ML20078N869
| ML20078N869 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/26/1983 |
| From: | Backus R BACKUS, MEYER & SOLOMON, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | |
| Shared Package | |
| ML20078N867 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8311030053 | |
| Download: ML20078N869 (18) | |
Text
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FILED- October 2000 $
UNITED STATES OF AMERICA NUCLEAR REGULATORY CONNISSION '
'83 GI 31 Pi2 :57 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
!~~~~ .<
'In the matter of:
PUBLIC SERVICE COMPANY OF Docket Nos. 50-443 OL NEW HAMPSHIRE, et al 50-444 OL (Seabrook Station, Units 1 and 2)
SEACOAST ANTI-POLLUTION LEAGUE'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW I. PROCEDURAL HISTORY The Applicants in this case sought construction permits to build a two-unit nuclear power facility utilizing pressurized water reactors. The application was docketed on July 9, 1973. Those permits were issued July 7, 1976. The Applicants filed their Final Safety & Analysis Report with the Staff of the US NRC on Ju'ne 29, 1981, and the Application was docketed on October 5, 1981. Notice of the opportunity for requesting a public hearing was published in the Federal Register on October 19, 1981. 47 Fed. Reg. 51331.
' Petitions for leave to intervene were received from numerous persons and organizations, including the Seacoast Anti-Pollution League. . Subsequent to the filing, wi thdrawal and summary disposition of numerous contentions, several remained for adjudication in the
'first phase of these proceedings. Among those content ions were those two filed by the New England Coalition Against Nuclear Pollution (hereinafter "NECNP") relating specifically to the adequacy of
- Applicants' evacuation time estimates.
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NECNP con t en t ions III .12 and I11.13 we re summa r i ly d i sposed o f ,
in part, in an order issued by this Atomic Safety and Licensing Board on June 30, 1983. In that order, this Board rephrased NECNP's evacuation time estimate contentions as follows:
NECNP 111.12/1I1.13 Evacuation Time Estimates "The evacuation time estimates provided by Applicants in Appendix C of the Radiological Emergency Plan are deficient in f ailing to include an estimate of:
- 1) The times for evacuation during adverse weather conditions developing on a busy summer weekend; and
- 2) The times for' simultaneous evacuation of beach areas lying NE to SSE of the Seabrook site."
Hearings were conducted on these and other contentions beginning on August 16, 1983. The hearings lasted a total of eight days, including limited appearance sessions on August 20, 22, 26 and 31.
The Seacoast Anti-Pollution League (hereinafter "SAPL")
actively participated in those hearings and conducted cross-examination of Applicant and Staf f witnesses. These are the Board's findings of f act and rulings of law for NECNP contentions 111.12 and 1II.13.
1I. PROPOSED FINDINGS OF FACT
- 1. The evacuation time estimates submitted by the Applicants in Appendix C of the Final Safety Analysis Report do not specifically account f or "preparat ion" t imes , bu t instead rely upon loading rates as a surrogate for " preparation" times. Tr. 1038.
- 2. The Applicants' reliance upon loading rates as a surrogate is misplaced because dif f erent segments of the evacuation population will react to notification in differing ways, and will take varying
amounts of time to prepare before_ beginning to travel out of the EPZ. Tr. 1052.
3._ Those-segments of the evacuation population that will take longer to prepare have not been identified. No studies have been
- undertaken by the Applicants to quantify the percentages of persons who: will take a fair amount of time to evacuate, and those which will evacuate immediately. Tr. 1054.
- 4. The NETVAC model used by the Applicants in calculating time estimates is capable of differing treatment with respect to various population groups. Tr . 10 3 8. In. f ac t , the Applicants modified their treatment of preparation time phenomenon in the areas of major employment. Tr. 1039._ Yet, no attempts were made to quantify
- preparation time variations in other population groups; such as beach goers and population residents. This is true with regard to both Appendix C.and Exhibit 2, as submitted.
- 5. The, Applicants have not engaged in discussions with local of ficials or emergency personnel to gather information on variations in preparation: time among different population group's.- Tr. 1048.
- 6. In support of their argument that use of loading rates as a surroga,te for preparation times is proper, Applicants' witness testified that the actual time for people to get onto the highway network is r.eally not governed by preparation time to any extent (emphasis added. Tr. 1050.) However, Applicants' witness admits that evacuees will not be-attempting to enter the roadways until they have completed " preparation". Tr. 1051.
- 7. The Applicants' conclusion that ef fects of preparation time variation are not significant enough to warrant a separate study is
. l based on the assumption that the scope of preparation times is within the spectrum adequately absorbed through the adopted loading rates.
Tr. 1054, 1055. .The Applicants refer to " sensitivity studies" of loading rates, which ultimately yielded-a " spectrum of preparation times". Tr. 1054. Notwithstanding the Applicants testimony in this regard, they are unable to provide quaitative support for their assumptions in that no attempt has been made to ascertain what the actual variations among population groups are. Therefore, any assumptions by the Applicants' witness concerning the standard distribution of various preparation times is without quanitative basis. Tr. 1057.
- 8. The evacuation time estimates for the adverse weather, summer peak population scenario ( Applicants' Exhibit 2) exclude alert time, time for confirmation of evacuation, and pedestrian evacuation.
Tr. 1068.
- 9. The time estimate calculated for the adverse weather, summer peak population scenario is nine (9) hours and fif teen (15) minutes, a result which' reflects an assumed 30% reduction in roadway capacities. That 30% reduction factor is incorporated to account for adverse weather effects. Tr. 1069. Applicants agree that the 30% reduction factor is a " critical assumption" in the estimate calculation. Tr. 1069.
- 10. The assumption of the 30% reduction by Applicants' wi tness was a " judgment" based almost entirely on a s tudy of rainf all ef f ects in Texas. Tr. 1070. Applicants' witness testifi'ed that adoption of the 30% figure was an " arbitrary" determination. Id.
- 11. Applicants' witness testified that he could find no literature on the capacity reduction ef fects of fog. Yet, the witness
-has not .at t tempted to make inquiries of local of ficials on the scene as to their first-hand observations of the ef fects of adverse weather in the Seabrook EPZ. T r_._ 1 0 7 1 .
- 12. The Applicants' witness admits that coastal fog could have the ef fect of reducing highway capacity by more than 30%. Tr. 1071.
- 13. The impacts of coastal fog are highly significant. Coastal fog is.quite common in beach areas in the summer, resulting when winds are on-shore on hot, humid days. Direct testimony of Professor Herr, pg. 3, A.04. Beach visitors have no way of knowing foggy weather is imminent, and often remain on the beach in hopes that it >
will " burn off". Id.
- 14. A peak summer evacustion scenario coupled with adverse weather would pose a grave threat to the safety of evacuating persons.
Therefore, the evacuation time estimates submi tted by the Applicants are grossly underestimated. Mere assumptions based on literature not specifically applicable to the Seabrook EPZ is an insufficient basis for the'30% reduction figure.
- 15. - The impact of coastal fog with respect .to roadway capacity is significant, and at a minimum, is deserving of more detailed investigation by the Applicants. Dir. Herr, pg. 3, A.04.
Specifically, local officials familiar with coastal fog impacts should be interviewed in order to ef f ectively reexamine the validity of.the Applicants' arbitrary 30% reduction factor.
- 16. The Applicants have not accounted for the adverse weather results of flooding. Herr, Rebuttal, A.06. Hampton Police Chief Robert Mark testified that many roads, including those along the nor th shore of Hampton Beach,- become flooded at least once or twice a year and that such roads become " impassable." Id. The effects of flooding could, in some instances, make evacuation virtually impossible by reducing roadway capacity factors by 100% instead of the assumed 30%. I d. Indeed, such conditions were observed in 1978.
Id. The potential for serious flooding within the EPZ is further corroborated by " FEMA, Flood Hazard Boundary Maps for the Town of Hampton, NH", Exhibits A-D as at tached to Prof essor Herr's rebuttal testimony. Herr, Rebuttal, A.06.
- 17. The observations made by Chief Mark are the basis for Professor Herr's asser tion. Chief Mark is intimately familiar with the area, and has of fered his observations in sworn testimony. This raises serious questions with respect to why the Applicants have not seen fit to include any flooding analysis within the context of their evacuation time study.
- 18. It is not the responsibility of Professor Herr or any other witness on behalf of the intervenors or interested states to.make f requency s tudies for the Applicants. The observations of reliable persons who live within the EPZ are clear on the record: flooding is a common occurrence and has not been addressed.
- 19. The evacuat ion t ime es t ima tes submi t ted by the Appli cant s do.not account in any way for the possible or probable occurrence of accidents blocking any of the egress routes. Tr. 1085, 1086, 1100. Further, no attempts were made to discuss with local of ficials areas where traffic accidents typically occur,or the delay times associated with traf fic accidents in the vicinity. T r . 110 0. Neither L
m do the Applicants take into account the possible or probable f requency of cars' running out of fuel and blocking egress routes as a result.
tr. 1086.
.20. Failure to account for the likely occurrence of accidents and stalled vehicles is not justified through the Applicants assertion that " assuming specific types of accidents and speci fic places" would
" involve sheer speculatlon" as to events. Tr. 1114, Applicants' Proposed Findings of Fact and Conclusions of Law #65, pg. 48.
- 21. To some extent, the entire planning process involves some
" speculation" as to likely . evacuation conditions in order to f ormulate a workable emergency response plan. It is impossible to predict with certainty all the emergency conditions which might detract f rom or contribute to the f easibility of any protective response. It is possible, and desirable, to anticipate likely occurrences which may impact on the actual response chosen. The occurrence of route blocking accidents and stalled vehicles is an obvious, likely occurrence in an evacuation involving thousands of vehicles.
- 22. The Applicants' evacuation time estimates do not account for the City of Portsmouth in calculating the time required for evacuat ion of the ent i re EPZ. Tr. 1073. The populat ion of the Ci ty of Portsmouth is approximately 24,000-25,000 persons. Tr. 1072.
Notwithstanding the fact that the computer model used by the Applicants has the capacity to perform runs including the Portsmouth population, Applicants have not yet ordered those runs to be done.
Tr. 1073.
.. 23. The evacuation time es timates disregard the impacts of vehicles going into, or back and forth within the EPZ as a result
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.of distraught persons trying to locate other family members instead of evacuating immediately according to presumed evacuation instructions. Past experiences with evacuations carried out within the EPZ have demonstrated the occurrence of this phenomenon. Direct Testimony of Robert J. Mark, pg. 8.
- 24. Applicants' argument that the problem will not impact the time estimates assumes continuous two-way traf fic will be maintained where it normally occurs. This assumption is without basis on the record.
- 25. Chief Marks testimony that evacurcing persons tend to become "very emotional" supports the assertion that inbound lanes mal , in fact, be used as outbound lanes. This is especially likely when long lines and traffic " ques" become significant.
- 26. Applicants' witness admitted that assuming inbound lanes are left open, returning vehicles can lengthen times required for outbound traffic to pass through certain intersections. Tr. 1103.
Also, the witness agreed that inbound emergency vehicles would have a similar effect on evacuation times, although he did not know how much of an ef f ect and had made no attempts at quantif ying the impact.
Tr. 1104.
- 27. NUREG-0654, Appendix 4 requires consideration of the impacts of peak popu lations , including behavioral aspects. (See NUREG-0654 App. 4 IV B. (pg. 4-10).) The Staff supports this requirement. Tr.
1332.
28.. The evacuation time estimates indicate no investigation or explanation concerning behavioral aspects of peak populations.
Tr. 1352. During cross-examination on this point, Staff's witness suggested the consideration was "there by omission", then admitted he could not " point out what isn't there". Tr. 1352,
- 29. Staf f's witness sugges ted that the NUREG-0654 requirements applied only to such unique and unusual behavioral characteristics as those of the Amish traditions of sole reliance on horse drawn transportation. Tr. 1351.
- 30. Staff's witness concluded that in the case of Seabrook, as f ar as he was concerned, "there was nothing to consider". Tr . 13 5 4.
- 31. The Applicants' estimates are, in some cases, based on tangential routings which direct evacuees toward rather than away from the plant for certain periods of time. Cross-examination, Urbanik, Tr. 1387. This "non-radial" dispersion has been assumed and adopted for calculation of these evacuation time estimates.
Therefore, the psychological impact of movement toward the plant,
.after notification to evacuate away from the plant, may be of great significance to evacuees and will evoke behavioral responses of critical importance to the planning process. Staff's witness agreed that non-radial dispersion in particular raised questions about the behavior of evacuees. T r . 13 8 9 , 9 0. These questions are not addressed anywhere in the evacuation time estimates.
32.- The evacuation time estimates do not contain an account for confirmation time, as required by NUREG-0654 App. 4, V.
- 33. The evacuation time estimates for Seabrook Station were characterized by Staff's witness as "long" with respect to other sites that have 5,000-6,000 people living within their respective EPZ's.
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- 34. Evacuation time estimates for special facilities and institutions must be calculated and presented on an institution by ins t i tu t' ion bas i s. NUREG-0 6 5 4, Rev . 1, App . 4 I .C. Thi s requirement includes schools. Id.
- 35. The Applicants' time estimates do not meet the above requirement with the exception of two institutions; the Seacoast Health Center-and the Exeter Hospital, & 1355.
- 36. There is no indication on the record that the Applicants have made a comprehensive survey of how many nursing homes, hospitals, or-schools there are within the EPZ.
- 37. Similarly, there is no indication on the record of the detailed . evacuation time estimates required by NUREG-0654 for individual institutions by institution by institution basis.
- 38. Failure to account for the means of accomplishing institutional evacuation along with accompanying individual time estimates significantly increases the likelihood that the estimates are optimistically lo'w.
- 39. Th e - NRC Staff's independent study of evacuation time estimates for Seabrook yields estimates ranging up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for a summer evacuation of some sectors of thh EPZ. Tr. 1365. When the thirty (30) percent reduction f actor is taken into account f or adverse weather, the Staf f's ' twelve (12) hour estimate is raised to 15.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Tr. 1413. Staff's witness was unaware of any other time estimates for nuclear plant sites longer than 15.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> except one.
Tr. 1414.
O II1. CONCLUSIONS OF LAW
'4 0 . Neither.the Applicants nor Staff's witnesses dispute any of.the requirements of NUREG-0654 as a proper interpretation of 10 C.F.R. 650.47 et seg. In its Order of June 30, 1983, this Board ruled that in the absence of any dispute, NUREG-0654 is a reasonable interpretation of the applicable emergency planning regulations.
(See Boar.d's Or' der of June 30'at pgs. 5-6.)
Therefore, with respect to emergency planning contentions admitted in these proceedings, NUREG-0654 provides the appropriate benchmark standard for review.
- 41. Neither the Applicants nor the Staf f have put into dispute the' requirement set forth in NUREG-0654 App. 4, IV B (pg. 4-10) that
" consideration shall be given to the impact of peak populations including behavioral aspects." Id. Therefore, that requirement must be met before the Applicants' evacuation time estimates are deemed adequate under 10 C.F.R. 050.47 (a)(1) et seg.
- 42. The assumption by Staff's witness that 'the behavior considerations requirement is limited to unique, " unusual". behavior is unsupported on the record. The interpretation runs contrary to the intent of the statement- that. behavioral ' aspects of " peak populations" be considered. Indeed, there is no language in NUREG-0654 which suggests limiting such considerations to those segments of peak populat ions known to exhibit " unusual" behavior. The Staf f 's characterization of the requirement is therefore incorrect as a matter of law. Use of the term " peak populations" refers to all
- behavioral aspects associated with evacuation of those populations.
- 43. Therefore, the evacuation time estimates submitted with respect to NECNP contentions III.12 and III.13 are inadequate under 10 C.F.R. 50.47 et seq. as interpreted by NUREG-0654.
- 44. The Applicants adopt the position that the purpose for deriving evacuation time estimates is two-fold. The first is to quantify the amount of time an evacuation would require so that emergency response personnel can chose the best alternative protective action for any given accident scenario. The second purpose is to identify traf fic bot tlenecks that may require the implementation of. traf fic management techniques in order to reduce evacuation times.
Cross-examination of Appl'icants' witness Mcdonald at Tr. 1078, 79.
This chara.cterization of time estimate functions is cited in support of Applicants ' conclusion that evacuation is "always f easible", which suggests that estimates only serve to identify the most favorable protective action alternative. This position is incorrect as a matter of law; the Applicants have not met their burden of proving that evacuation time' estimates, as an indication of evacuation
" feasibility", contribute in any way to the requisite findings that on-si te and of f-si te emergency preparedness mus t provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. 10 C.F.R. 650.47 (a)(1).
Absent such a showing, this Board _cannot accept the validity of the time estimates submitted with respect to NECNP contentions 111.12 and III.13.
- 45. There are Seabrook accident scenarios in which evacuation would not be an available option as a matter of law because it would not be a measure sufficiently adequate to protect the health and
saf ety of the public in the event of a radiological emergency. Sworn testimony by both Applicants' and Steffs' witnesses supports this finding.
.For example, Applicants' witness Mcdonald testified that:
"All it really does is put information on the accident prognosis, evaluates the impor tance of information on the accident prognosis early enough in the accident sequence, so that evacuation as a potential protective action can be decided on in the time frame early enou'gh to implement effectively." (Emphasis added.) Tr.
1079.
The de facto implicat ion - o f Mr. Mcdonald's testimony runs cont rary to his assertion that evacuation is "always f easible". Tr.
1078. By admitting that evacuation might not be capable of timely,
" effective" implementation, the Applicants admit that evacuation as a protective response may not be adequate to protect the health and safety of the public in the event of a radiological emergency.
- 46. A similar admission is made by Staff witness Urbanik when he expressed concern about adopting overly conservative evacuation time estimates. Urbanik noted that such estimates might create a si tuat ion where evacuat ions would not be ordered in spite of the fact that they might still be " feasible". This necessarily implies that at some point evacuation will cease to become feasible, and therefore would be inadequate as a protective measure that can and will be taken to protect the health and saf ety of the public. T r . 13 5 6 .
- 47. This Board finds that 10 C.F.R. 950.47 (a)(1) requires more than a showing of information upon which to prioritize the available alternative responses in terms of their desirability. The Applicants have made no showing on this record that, at least with respect to those estimates submitted in connection with NECNP
contentions III.12 and 111.13, evacuation as a possible protective response for the adverse weather, busy summer weekend scenario and the simultaneous evacuation of beach areas lying NE to SSE of the Seabrook site is, in fact, reasonably adequate to protect the health and safety of the public.
- 48. The evacuat ion time estimates submi tted by the Applicants with respect to the contentions noted above are insufficient under the regulations as a matter of law because the 30% reduction f actor applied to account for adverse weather conditions is not adequately supported on the record. Speci fically, we hold that Applicants mus t do more than merely conduct literature searches in order to.obtain adequate and reliable information upon which to calculate capacity reduction. The sole reliance by Applicants upon a single piece of literature detailing the effects of rain storms on roadway capacity in-Texas is hardly a sufficient basis for the 30% assumpt ion when local officials and emergency response personnel could have easily been interviewed for purposes of learning from the first-hand observations of those persons most experienced *r local weather patterns and conditions.
- 49. The intervenors have met their burden of going forward with respect to the issue of flooding as an important component of adverse weather and its corresponding effects of road capacity reduction. Ilampton Police Chief Robert Mark is a credible witness in this respect and the fact that EPZ roadways would be flooded and Indeed, impassable with some f requency is an area which merits further investigation by the Applicants. As indicated in Prof essor Herr's rebuttal testimony, Chief Mark's assertion is corroborated by the
s FEMA Flood Hazard Boundary Maps at tached to P rof essor Herr 's tes timony as Exhibits A-D.
- 50. We hold that the testimony of Chief Mark and Professor Herr raises serious ques t ions' wi th respect to why the Applicants have not seen fit to include any flooding analysis wi thin the _ context of their evacuation time estimates. It is not the responsibility of Professor ~ Herr or any other witness on behalf of intervenors or interested states to make f requency studies for the Applicants. The
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observations of reliable persons who live within the EPZ are clear
.o n the record; flooding .i s a common occurrence and has not been addressed. Therefore, Applicants must make a detailed analysis of the impacts of flooding on evacuation and.other protective action options, including frequency studies, and must incorporate the results into its calculations of evacuation time estimates.
- 51. The evacuation time estimates submitted by the Applicants with respect to the contentions litigated in this proceeding are insufficient as a matter of law because they do not account in any way for the impact of traffic accidents. Despite the existence of some testimony on the record asserting that vehicles involved in accidents would simply be pushed out of the way and that their impact on road.vay capacity would be negligible, we hold that the potential f o r - cap ~aci ty reduc t ion i s s igni f i can t , and tha t the App li can t s should incorporate likely traffic accident scenarios into their computer model, including informat ion. der ived from interviews with local of ficials as to the most likely locations for accidents of a serious
. nature.
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5 2.- The evacuation time ~ estimates submitted by the Applicants with respect to contentions litigated in these proceedings are
.insuf ficient and incomplete as a matter of law because the Applicants have not quantified the effects of inbound traffic upon those estimates.
(See Finding of Fact, #20.)
- 53. The evacuation time estimates are insuf ficient as a matter of law because there is no comprehensive analysis of the special dif fleu1tles and time associated with evacuation of institutionalized persons; i.e. , persons in nursing homes, schools, jails, clinics, etc.
Respectfully submitted, Seacoast Anti-Pollution League By its attorneys, BACKUS, SilEA & MEYER
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Ro bet t A. Backus 116 Lowell St., Box 516 Manchester, N.H. 03105 Tel: (603) 668-7272 October 26, 1983
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CERTIFICATE OF SERVICE DATED: October 26, 1983 I, Robert A. Backus, hereby certify that I have mailed to the attached list of people, first-class, postage prepaid a copy of the enclosed. li served by Federal Express or Express Mail it is so indicated by
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bv the person's name. - ~' ~ 2 -E : - =em Rdbert A. Backus i
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'u Brian Cassidy Helen Hoyt, Chm. + Thomas G'. Dignan, Esq.
Fed. Frerg. Mgmt. Agcy. Admin. Judge Ropes and Gray Region I Atomic Safety & Lic. 225~ Franklin Street J.W.McContack POCH Board - U.S. NRC Boston, MA 02110 Toston, MA 02109 Washington, DC 20555
-Sen. Gordon Humphrey [ni d '
Atta: Tom Barack'- Atomic Safety &Lic.
NR tc DC .20510 a[hn n D 20555
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,w Sen. ' Cordon Humphrey Roy P. Lessy, Jr., Esq. Robert L. Chiesa, Esq. s' Office of Executive '^
Attn: Herb Boynton 95 Market Street l Pillsbury Street Legal Director Manchester, NH 03101 \
U.S. NRC
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Concord, Mi 03301 ,-
Washington, DC 20555 -
4s g Phillip Ahrens, Esq. Jane Doughty Asst. Atty. General , Field Director Town Manager's Office State House, Station #6 s SAPL Town Hall - Friend St. Augusta, ME 04333 5 Market Street Amesbury, MA 01913 Portsmouth, NH 03801 Donald E. Chick Anne Verge, Chairpermn Dana Bisbee Tmn Manager man of Men Attorney General's Office 10 Front-Street State of New Hampshire Exeter, M. 03S33 }nHa g n, 03M2 Concord, NH 03301 Dr. Emneth A. Luebke David R. Lewis
.3ffice of Selectmen A'dmin. Judge
. Tmn of North Hampton Atomic Safety & Lic. Brd.
Atomic Safety & Lic. U.S. NRC - Rm. E/W-439 trth ihmpton, NH 03802 Board - U.Si NRC Washington, DC 20555 Washington, DC 20555 w
Jo Ann Shotwell, Asst. AG Calvin A. Candey, One Ashburton Place, 19th City Mgr.-City Hall Floor 126 Daniel Street Boston, MA 02108 Portsmouth, NH 03801 Charles Cross, Esq. William S. Jordan, II, Esq. Mr. Anzie Machiros, Chnr.n.
25 Maplewood Ave. Ellyn R. Weios, Esq. BoardDiSelectnen '
P.O. Box 366 1725-I Street, N.W. Town of Newbury (
Portsnauth, NI =03S01 Suite 506 Newbury, MA 09150x Washington, DC 20006 -
Edward Meany- Dr. Muray Tye, President Sandra Gauvutis -,
' l'own ol ' Rye ' Sun Valley Ass'oc. Town of Kinsington ( ^
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~11 fred Sargent, Chm.
Brentwood Board of Selectnen i 1 130ard of Selectmen RFD Dalton Road Newfuryport,1 UA 01950 Imn of' Salisbury,MA 01950 Brentwoodn. NI 03833