Ropes L Gray Bactus, Meyer & Solomon One International Place 116 Lowell Street Boston, MA 02110 Manchester, NH 03106
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Paul McEachern, Esq.
Gary W. Holmes Esq.
Shaines k McEachern Holaes & Ells 25 Maplewood Avenue, P.O. Box 360 47 Winnacunnet Road Portsmouth, NH 03801 Hanoton, NH 03842 Judith H. Mizner. Esc.
Suzanne P. Egan Counsel for West Newbury City Solicitor 79 State Street Lagcults Hill-Wilton anc Rotonot Newburyport, MA 01950 79 State Street 2
Newouryport, MA 01950
- Barbara J. Saint Andre. Esc.
Counsel for Amesbury, Newburyport Jane Douchty, Director
& Salisbury Seacoast Anti-Pollution League i
Kopelsen and Paige. P.C.
5 Market Street 101 Arch Street-Portsecutn, NH 03801 Boston, MA 02110 Georce Iverson. Director Ashoc N. Amnrian. Esc.
N.
- m. Office of Eseroency Manacement 145 South Main Street. P.O. Box.30 State House Office Park South
-Braafore, MA 01830 107 Pleasant' Street Concord,, NH 03301 Georce W. Watson, Esq..
Jack Dolan Federal Emeroency Manacement Agency Federal Eneroency Management Acency L
500 C Street. S.W.
442 J.W. McCormack (FOCH)
'Washinoton..DC 20472 Boston, MA 02109 t
George D. Bisbee, Esc.
Paul A. Fritzsche, Esc.
Assistant Attorney General Office of the.Public Advocate l
Office of the Attorney General State House Station 112 25 Capitol Street-Auousta. ME 04333 Concord. NH 03301 l=
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l
e-Docket No.ts>50-443/444-0L AB MEMO 6 ORDER (ALAB-933)-6/7 i
Suzanne Breiseth John Traficente. Esc.
Board of Selectmen Chief, Nuclear Safety Unit Town of Hampton Falls Office of the Attorney General Drinkwater Road One Ashburton Place, 19th Floor Hampton Falls, NH 03644 Boston, MA 02100 Peter J. Brann, Esc.
Allen Leapert Assistant Attorney General Civil Def ense Director Office of the Attorney General ionn of Brentwood State House Station. 46-20 Franklin Street Augusta, ME 04333 Exeter, NH 03633 Williae Arestreno Anne Goodman, Chairman Civil Defense Director Board of Selectmen Town of Exeter 13-15 Newmarket Road 10 Front Street Durnam, NH 03024 Exeter. NH 0383" R. Scott Hill-Whil ton, Esq.
Michael Santosuesso, Chairman Lagoulis, Hill-Whilton & Rotondi Boarc of Selectmen 79 Statt Street South Hamoton, NH 03027 Newburyport,, MA 01950 Stanley W.
- Knonlef, n u ;.e n Norman C. Katner Boaro of Selectm' Superintendent of Schools P.O. Box 710 School Administrative. Unit No. O!
Nortn Hampton, te 164 Alumni Drive Hampton, NH 03642 Sandre F. Mitchel Civil ' Defense DirestCi Beverly Hollinoworth
- 1wn of renstn *.:r.
209 Winnacunnet Road Box 10 RR1 Hampton, NH 03842 East Kingston, NH 03627 The Honorable The Honorable o
.Gordon J. Humphrev Nicholas Marvoules ATTN Janet Coat ATTN Michael Greenstein United States Senate 70 Washington Street Wasninoton, DC 20'10 Salem, MA 01970 l
I Dochet No.(s)50-443/444-OL AB MEMO & ORDER-(ALAB-9331-6/7 t
4 Dated at Rockville, Md. this c
8 cay of June 1990.
Office i the Secretary of the Coastssten t
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