ML20148Q917
| ML20148Q917 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/25/1988 |
| From: | Ferster A HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5447 OL-1, NUDOCS 8802020005 | |
| Download: ML20148Q917 (18) | |
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January 25, 1988 UNITED STATES NUCLEAR REGULATORY COMM BEFORE THE ATOMIC SAFETY AND LICENSING BOARQFF! E 3
y BRANCH
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In the Matter of
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Public Service Company of
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New Hampshire, et al.
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Docket No. 50-443 OL-1 t/N-Bl.-/,
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(Seabrook Station, Units 1 & 2)
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ONSITE EMERGENCY
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PLANNING & TECHNICAL
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ISSUES
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NEW ENGLAND COALITION ON NUCLE @ POLLUTION'S MOTION TO COMPEL APPLICANTS TO RESPOND)NECNP'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS ON NECNP CONTENTION IV The New England Coa.lition on Nuclear Pollution ("NECNP")
hereby requests that the Licensing Board order Applicants to pro-3 m), (n),
vide answers to interrogatories 2(1), (n), (o), (t),
t (o), (q), (r), and (w),
4, 5,
6, and 8, to which Applicants have objected and supplied partial answers.
NECNP also seeks a gen-eral ruling on whether interrogatories concerning "microbiologi-cally induced corrosion" are within the scope of NECNP Contention IV, in order to resolve these disputed issues prior to the hear-ing on NECNP Contention IV.1 1
While a motion to compel Applicants to respond is not needed with respect to Applicants' general objection to interrogatories regarding microbiologically induced corrosion, since Applicants nonetheless respond without waiving their objection, NECNP believes that it is most efficient for tne Licensing Board to resolve this matter regarding the scope of issues to be litigated now, before the parties devote substantial resources to develop-ing evidence on this issue.
8802020005 880125 PDR ADOCK 05000443 G
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Objections to Specific Interrogatories Requesting Information on Circulating Water Systems Other than Coolino Systems Applicants' answers to interrogatories 2(t) and 3 (w), which seek information concerning possible biofouling and corrosion in "circulating water systems" at the Seabrook plant, are partially unresponsive.2 Applicants have refused to provide the requested information with respect to all circulating water systems which Applicants claim are not "cooling systems" based on their view that "Issues concerning circulating water cystems generally are outside the scope of Contention IV."3 Based on this objection, Applicants' answers to Interrogatory 5,4 6,5 and 8,6 are also 2
Interrogatory 2(t) seeks information about whether leaks similar to that found in the PCCW pump discharge check valve has been identified "in other circulating water systems in the plant."
Interrogatory 3(w) seeks information about whether tube degradation similar to that found in the PCCW heat-exchanger has been identified "in other circulating water systems in the plant."
3 "Applicants Responses to NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention IV," filed January 14, 1988, at 13, 28.
4 Interrogatory 5 requests Applicants to "describe all occasions in which microbiologically induced corrosion has been discovered for each water circulating system at the Seabrook plant." NECNP's Second Set of Interrogatories and Request for Production of Docu-ments to Applicants on NECNP Contention IV," filed December 23, 1987, at 12 5
For each incident identified in response to Interrogatory 5, Interrogatory 6 asks specific questions regarding "how and when it was treated."
NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Con-tention IV,"
filed December 23, 1987, at 12-13.
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. partially unresponsive, since they refuse to provide the requested information with respect to circulating water systems that are not "cooling systems."
In their partial responses to each of these interrogatories, Applicants have failed to identify what systems they do consider cooling systems, so that NECNP does not know how unresponsive their answers to these questions are.
Applicants have failed to respond at all to Interrogatory 4, which consists of subparts (a) through (k) requesting information about microbiologically induced corrosion found in the fire pro-tcction system, because "issues regarding the Fire Protection system, which is not a cooling system, are outside the scope of Contention IV."7 We gather that Applicants' objections are premised on its (continued) 6 Interrogatory 8 requests information regarding Applicants' program for detecting the presence of microbiologically induced corrosion, and the conditions condusive to microbiologically induced corrosion, "For each system at the Seabrook plant filled with cirulating water, etiher fresh water or salt water, includ-ing but not limited to the Fire Protection, PCCW, ECCS, Secondary Component Cooling Water, Residual Heat Removal, and Feedwater systems."
NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention IV,"
filed December 23, 1987, at 13, 7
"Applicants ' e; >.Jes to NECNP's Second Set of Interrogatories and Request for
'7 luctio:' of Documents to Applicants on NECNP Contention IV,"
... Tanuary 14, 1988, at p.
30.
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. view that the literal terms of NECNP Contention IV concern the adequacy of Applicants' "surveillance and maintenance program for the prevention of the accumulation of mollusks, other aquatic organisms, and debris in cooling systems."8 Therefore, questions concerning circulating water systems other than "cooling systems" are not relevant.
Applicants view of allowable discovery is too narrow.
It is well established that "In modern administrative and legal prac-tice, pretrial discovery is liberally granted to enable the parties to ascertain the facts in complex litigation, refine the issues, and prepare adequately for a more expeditious hearing or trial."
Pacific Gas and Electric Co. (Stanislaus Nuclear Pro-ject, Unit 1, LBP-78-20, 7 NRC 1038, 1040 (1978).
In this regard, interrogatories need only have "general relevance, for discovery purposes, to the matters in controversy in the proceed-ing."
Texas Utilities Generatina Co. (Comanche Peak Steam Elec-tric Station, Units 1 and 2), LPB-81-25, 14 NRC 241, 243 (1981).
Here, NECNP is seeking information about other systems in order to determine the extent to which biofouling has occurred 1
and is adequately treated in general at Seabrook.
These inter-rogatories seeking information about other systems are designed to lead to information that is relevant to NECNP's Contention IV, 8
"NECNP's Supplemental Contentions," filed June 17, 1982.
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. which concerns the adequacy of Applicants' surveillance and maintenance program for the prevention of biofouling in cooling systems.
The presence of biofouling or corrosion in other cir-culating water systems may well indicate that biofouling may occur in cooling systems.
If biofouling has occurred in other circulating water systema, it is necessary to determine whether Applicants have a program designed to prevent or control biofoul-ing in these systems.
Obviously, if Applicants' responses showed that these programs are the same as the programs used to prevent or control biofouling in cooling systems, this may be admissible evidence that such programs are also not adequate to treat or control biofouling in cooling systems.
Accordingly, Applicants have improperly refused to respond to interrogatories that are clearly "relevent to the subject matter involved in the proceed-ing...[or which) appears reasonably calculated to lead to the discovery of admissible evidence." 10 C.F.R. $ 2.740(b) (1).
II.
General Objections Regarding the Scope of NECNP Contention IV and the Definition of "Biofoglina" Applicants make two, general objections to NECNP's inter-rogatories.
First, Applicants object generally to NECNP's inter-rogatories requesting information about microbiologically induced corrosion, on the grounds that "issues concerning the occurrence of microbiologically induced corrosion are not within the scope l
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. - _ _ of Contention IV."9 Second, Applicants object to NECNP's defini-tion of "biofouling" as "any degree of sedimentation and/or cor-rosion of nuclear power plant cooling systems by aquatic debris, macro-or micro-biological organisms, silt, and mud, or by any other organic or inorganic material."10 Instead, Applicants base their responses on the following re-definition of biofouling:
"The term 'biofouling' as used in these responses means extensive settlement of fouling organisms, resulting in significant per-centages of the surfaces being covered and thus measurable t
affecting flow or heat exchanger efficiency.
' Settlement' means colonization on plant surfaces by fouling organisms, primarily mussels and barnacles."11 Applicants objections as to both of these issues are without merit.
A.
Microbiologically Induced Corrosion is Within the Scoce of NECNP Contention IV.
Applicants base this general objection to interrogatories regarding microbiologically induced corrosion on the fact that 9
"Applicants Responses to NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention IV,"
filed January 14, 1988, at 2.
10 NECNP's Second Set of Interrogatories and Request for Produc-tion of Documents to Applicants on NECNP Contention IV," filed December 23, 1987, at 3.
11 "Applicants Responses to NECNP's Second Set of Inter-rogatories and Request for Production of Documents to Applicants on NECNP Contention IV," filed January 14, 1988, at 2.
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. NECNP's Contention IV does not specifically identify "micro-biologically induced corrosion" as a concern.
- However, Applicants' construction of NECNP's contention IV is too narrow, and utterly inconsistent with liberal pleading concept embodied in 10 C.F.R. 5 2.714(b), which require only that contentions identify issues with "reasonable specificity." 10 C.F.R. 5 2.714(b).
"Biofouling" is a broad concept that encompasses several different types of fouling, including fouling by bivalves and other aquatic organisms, and also includes fouling by micro-biological organisms, and the by-product or damage caused by that process, such as sedimentation, corrosion, and degradation of piping and related equipment.
"Microbiologically induced corro-sion " is merely one member of the community of fouling agents that is encompassed by the term "biofouling."
Specifically, it refers to the corrosive by-product of bacteria that grows underneath slime on piping and equipment, as well as any sedimen-tation caused by that process.
As such, it plainly comes within the accepted, scientific definition of "biofouling," and is therefore within the scope of NECNP Contention IV.
A contention need only be specific enough to put other parties on notice so that they will know what to defend against i
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. or oppose, and to assure that the proposed issues are proper for adjudication.
Philadelchia Electric Co. (Peach Botton Atomic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20 (1974).
Clearly, disallowing discovery about any matter not specifically identified by the literal terms of a contention would be inconsistent with the liberal pleading rules for contentions, which "should not be read and construed as establishing secretive and complex technicalities." 1d.12 Here, Applicants do not appear to contend that the question of the adequacy of Applicants' program for monitoring and con-trolling microbiologically induced corrosion is not appropriate for adjudication.
Rather, their objection appears to be a tech-nical, legalistic one, premised on the view that because NECNP Contention IV fails to specifically identify "microbiologically induced corrosion" as one of the types of biofouling encompassed by this contention, it therefore cannot be litigated.
- However, the specific issue of microbiological 1y induced corrosion is one of the several different types of nuclear power plant foulants encompassed within the term "biofouling," as that term is 12 While Intervenors may be bound by the literal terms of their contentions for some purposes, this principle is certainly not applicable in determining the scope of discovery.
Rather, Texas Utilities Generatina Cox (Comanche Peak Steam Electric Station, i
Units 1 and ;), ALAB-868, 25 NRC Slip op at 37. n.32 (June 30, 1987), quoted by Applicants, is inapposite here, as that case does not address the scope of discovery, i
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generally understood in the scientific and industrial community.
Applicants therefore cannot be permitted to avoid litigating this relevant, contested issues based on legalistic objections about the technical wording of the contention, since to do so would undermine the concept of "notice" pleading embodied in 10 C.F.R. 5 2.714(b).13 Other Licensing Board's have refused such literal and narrow constructions of intervening parties' contentions.
In Texas Utilities Generatina Co. (Comanche Peak Steam Electric Station, Units 1 and 2), LPB-81-25, 14 NRC 241 (1981), Applicants argued that the literal terms of Intervenor's contention, which con-cerned the adequacy of the Applicants" program to evaluate "rock
'overbreak'" and "fissure repair" to withstand seismic dis-turbances, did not permit interrogatories into the nature of con-crete poured for foundations, or the use of loose rock materials.
L However, the Licensing Board ruled that the contention was "broad enough to encompass" those matters, stating "Applicants seek to apply too narrow and legalistic an interpretation to contention 7 l
and the interrogatories in question.d Id. at 244.
13 Under Applicants' reasoning, they might legitimately refuse
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to answer all questions concerning fouling by asiatic clams on l
the principle that NECNP Contention IV only specifically i
identifies "mollusks," and identifies all other foulants under l
the general term "aquatic organisms and debris."
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- Here, even a literal reading of NECNP Contention IV clearly puts Applicants on notice that microbiological 1y induced corro-sion is within the scope of this contention.
NECNP Contention IV refers specifically to "the accumulation of mollusks, other aquatic organisms, and debris."
An NRC-sponsored study prepared by Pacific Northwest Laboratories states that "Fouling of all types has often been referred to as "debris" in inspection and maintenance programs."
Neitzel, at al, "Improving the Reliability of Open-Cycle Water Systems: An Evaluation of Biofouling Surveillance and Control Techniques for Use at Nuclear Power Plants," NUREG/CR-4724, Vol. 1 (1986), at 9.
Mcreover, the basis of NECNP Contention IV, by using the term "fouling,"
clearly indicates that all forms of "fouling" are included within the scope of the contention.
NUREG/CR-4724 defines "fouling" as including "bivalve fouling, microbiological fouling, sedimenta-tion, and corrosion." NUREG/CR-4724, Vol.
1, at 5.14 Accor-dingly, merely by use of the terms "fouling" and "debris," the plain language of NECNP Contention IV, and its basis statement, put Applicants on notice that all forms of biofouling, not just fouling by mussels, clams, or other bivalves, is encompassed by l
NECNP Contention IV.
It is also clear from the basis of NECNP Contention IV, that i
14 Hereinafter referred to as "NUREG/CR-4624, Vol.
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. the contention was intended to address the form of biofouling that corrodes the outside of pipes, as well as the form of foul-ing by aquatic organism that blocks intake structures:
The fouling does not occur only in the intake pipes of reac-tors. Organisms may find their way into the entire cooling system and even into the heat exchangers.
Id. at 21654.
In addition, the builduo of foulina orcanism or corrosion oro-ducts on Dioina walls, althouah not severe enouah to block water flow durina normal operation, could be dislodaed by seismic activity and "collect in eauioment bearina or seal coolers blockina the coolina water flow.
NECNP Contentions," filed June 17, 1982, at 2-3 (emphasis added).
The above-quoted identification of the issue clearly indi-cates that microbiologically induced corrosion is within the scope of NECNP Contention IV.
The contention contemplates the build-up of corrosion products, which is understand to be a by-product of the process of microbiologically induced corrosion.
For example, NUREG/CR-4724 specifically defines microbiologically influenced corrosion as a form of "under-sediment corrosion" that can be "biologically induced by the breakdown of organic matter.
Although sediment is sometimes thought of as an inorganic foulant, it is a combination of silt, mud, organic matter, and microbiological foulants such as algae, bacteria, and fungi."
NUREG/CR-4724, Vol.
1, at 8.
"Microbiologically influenced cor-rosion is of particular concern to the utility industry because it has caused through-wall pitting of condenser tubes in a matter 1
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- 12 of weeks." NUREG/CR-4724, Vol.
1, at 7.
Accordingly, while Con-tention IV does not expressly call this corrosive form of fouling by its technical term, microbiologically induced corrosion, this form of biofouling is plainly within the scope of Contention IV.
Even industry-sponsored scientific and technical literature on the subject of "biofouling" recognizes that corrosion caused by microbiological organisms as well as blockage by aquatic organisms is part and parcel of the general "community" of poten-tional foulants at Seabrook:
At Seabrook Station it is expected that the fouling com-munity will be composed predominantly of mussels and barnacles,... Though many other organisms are usually required for the establishment of a fouling community and still others are normally found as constituents of fouling communities, these will not be considered because they are subdominants and make a relatively small contribution to the total community biomass.
Except for their ability for providing initial attachment surfaces for mussels and barnacles, they are generally unobtrusive in terms of cool-ing flow blockage.
However, films composed of some of these orcanisms may impede heat transfer in heat exchance systems
("condenser "slime").
"Biofouling Control for Seabrook Station: Summary Report and Recommendations," Prepared by Public Service Co. of New hampshire and Yankee Atomic Electric Co. (September 1978), at 3 (emphasis added).
This slime also causes the growth of sulfer-reducing bacteria, which acts as "an agressive corrosive agent theat has caused through-wall pitting in mild steel condenser tubing in a s i
. litte as 6 weeks."
NUREG/CR-4724, Vol.
1, at 8.
Finally, it is necessary for Applicants to respond to NECNP's questions regarding the different types of biofouling, in order to obtain information relevant to proving NECNP's ultimate One aspect of NECNP's contention is the extent to which case.
Applicants' biofouling monitoring and surveillance program is adequate to prevent forms of biofouling that have corrosive effects, as well as those forms of biofouling which cause block-age of coolant flow.
This was recognized as a potention issue in NUREG/CR-4724, Vol.
1, at 9 ("Utility personnel contacted during this study indicated that current fouling surveillance and con-trol practices do not distinguish between the different types of fouling.")
Applicants' refusal to respond to NECNP's inter-rogatory questions regarding specific types of biofouling pre-vents will therefore impair NECNP's ability to prove its ultimate case, and is therefore "relevant" for purposes of discovery, within the meaning of 10 C.F.R. 5 2.740(b) (1).
B.
Applicants' Definition of "Biofouling" Is Inappropriate Since it Presumes the Ultimate Issue in Discute.
NECNP defines biofouling as "any degree of sedimentation and/or corrosion of nuclear power plant cooling systems by aquatic debris, macro-or micro-biological organisms, silt, and mud, or by any other organic or inorganic material."15 15 NECNP's Second Set of Interrogatories and Request for Produc-
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- 14 Applicants refuse to accept this general definition, and instead re-define "biofouling" as "extensive settlement of fouling organisms, resulting in significant percentages of the surfaces being covered and thus measurable affecting flow or heat exchanger efficiency.
' Settlement' means colonization on plant surfaces by fouling organisms, primarily mussels and barnacles."16 Applicants provide no explanation for why they object to NECNP's definition of biofouling, nor do they provide any support for their re-definition.
Interrogatories 2(1), (n),
(o), 3(m), (n), (o), (q), (r) request information regarding biofouling.
Accordingly, to the extent that Applicants' responses to this questions are based on an improper definition of "biofouling," their answers to these questions are partially unresponsive.
Neither the plain language of NECNP Contention IV, nor the accompanying statement of basis for the contention, contains any indication that the term "biofouling" encompasses only a particu-lar degree or severity of sedimentation, blockage, or corrosion.
(continued) tion of Documents to Applicants on NECNP Contention IV," filed December 23, 1987, at 3.
16 "Applicants Responses to NECNP's Second Set of Inter-rogatories and Request for Production of Documents to Applicants on NECNP Contention IV," filed January 14, 1988, at 2.
. To the contrary, the basis for NECNP Contention IV, quoted above, clearly indicates that, for purposes of Applicants' responses to NECNP's interrogatories, the definition of "biofouling" must include aDY settlement of fouling organisms on piping wallc.
It makes no reference to the degree or the severity of the settle-ment or the percentage of equipment surfaces being covered.
More importantly, the extent or severity of biofouling is one of the ultimate issues in this litigation.
It may be, that even minor incidents of biofouling may indicate that Applicants' biofouling monitoring and surveillance program is inadequate.
Only after the completion of discovery and after hearing from all parties, is it appropriate to make judgments about the extent or degree of biofouling or sedimentation, for purposes of assessing Applicants' compliance with the relevant General Design Criteria.
At the discovery stage, however, it is critical for Applicants to disclose all information about biofouling incidents, treatments, and surveillance programs, regardless of whether or not Applicants consider the degree or extent of biofouling to be sig-nificant.
Otherwise, NECNP will be foreclosed from acquiring information relevant to its contention based on a prejudgment l
about the merits of NECHP's Contention IV that is not theirs to l
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l III. Relief Recuested Based on the arguments above, NECNP respectfully requests that the Board enter an order compelling Applicants to provide full and complete answers to NECNP's Second Set of Inter-rogatories and Request for Production of Documents to Applicants on NECNP Contention IV.
Specifically, NECNP requests the follow-ing relief from the Board:
1)
That Applicants be ordered to respond fully to Inter-rogatories 2(t), 3(w),
4, 5,
6, and 8,.with respect to all cir-culating water systems at Seabrook, it.cluding but not limited to "cooling systems."
In the alternative, NECNP requests that Applicants be ordered to identify specifically those circulating water systems that they do not consider "cooling systems."
2)
That the Board rule that microbiologically induced cor-rosion is within the scope of NECNP Contention IV for purposes of this litigation, or at minimum, for purposes of this, and all future, discovery.
3)
That Applicants be order to respond fully to Inter-rogatories 2(1), (n), (o), 3(m), (n), (o), (q), (r), based on the definition of biofouling contained in NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention IV, to wit, "any degree of sedi-mentation and/or corrosion of nuclear power plant cooling systems by aquatic debris, macro-or micro-biological organisms, silt,
. and mud, or by any other organic or inorganic material."
Respect ully submitted, Andrea Ferster HARMON & WEISS 2001 "S" Street N.W.
Suite 430 Washington, D.C.
20009 (202) 328-3500 CERTIFICATE OF SERVICE I certify that on January 25, 1988, copies of the foregoing pleading were served by first-class mail on all parties listed on the attached service list.
f Andrea Ferster 0
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CCCHCiED DWC
'88 JAN 27 40:n SEABROOK SERVICE LIST -- ONSITE LICENSING BOARD h
Charleb.7M I,hf #
'Sheldon J. Wolfe, Chairman North flampton. Nil 03826 111 LowellStreet Oprhoch.
Atomic Safery and Licensing Manchester,NH 03105 Board J.P. Nadeau McKay, Murphy and Graham U.S. NRC Town of Rye
'Greg Bery 100 Main Street Washington, D.C 20555 155 Washington Road NRC Amesbury,MA 01913 Rye, New Hampshire 03870 1155 Rochille Pike
'Dr. Jerry Harbour 1 White Flint North Atomic Safety and Licensing Richard E. Sullivan, Mayor Rochille,MD 20852 Board City Hall
- By hand U.S. NRC Newburyport,MA 01950 Mr. Angie Machitos, Washington, D.C 20555 Chairman
" By Overnight Mail Alfred V. Sargent, Chairman Town of Newbury
- Dr. Emmeth A. Luebke Board of Selectmen Town Hall,25 High Road
$500 Friendship Blvd.
Town of Salisbury, MA 01950 Newbury,MA 01951 Apartment 1923N Chesy Chase, MD 20815 Senator Gordon J. Humphrey George Dana Bisbee, Esq.
U.S. Senate Geoffrey M. Huntington, Esq.
Atomic Safety and Licensing Washington, D.C. 20510 Office of the Attorney General Board Panel (Attn. Tom Burack)
State House Annex 1
U.S. NRC Concord, NH 03301 Washington, D.C 20555 Selectmen of Northampton Northampton, New Hamp-Allen Lampert Atomic Safety and Licensing shire 03826 Civil Defensa Direvor Appeal Board Panel Town of Brentowood U.S. NRC Senator Gordon J. Humphrey Exeter,NH 03833 Washington, D.C. 20555 1 Eagle Square, Ste 507 Concord,NH 03301 Richard A. Hampe, Esq.
Docketig and Senice Hampe and McNicholas U.S. NRC Michael Santosuosso, 35 Pleasant Street Washington, D.C. 20555 Chairman Concord,NH 03301 Board of Selectmen Mrs. Anne E. Goodman Jewell Street, RFD # 2 Gary W. Holmes, Esq.
Board of Selectmen South Hampton, Nil 03S42 Holmes & Ellis 1315 New Market Road 47 Winnacunnent Road Durham,NH 03842 Judith H. Mizner, Esq.
Hampion,NH 03S42 Silverglate, Gertner, et al.
William S. Lord, Selectman 88 Broad Street William Armstrong Town Hall-Friend Street Boston, MA 02110 Chil Defense Director j
Amesbury,MA 01913 10 Front Street Rep. Roberta C. Pevear Exeter,NH 03S33 Jane Doughty Drinkwater Road SAPL Hampton, Falls, NH 03S44 Cahin A. Canney 5 Market Street City Manager Portsmouth,NH 03801 Phillip Ahrens, Esq.
City Hall Assistant Attorney General 126 Daniel Street Carol S. Sneider, Esquire State House, Station # 6 Portsmouth, Nil 03S01 l
Assistant Attorney General Augvsta,ME 04333 1 Ashburton Place,19th Floor Matthew T. Brock, Esq.
Boston,MA 02108 "Thomas G. Dignan, Esq.
Shaines & McEachern R.K. Gad 1I, Esq.
P.O. Box 360 l
Stanley W. Knowles Ropes & Gray Maplewood Ave.
4 Board of Selectmen 225 Franklin Street Portsmouth,NH 03S01 P.O. Box 710.
._ _ Boston, MA 02110__ _ __ _ _._
Sandra Gavutis Robert A. Backus, Esq.
RFD 1 Box 1154 Backus, Meyer & Solomon East Kensington, NH 03827
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