ML20151G636
| ML20151G636 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/22/1988 |
| From: | Bergquist S, Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#388-6799 ALAB-895, OL-1, NUDOCS 8807290056 | |
| Download: ML20151G636 (19) | |
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[ *... 'E UNITED ST ATES OF AMERIC A . _
NUCLE AR REGUL ATORY~ COMMISSION 'T8 -JUL 22 P 3 :27'
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B E F O R E T H E C,0 M MISSIO N
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'). Ir the Matter of. )
Docket Nos. 50-443 OL-01 PUBLIC . SERVICE. COMPANY 0F . 50-444 OL-01 NEW H AMPSHIRE, et al. (On-site ' Emergency Planning
) and Safety Issues)
(Seabrook Station, Units 1 and 2) )
NRC ST AFF RESPONSE TO COMMISSION ORDER OF JULY 14, 1988 Gregory Alan Berry Counsel for N R C Staff 8807290056 880722 3 Stephen A. Bergquist PDR ADOCK 0500 Counsel for N RC Staff o
July 22, 1988 f*b
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.,. UNITED ST ATES OF AMERIC A~
- '- ' N U C LE A R R EG UL'A T O R Y C OMMISSIO N' y
BEFORE THE COMMISSION
)
In the Matter of )
) Docket Nos. 50-443 0 L-01 PU BLIC SE R VICE C OMP A N Y O F. ) 50-444 - O L-01 NEW }! AMPSHIRE, et al. --
) - (On-site Emergency Planning
) and Safety Issues)
(Seatrook Station, Units 1 and 2) )-
NRC ST AFF RESPONSE TO COMMISSION ORDER OF JULY 14, 1988 .
l i
i l-Gregory Alan Berry ;
l Counsel for N R C Staff Stephen A. Bergquist
- Counsel for N RC Staff July 22, 1988 1
UNITED, STATES OF AMERICA
' ' ' , NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF 50-444 OL-01
'- NEW HAMPSHIRE, et al. On-site -Emergency Planning
) and Safety Isstes (Seabrook Station, Units 1 and 2) )
NRC STAFF RESPONSE TO COMMISSICN 0_RDER OF JULY 14, 1988 INTRODU_CTION On July 14, 1988, the Commission issued an order soliciting the parties' views regarding ALAB-895 1/ i n which the Appeal Board held that the Massachusetts Attorney General's petition for a waiver of the
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Public Service Company of flew Hampshire (Seabrook Station, Units 1 and27,'ALAB-895,28NRC ~'(July 5, 1988). In ALAB-895, the Appeal Scard also had Lefore it a petition for waiver of the Commissier.'s financial qualification rules filed jointly by the Seacoast Anti-Follution League (SAPL), the New England Coalition On Nuclear Pollution (NECNP), and the Town of Hampton. The Appeal Bocrd found that the joint petition, as amended, which rested upon the bankruptcy petiticn filed by Public Service Company of New Hampshire, made out a prima facie that Applicants might not have the resources necessary to operate the facility safely at low power. See ALAE-895, slip op. at 21-24 Accordingly, the Appeal Board affirmed the Licensing Board's denial of the joint petition. Id. at 39.
It is not necessary to
- address in this response whether ALAB-895 is correct insofar as it l relates to the waiver petition filed jointly by SAPL, NECNP, and the Tcwn of Hampton since that question is not presented here. The Staff will address this question in its response to the joint intervenors' July 12, 1988 petition for review of ALAB-895 which will be filed
. with the Conmission en or before July 25, 1988.
-7 Commission's financial qualification rules 2/ presented a prima facie case that Applicants lack sufficient funds to operate the Seabrook facility safely at low power. In view of this finding and pursuant to 10 C.F.R. 9 2.758(c), the Appeal Board certified to the Comission the question whether the Attorney General's petition should be granted.
- For the reasons set forth in this brief, the Comission should deny the Attorney General's petition for a waiver of the Commission's financial qualifications rules.
RACKGROUND On March 7, 1988, the Attorney General for the Commonwealth of Massachusetts filed a petition for waiver' of the Ccmission's financial cualification rules. 3/ The Attorney General alleged that special circumstances exist such that application of the Commission's financial qualification rules would not achieve the purpose for which they were promulgated. Thus, ~ the Attorney General reouested the Appeal Board to find that his petition made the prima facie showing required by 10 C.F.R. 6 2.758 and to refer the petition to the Commission for a determination as 2/ 10 C.F.R.,%@ 2.104(c), 50.33(f), and 50.57(a)(4).
-3/ See Massachusetts Attorney General James M. Shannon's Petition Under TF C . F. R . 2.758 For A Waiver Of Or An Exception From The Public <
Utility Exemption From The Requirement Of A Demonstration Of Financial Qualification (March 7,1988) (hereinaf ter "AG Petition").
It should be noted that in July 1987, the Seacoast Anti-Pollution League (SAPL), the New England Coalition On Nuclear Pollution (NECNP), and ti
- Town of Hampton filed a similar waiver petition.
The Licensing Boa.d denied their petition on the ground that it did not make out a priaa facie case that application of the regulations in question would noT. serve the purposes for which they were adopted.
See Memorandum and Oider (Denying Waiver Petition) (August 20,1987).
TFe ricensing Board'sTetermination was affirmed by the Appeal Board.
See ALAB-895, slip op at 12-23.
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w to whether a waiver of or excep' tion to. the financial qualification rules should be granted.
On May 13, 1988, the Attorney General filed a supplement to his petition. SI His initial ' petition and this supplement maintained that substantial present and potential costs associated with low power o'peration and testing of the Seabrook plant, together with possible bankruptcy-related constraints on the availability of funds to Public Service Company of New Hampshire (PSNH) to cover its pro rata share of the facility's maintenance costs, and the questionable willingness or ability of the other joint owners to abscrb PSNH's cost share, trade it unlikely that adequate funding for safe icw-power operation and decommissioning of the plant would be available.
In ALAB-895 the Appeal Board held that the Attorney General's initial waiver petition failed to demonstrate that the pending Dankruptcy reorganization proceeding involving PSNH precluded Applicants from n:eeting the low-power operation costs of the Seabrook Station. ALAB-895, slip op.
at 35. However, the Appeal Board determined that this deficiency was cured by the Attorney General's second supplement to his waiver petition. SI Id., slip op, at 37. In that supplement, the Attorney
-4/ See Supplement to Fassachusetts Attorney General James M. Shannon's Petition Under 1G C.F.P. 6 2.758 For A Waiver Of Or An Exception To The Fublic Utility Exemption From The Pequirement Of A Demonstration Of Financial Qualification (May 13,1988).
~5/ See Second Supplement to Massachusetts Attorney General James M.
3hannon's Petition Under 10 C . F . P . s P.758 For A Haiver Of Or An Exception From The Public Utility Exerrption From The Requirement Of A Demonstration Of Financial Quelification (June 2,1988) ("Secend AG Supplement").
General alleged that Massachusetts Municipal Wholesale Electric Company (MMWEC), a co-applicant holding a nearly 12% interest in the Seabrook Station, had halted its monthly pro rata contribution toward the facility maintenance costs. The Appeal Board held that the potential revenue shortfall occasioned by MMWEC's action satisfied the prima facie showing
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that Applicants lack sufficient funds to cperate the facility safety at low power necessary to certify the matter to the Commission. Id., slip op. at 37.
On July' 14, 1988, the Commissicn issued an order soliciting the parties' views as 'to whether the Commission should grant the Attorney General's waiver petition. July 14 Order at 2. For the reasons set forth in this respcnse, the Commission shculd deny the Attorney General's waiver petition.
ARGUMENT A. Legal Standards Regulations prcmulgated by the Commission may.not be challenged in an adjudicatory proceeding. See 10 C.F.R. 5 2.758(a). A party, however, may-petition for a waiver of or exception from the application of the regula-tion in question. See 10 C.F.R. 6 2.758(b). As is apparent from the text of section 2.758(b), the application of a duly promulgated regulation will not be waived lightly:
The sole ground for petition for waiver or exception shall be that special circumstances with respect to the subject matter of the particular proceeding are such that application of the rule or regulation (or provision thereof) would not serve the purposes for which the rule or regulation was adopted.
i .,
10 C.F.R. -6 2.758(b) (emphasis added); see Northern State,s, Power Company (Venticello Nuclear Generating Plant, Unit 1), CLI-72-31, 5 AEC 25, 26 (1972) (waiver petitions should be granted only in "unusual or compelling circumstances"). Adjudicatory tribunals have no warrant to waive or grant an exception to a Commission regulation. Rather, section 2.758(d) provides that if a waiver petition makes a prima facie case that applica-tien of _the regulation would not serve its intended purpose, the presiding officer is to refer the matter directly to the Commission for a determina-tion as to whether a waiver or exception should be granted. 10 C.F.R.
! 2.758(d). On the other hand, if the petition fails to set forth a prima facie case, the petition must be dismissed. 10 C.F.f! 5 2.758(c).
While section 2.758 itself does not specify the quantum of proof necessary to establish a prima 'acie case, Comission case law establishes that it "must be legally sufficient to establish a fact or case unless disproved." Pacific Gas and Elec,tric Company (Diablo Canyon Plant, Units 1 and 2), ALAB-653, 16 NRC 55, 72 (1981). Further, this standard must be applied in conjunction with the provisions of section 2.758(c), which commands the presiding officer to consider not only the waiver petition itself, but also supporting effidavits and responses, affidevits, and other information submitted in opposition to the petition. See 10 C.F.R.
%2.758(c). In view of these considerations, it is apparent that a waiver petition must be dismissed unless it is sufficient -- when considered in light of any response, affidavit, or other information submitted in opposition -- to establish that application of the regulation in cuestion would not serve the purpose for which it was adopted. For the reasons set
1 forth: in Part C of this brief, po_s t , the Attorney General's waiver petition fails to satisfy this showing.
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B. The C_ omission's Financial Qualification Rules The regulatory provisions which the Attorney General seeks to have 1.
waived were first propcsed by the Comission in April 1984. See "Elimination Of Review Of Financial Qualifications Of Electric Utilities In Operating License Reviews And Hearings For Nuclear Power Plants", 49 Fed. Reg. 13044 (April 2, 1984). In the preamble accompanying the proposed rule, the Comission stated that it is:
- reasonable to conclude that, as a general rule, the rate regu-lation process assures for regulated electric utilities (or for those able to set' their own rates) the ability to meet the costs of safe operation of a nuclear facility.
49 Fed. Reg. at 13045. The Comission noted that "in financial qualification reviews at the operating license stage conducted under the original rule, [it] has found in every case that the state and local public utility commissions could be coated on to provide all reasonable operating costs to licensees, including costs of compliance with NRC requiren,ents associated with safe plant operation." Ld . In light of this experience, it appeared to the Commission that future "case-by-case review on this issue [i.e., the financial qualification of a regulated utility to operate a nuclear plant that has already been constructed] is neither necessary nor productive." Ld.
According to the Comission, such case-by-case review would be unwarranted if it was in fact the uniform practice of state regulatory bodies to set the rates of regulated utilities "such that all reasonable
! costs of serving the public may be recovered, assuming prudent management
! of the utility." 49 Fed. Reg. at 13045, n.1. The Comission alluded to a
,i , study of public utili.ty commissions then being conducted by the National Association of Regulatory Utility Comissioners "to determine whether, historically, utilities which have requested rate increases or rate provisions for .cperating safety requirements have regularly received them." I d_. The Comission stated that if "this study should indicate that [the] Comission is mistaken in its present view that the rate process assures electric utilities t.e financial resources needed fcr safe operation, the Comission will of course reassess its position on the proposed rule." ,I_d.5/
It is clear from the - foregoing that the Comission was exempting regulated utilities frcm the requirement to demonstrate its financial qualification to operate a nuclear facility because the Comission belicved that reculatory bodies could be counted on to provide all reasonable operating costs to licensees. The Comission's purpose in amending sections 2.104(c)(4), 50.33(f), and 50.57(a)(4) was to give effect to this belief. See 49 Fed. Reg. 13044-13046. As the Comission stated in the preamble accompanying the final rule:
The Comission believes that the record of this rulemaking den:onstrates generically that the rate process assures that funds needed for safe operation will be made available to regulated electric utilities. Since obtaining such assurance was the sole objective of the financial qualification rule, the Commission concludes that, other than in exceptional cases, no case-by-case litigation of the financial qualification of such applicants is warranted.
"Elimination Of Review Of Financial Qualifications Of Electric Utilities In Operating License Reviews And Hearings For Nuclear Power Plants", 49 6/ The study confirmed the Comission's view. See 49 Fed. Reg. 35747 (September 12,1984),
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Fed. Reg. 35747, 35750 (September 12, 1984). Although eliminating
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case-by-case litigation in an operating license proceeding of an electric utility's financial qualification, E the Comission advised that it retained "its residual authority under Section 182a [42 U.S.C. 6 2232(a))
of the Atomic Energy Act of 1954, as amended, to require such additional
- information in individual cases as may be necessary for the Comission to determine whether an application should be granted or denied or whether a license should be Ecdified or revoked." 49 Fed. Reg, at 35751. Mnreover, the Conmission provided that the amended regulations -- as are all Commission regulattens -- might be subject to a waiver or exception pursuant to 10 C.F.R. 5 2.758. J_d . The Comission gave an example of the type of showing necessary to permit financial qualification review for an operating license applicant:
[A]n exception . . . might be appropriate where a threshold showing is made that, in a particular case, the local public utility conmission will not allow the total cost of operating the facility to be recovered through rates.
Id. (emphasis added). Such a showing might be sufficient under 10 C.F.R. 5 2.758 hecause it is the kind of "special circumstances" which tend to indicate that the purpose of the financial qualification exemption for electric utility operating license applicants -- to cbviate the need to review financial qualification in cases where the ratemaking process assures that funds needed for safe operation will be made available --
1 l ~7/ Case-by-case review of an electric utility's financial qualification would remain pennissibic in construction permit proceedings. See 49
. Fed. Reg. at 13045 ("The Comissien proposes to retain its current l review under i 50.33(f) et the construction pennit stage").
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would not be served if the rule were applied. Compare 10 C.F.R.
$ 2.758(b), with, 49 Fed. Reg. 35750 (September 12,1934) (final rule).
C. The Atto,rney General's Waiver Petition Should Be_ Denied As noted earlier, the Appeal Doard's finding that the Attorney General had established a prima facie case rested solely on the Attorney
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General's showing that (1) MMWEC had announced its decision to discontinue contributing its 11.59% share of the seabrook maintenance costs and (2) the ur.willingress or inability of any of the other co-owners to pick up MMWEC's share:
It is the financial inability or unwillingness of PSNH or some other joint owner to fund its share of the cost to operate Seabrook safely at low power that, if established, provides the special circumstances warranting a rule waiver.
ALAB-895, slip op. at 29; see also id. at 30,31-38. This finding has been superseded by subsequent events, however, and therefore should be vacated. U On July 13, 1966, eight days after the issuance of ALAB-895, Northeast Utilities, another of the Seabrook joint owners, issued a news release announcing that it would "provide funding of the 11.6 percent share in Seabrook owned by Passachusetts Municipal Wholesale Electric i
Company (MMWEC) through August 31, 1988." See News Release at 1, attached to "Commission Notification filed by Applicants (July 14,1988). A copy of the news release is attached to this response. The news release also 8/ For this reason, it is not necessary to address whether the Appeal Board was correct in concluding that a prima facie case could be established where it is uncontroverted that an applicant will be able to recoup its operating costs through the ratemaking process once a full pcwer license is issued.
1 1
i indicates that Applicants "are workin0 vigorously to structure an arrangement to provide funoing for the WWEC share for a period of at least a year." M.at~2.
In view of this development, the circumstances underlying the Appeal Board's decision to certify the Attorney General's . petition to the Comission do not currently obtain. In other words, another co-owner of Seabrook 'has "step [ ped) forward to meet the shortfall caused by MWEC's action," an occurrence which, had it taken place earlier, likely would hcVe led the Appeal Board to deny the Attorney General's petition. See ALAB-895, slip op. at 37. Since jurisdiction over the Attorney General's petitien has now passed from the Appeal Board, the Commission properly can and should consider this new development in determining whether to exercise its discretion to waive its financial qualification rules. See 10 C . F . R . 62.758(c) (in considering a waiver petition, the presiding officer is to consider not only the pe ti tion itself but also any responses, affidavits, and other information submitted in opposition).
Based on the present state of the record, it appears that Applicants currently have adequate funding to maintain and operate the Seabrook Station safely at least through August 31, 1988. Therefore, the Attorney General's petition for a waiver of the Comission's financial qualification rules does not now set forth a prima facie case that Applicants lack the funding necessary to maintain and operate the Seabrook Station. Consequently, there is no present basis for the Commission to conclude that the waiver petition satisfies the requirements of 10 C.F.R.
, , . ! 2.758(b). 2/ -Accordingly, the Commission should deny the Attorney General's waiver petition and vacate ALAB-895 to the extent that it concludes that the petition establishes a prima facie' case. El CONCLUSION For the reasons stated ir, this brief, the Attorney General's waiver petition shculd be denied and ALAB-895 vacated to the extent the Appeal Board found that the petition made out a prima facie case that application of the Commission's financial qualification rules would not serve the purpose for which they were adopted, ctfully submitted Gregory N
an I Mi rry Counsel rN Staff b '
Stephen A. Bergquist Counsel for NRC Staff Dated at Rcckville, Maryland this 22nd day of July 1988 9/ Although the waiver petiton shculd be denied in view of Applicants' success in securing funding to compensate temporarily for the shortfall caused by MMWEC's withdrawal, the Attorney General remains free to renew or amend his petition for waiver at such time in the future as it appears to him that circumstances exist to warrant a waiver of the Coninission's financial qualifications rules and which satisfy the requirements of 10 C.F.R. 5 2.758(b).
-10/ The Staf f will continue to folicw its usual practice of monitoring developments bearing on Applicants' ability to maintain and operate the Seabrook Station safely and, pursuant to secticn 182 of the Atomic Energy Act, will require Applicants to demonstrate -- prior to the commencement of low power operations -- that there is reasonable assurance that they possess or can obtain the financial resources needed to conduct that activity in a manner that does not threaten the public health and safety.
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July 14, 1988 UNITED STATES OF AMERICA before the NUCLEAR REGULATORY COMMISSION
)
In the Matte- of )
)
PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL-1 OF NEW HAMPSHIRE, EI AL. ) 50-444-OL-1
)
(Seabrook Station, Units 1 ) (Onsite Emergency and 2) ) Planning and Safety
) Issues)
)
COMMISSION NOTIFICATION Pursuant to its obligation to keep the Commission and parties advised as to matters which may affect issues before it, the Applicants attach hereto a press release issued by Northeast Utilities indicating that it is advancing sufficient funds to the Seabrook Project to provide funding for the 11.6% share owned by MMWEC through August 31, 1988.
The release further indicates that activities are underway to attempt to put in place a structure which will assure funding for a period of at least a year.
Respectfully submitted,
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/
-?e _ Yh
' Th oma s' G . Dignan, Jr.
George H. Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 counsel for Applicants
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l 90 0 R T N E A C T trT E m m s NE!1AE, Release <
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8 e bu f fo M4?cet CmaJ 061414270 CONTAC7: R. E. Busch office (203) 665-3144 Evenings: (203) 665-5000 E Np p o uen/L /pr,'s o /, m .
AGREEMENT oN SEASROOX INTERIM FUNDrNG REACHED HAR;roRo, July 13, 1988--In a move designed to preserve the region's options for supplying the demand for electricity, Northeast Utilities (NU) today announced an agreement with a group of ether New England utilities under which NU will provide short-term funding for a portion of the seabrook project that was subject to default. As an integral part of the agreement, New England utility participants in the Seabrook project have contracted to purchase for one year a combined total of 250 megawatts of capacity from the NU system at that utility system's average cost.*
Under the agreement, the Northeast Utilities system is advancing approximately $2 million, an amount which will provide funding of the 11.6 percent share in seabrook owned by the Massachusetts Municipal Whelesale tiectric Company (MMWtc) through l
l August 31, 1988. MMWEC's Board of Directors is continuing on a 1
l course, decided upon last month, not to provide additional support 1
l payments to the Seabrook project, l
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- The cost vill be on a "slice of system" basis as recomnended l by the Connecticut Oepart=ent of Public Utility control in a 1987 l C'o & P rate decision. This is the average cost of all capacity
"'^V'ifd DV NU- . . . . . , . , . .. .. . ...
, Announcing the agreement, HU President and Chief Operating officer Bernard M. rex emphasized NU is not acquiring any additional ownership in Seabrook beyond the 4.1 percent share held by its Connecticut Lignt and Power Company (CL&P) subsidiary. Me stated:
This interim funding will assure the project financial viability until september 1, 198s,'s by which time longer term arrangements could be in place. We are werking vigorously to structure an arrangement to provide funding for the MMWEC share for a period of at least a year. As with the interim arrangement, NU's participation in the longer term financing vehicle would maintain the Seabrook option while providing important benefits to the NU system's ratepayers and shareholders.
The utility systems contracting to purchase the short-term capacity from NU as part of the agreement are Commonwealth Electric System and ! astern Utilities Associates both Massachusetts companies, Public Service Company of New Hampshire, and The United Illuminating Conpany, Connecticut, i # ##
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' .. UNITFn ST ATES OF AMERIC A NUCLEAR REGULATORY COMMISSION 88 JL 22 P3 :27 BEFORE THE COMMISSION 0((CbBRAMmY) U In the Matter of- )
) Docket Nos. 50-443 OL-01 FUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW- H AMPSFIRE, et al. ) On-site Emergency Planning
) and Safety Issues (Seabrook Station, Units 1 and 2 )
CERTIFIC ATE OF SERVIH I hereby certify that copies of "NRC STAFF RESPONSE TO C O M MIS SIO N ORDER CF JULY 14, 1988" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as in dicated by an asteris k , by deposit in the fluclear Reg ulatory Commission's internal mail system or, as indicated this 22nd day of July 1988.
Sheldon J. Wolfe, Esq., Chairman
- Atomic Safety and Licensir.g Administrative Judge Board
- Atorric Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D C 20555 Washington, DC 20555 Dr. Jerry Harbour
- Docketing and Service Section*
Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke T homas G. Dignan, Jr., Esq.
A dministrative Judge Robert K. Gad, III, Esq.
4515 Willard Avenue Ropes & Gray Chevy Chase, Maryland 20815 225 Franklin Street Pcston, M A 02110 Atomic Safety and Licensing H . J . Fly n n , Es q .
Appeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Washington, DC 20555 500 C Street, SP Washington, D C 20472
w gu . :,
0
, , , Philip Ahren, Esq. Calvin A. Canney Assistant Attorney General City Hall
-Cffice of the Attorney. General 126 Daniel Street
. State House Station Portsmouth, N H 03801 Augusta, ME 04333 Mr. Angie Machiros, Chairman Carol S. Sneider, Esq. Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General Newbury, M A 09150 One Ashburton Place,19th Floor Boston, M A 02108 George Dana Bisbee, Esq. Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwocd 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, N H 03833 Ellyn R . Weiss , Esq. William Armstrong Diane Curran, Esq. Civil Defense Director Harmon & Weiss Town oF Exeter 7001 S Street, N W 10 Front Street Suite 430 Exeter, N H 03833 k'ashington , D C 20009 Robert A. Backus Esq. Gary W. Holmes, Esq.
Backus, Meyer & Solomon Holmes & Ellis 116 Lcwell Street 47 Winnacunnet Road Manchester, N H 03106 Hampton, N H 03E4?
Paul McEachern, Esq. J. P. Nadeau Matthew T . Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Street 25 Maplewood Avenue Rye, NP 03870 P.O. Box 360 Portsmouth , N H 03801 Judith H. Mizner, Esq.
Charles P. Graham, Esq. Silverglate, Gertner, Baker, Mcrsay, Murphy & Graham Fine & Good 100 Main Street 88 Board Street Amesbury, M A 01913 Boston, M A 02110 Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectmen Board of Selectmen R F D #1, Box 1154 Town Office Kensington, N H 03827 Atlantic A venue North Hampton, NH 03870 William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall
- Town Hall - Friend Street Newburyport, MN 09150 Amesbury, M A 01913
Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, N H 03824 Hon. Gordon J. Humphrey Ashed N. Amirian, Esq.
United States Senate Town Counsel for Herrimac 531 Hart Senate Office Building . 376 Hain Street Washington, D C 20510 Haverhill, M A 08130 Gregorf Alt AU Ber ay M . >
Counsel fori : P. C Staff
.