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Category:INTERVENTION PETITIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20237C6981998-08-18018 August 1998 Sapl/Necnp Reply to Naesco Response to Proposed Contentions.* Board Should Admit Sapl/Necnp Contentions 1-4 & North Atlantic Energy Svcs Corp Arguments to Contrary. W/Certificate of Svc ML20237C6791998-08-18018 August 1998 Sapl/New England Coalition on Nuclear Pollution Reply to Staff Answer to Contentions.* Petitioners Believe Board Can & Should Give Cases Consideration W/O Filing of Addl,But Not Substantively Different Contention.W/Certificate of Svc ML20237A0501998-08-10010 August 1998 North Atlantic Energy Svc Corp Response to Proposed Contentions.* Petitioners Failed to Propose Admissible Contention.Request for Hearing & Petition to Intervene,As Applied to Both Petitioners Should Be Denied ML20236X9281998-08-10010 August 1998 NRC Staff Answer to Contentions.* for Reasons Stated,All of Contentions Proposed Should Be Rejected & Proceeding Should Be Terminated.W/Certificate of Svc ML20066H2581991-02-14014 February 1991 Response of Ma Atty General & Necnp to ASLB Order of 910124.* Intervenors Believe ASLB Should Reopen Record, Permit Discovery & Hold Hearing on Beach Sheltering Issues. W/Certificate of Svc ML19332D7241989-11-21021 November 1989 Intervenors Motion for Clarification Or,In Alternative,For Reconsideration.* Clarification or Reconsideration of Scheduling Requirements Set by Commission 891121 Order Requested.Certificate of Svc Encl ML19332D5191989-11-15015 November 1989 Applicant Answer to Intervenors Motion to Admit late-filed Contention & Reopen Record Based Upon Withdrawal of Commonwealth of Ma Emergency Broadcast Sys Network & Wcgy.* Motion Should Be Denied Since Results Unlikely to Change ML19325E0171989-10-20020 October 1989 Applicant Answer to Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Motion to Assert Addl Bases for Original Onsite Exercise Contention JI-Onsite Ex-1 Should Be Denied.W/Certificate of Svc ML19325E0011989-10-20020 October 1989 Applicant Response to Intervenors Motion to Amend Intervenors Motions of 890929 & 1013 to Admit Contentions on 890927 Onsite Emergency Plan Exercise.* Issue Re Admittance Committed to Board Discretion.Certificate of Svc Encl ML20248J3511989-10-13013 October 1989 Intervenors Second Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Advises That Applicant Contentions Filed on 890929 to Admit Addl Bases Re Scope of Onsite Exercsise Should Be Admitted.W/Certificate of Svc ML20248J0601989-09-28028 September 1989 Intervenors Motion to Admit Contentions on 890927 Emergency Plan Exercise.* Requests Hearing & to Engage in Discovery for Hearing on Contention.Supporting Documentation & Certificate of Svc Encl ML20247Q6761989-09-22022 September 1989 Intervenors Second Informational Suppl to Low Power Contentions Filed on 890721 & 0828.* Incorporates Encl Plant Startup Test Procedure 1-ST-22,Rev 2 Into Low Power Testing Contentions.W/Supporting Info & Certificate of Svc ML20246N1001989-09-0101 September 1989 Intervenors Reply to Responses of Applicant & Staff Re Intervenors Motion to Admit Contention,Or,In Alternative,To Reopen Record & Request for Hearing.* Contention Raises New Issues & Should Be Admitted.W/Certificate of Svc ML20247E0321989-07-21021 July 1989 Intervenors Motion to Admit Contention,Or in Alternative,To Reopen Record & Request for Hearing.* Requests Contentions Re Deficiencies in Training,Mgt Control,Supervision, Communication & Procedure Compliance Be Admitted ML20246P2041989-07-0505 July 1989 Joint Intervenor (Ji) Contentions on Spmc & June 1988 Graded Exercise.* ML20248F4691989-04-0303 April 1989 Seacoast Anti-Pollution League (Sapl) Trial Brief on Contention Ji 56 & Sapl Contentions EX-2,4,6,7,8,12,13 & 14.* Svc List Encl ML20206M9761988-11-23023 November 1988 NRC Staff Response to 881114 Board Order Requesting Comments on Significance of ALAB-903 for Seabrook Proposed General Exercise Contentions.* Contentions & Bases Should Be Denied. Certificate of Svc Encl ML20206M9431988-11-22022 November 1988 New England Coalition on Nuclear Pollution Comments on Significance of ALAB-903 to Seabrook Offsite Exercise Contentions.* Svc List Encl ML20206M9031988-11-22022 November 1988 Seacoast Anti-Pollution League Comments on Significance of ALAB-903 to Exercise Contentions.* Svc List Encl ML20205R7201988-11-0202 November 1988 Town of Hampton Contention on Applicant Plan to Fund Decommissioning Costs of Seabrook Station.* Supporting Documentation & Certificate of Svc Encl ML20205R5661988-11-0202 November 1988 Seacoast Anti-Pollution League Contentions on Applicant Plan in Response to NRC Order CLI-88-07.* Supporting Documentation Encl ML20205R5441988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Financial Qualifications to Operate Seabrook Nuclear Power Station.* Supporting Documentation & Certificate of Svc Encl ML20205R4971988-11-0202 November 1988 New England Coalition on Nuclear Pollution Contentions on Applicant Decommissioning Plan,Motion for Stay of Low Power Operation & Motion to Reopen Record.* Supporting Info & Svc List Encl ML20205R4821988-11-0202 November 1988 Commonwealth of Ma Atty General Jm Shannon late-filed Contentions Concerning Joint Applicant Decommissioning Plan for Seabrook Nuclear Power Station.* ML20205E0011988-10-24024 October 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to Commonwealth of Ma Atty General Exercise Contentions.* Certificate of Svc Encl ML20205E0271988-10-21021 October 1988 New England Coalition on Nuclear Pollution (Necnp) & Town of Hampton (Toh) Reply to Applicant & NRC Staff Responses to Contentions Toh/Necnp EX-2 & Toh/Necnp EX-3.* Svc List Encl ML20205D8051988-10-21021 October 1988 Town of Hampton & New England Coalition on Nuclear Pollution Reply to Responses of Staff & Applicant to Intervenor Contentions on Graded Exercise.* Certificate of Svc Encl ML20206C1951988-10-18018 October 1988 Seacoast Anti-Pollution League (Sapl) Reply to Applicant & Staff Responses to Sapl Contentions on June 1988 Graded Exercise.* Svc List Encl ML20204G9731988-10-13013 October 1988 NRC Staff Response to Intervenors Contentions on Graded Exercise.* Proposed General Exercise Contentions Should Be Admitted for Litigation & Proferred Contentions Should Be Denied Admission.Certificate of Svc Encl ML20154S4571988-09-28028 September 1988 Applicant Response to Intervenor Contentions on June 1988 Seabrook Exercise.* Intervenor Contentions Should Be Disposed Of.Certificate of Svc Encl ML20154P3461988-09-21021 September 1988 New England Coalition on Nuclear Pollution & Town of Hampton Contentions Re 1988 Exercise of Offsite Plans & Preparedness for Plant Emergency Planning Zone.* Svc List Encl ML20154K8741988-09-21021 September 1988 Commonwealth of Ma Atty General Exercise Contentions Submitted in Response to June 1988 Plant Initial full- Participation Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154K9331988-09-21021 September 1988 Town of Hampton & New England Coalition on Nuclear Pollution Emergency Planning Contentions on 880628-29 Exercise.* Supporting Documentation & Certificate of Svc Encl ML20154N9061988-09-20020 September 1988 Seacoast Anti-Pollution League Contentions on Graded Exercise.* Svc List Encl ML20154D7431988-09-12012 September 1988 New England Coalition on Nuclear Pollution Petition for Review of ALAB-899.* Petition Should Be Granted on Basis That Integrity of RCS Significantly Paramount to Safe Operation of Plant.W/Certificate of Svc ML20151A6461988-07-0707 July 1988 NRC Staff Response to Town of Salisbury Amended Contentions Re Applicant Plan for Commonwealth of Ma Communities.* Applicant Untimely Amends to Contentions Should Be Rejected. Certificate of Svc Encl ML20151A6301988-07-0606 July 1988 NRC Staff Response to City of Haverhill Detailed Contentions.* City of Haverhill late-filed Contentions Should Be Rejected.Certificate of Svc Encl ML20196G7031988-06-27027 June 1988 Applicant Response to City of Haverhill Detailed Contentions.* Contentions Should Be Rejected & City Should Be Denied Admission as Party,Per 10CFR2.714.Supporting Documentation & Certificate of Svc Encl ML20196A3761988-06-22022 June 1988 New England Coalition on Nuclear Pollution (Necnp) Reply to Applicant & NRC Staff Response to Necnp Contentions on Spmc.* Certificate of Svc Encl ML20196A3991988-06-22022 June 1988 Reply of Massachussetts Atty General to Responses of NRC Staff and Applicant to Contentions 7 Through 83 Filed by Massachussetts Atty General.* Certificate of Svc Encl ML20196A5261988-06-22022 June 1988 Town of Amesbury Reply to NRC Staff & Applicant Responses to Town of Amesbury Contentions on Seabrook Plan for Massachussetts Communities.* Certificate of Svc Encl ML20196A8701988-06-20020 June 1988 Reply of Commonwealth of Ma Atty General to Responses of NRC Staff & Applicant to First Six Contentions Filed by Commonwealth of Ma Atty General.* ML20151N6271988-06-17017 June 1988 Town of Salisbury Reply to Applicant Response to Intervenor Contentions on Seabrook Plan for State of Ma Communities ML20151A8361988-06-17017 June 1988 Reply of Town of West Newbury to Responses of Applicant & NRC Staff to Intervenors Contentions Re Seabrook Plan for Commonwealth of Ma Communities.* Certificate of Svc Encl ML20151N6461988-06-17017 June 1988 Town of Salisbury Amended Contentions Re Applicant Plan for State of Ma Communities.Certificate of Svc Encl 1999-07-20
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
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, 412Y catstico April 13, 1988 U9EC UNITED STATES NUCLEAR REGULATORY COMMISSION 3 NT 19 P5 :30 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Croce -
y 00CEi T.y. , j' In the Matter of )
'4-
)
Public Service Company of )
New Hampshire, et al. ) Docket Nos. 50-443 OL
) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY
) PLANNING
)
NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S CONTENTIONS ON THE SEABROOK PLAN FOR THE MASSACHUSETTS COMMUNITIES The New England Coalition on Nuclear Pollution ("NECNP")
submits the following contentions regarding Applicants' Seabrook Plan for the Massachusetts Communities ("SPMC"). These conten-tions invoke the provisions of 10 CFR 5 50.47, as well as the recent amendments to 5 50.47(c) regarding the consideration of utility-sponsored emergency plans. Consistent with the Commis-sion's description of the staged manner in which utility plans are to be litigated, we have divided the contentions into three parts.
The first part of NECNP's contentions addresses the feasibility of emergency planning for the Seabrook Emergency Planning Zone ("EPZ"). In a brief before the First Circuit Court of Appeals, the NRC has stated through its General Counsel that Nothing in the NRC's rule precludes a state or local government from arguing to the NRC that adequate emer-gency planning at a particular site is inherently impossible. However, the law gives the NRC the authority to decide whether that argument is valid in a particular case. If the NRC decides that emergency
, planning at a particular site is not inherently l impossible, then it must go on to decide whether the 8804260124 880413 ,
- PDR G
ADOCK 05000443 PDR 'lt)C.I
-2 -
utility's emergency plan provides reasonable assurance of adequate protection in an accident. i Commonwealth of Massachusetts, et al. v. U.S. Nuclear Reculatory Commission, Nos. 87-2032, 87-2033, 88-1121, Brief for Respondents ,
at 38-39. Thus, the contention raised in Part I must be liti-gated before the Licensing Board may proceed to address the ade-quacy of the SPMC.
When and if the issues raised in Contentelon 1 are resolved P in Applicants' favor, the amendments to the emergency planning [
2 regulations for review of utility-sponsored plans also con-template that as a threshold matter, Applicants must distinguish between those requirements of 5 50.47(b) it is attempting to ful- .
fill, and those requirements for which it seeks "due allowance" because it is unable to meet them and has designed compensatory measures. 10 CFR S 50.47 (c) (1) (iii) . As demonstrated in Part II of NECNP's contentions, Applicants have failed to identify which portions of 5 50.47(b) it is unable to meet or to specifically identify the compensatory measures addressed to those require-ments. Because Applicants have bypassed this essential step, we have no idea for what elements of noncompliance Applicants seek "due allowance" from the Licensing Board. Applicants must meet l this requirement before the parties can litigate the adequacy of compensatory measures in tho SPMC.
l 1
' It is NECNP's position that, consistent with their burden of proof in this proceeding, Applicants should be required to make i
the threshold showing described above before the parties are i
1 .
required to submit contentions on the SPMC. Nevertheless, in Part III of these contentions, NECNP challenges the adequacy of the plan under 5 50.47 (c) (1) . However, without a clear idea of what regulatory provisions are at issue here, we are placed in the position of taking shots in the dark. Our right to a rational and meaningful proceeding is thereby abridged. We therefore request that the Board dispose of the preliminary issues raised in Parts I and II before proceeding to the litiga-tion of contentions regarding the substance of the SPMC.
CONTENTIONS Part I Contention 1 Due to the unique features of the Seabrook Emer-gency Planning Zone ("EPZ"), adequate emergency planning for the Seabrook EPZ is inherently impossible. Therefore Applicants can-not satisfy 10 CFR S 50.47(a).
Basiqi The Massachusetts sector of the EPZ includes resort communities on a barrier beach that is populated by thousands of people during the summer months. These beachgoers include thou-sands of day-trippers as well as summer residents. Because of the limited roadways exiting the beach, evacuation during the summer could take many hours. In fact, Applicants estimate that evacuation times during a rainstorm on a peak summer weekend could take as much as 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Implementing Procedure ("IP")
2.5, Attachment 4. Moreover, sheltering facilities in these resort communities are fundamentally inadequate. First, many
people would have access only to unwinterized buildings, which provide little protection from radiation. The protection afforded by sheltering in these structures would be less than that afforded by a normal wood frame house.1 second, even if adequate shelters were available, they would not be reasonably accessible in an orderly, planned fashion to the thousands of transients who may be unfamiliar with the area and not understand where they should shelter. In addition, the SPMC contains no description of shelters that would be available to the transient population. Thus, in a fast-breaking release, the thousands of people would be unable to leave quickly or find adequate shelter from the radioactive plume.
Part II Contention 2 Applicants have failed to identify those portions of the SPMC for which they invoke the provisions of 10 CFR 5 i 50. 47 (c) (1) .
Basis: The regulations for review of utility-sponsored plans require Applicants to show either that deficiencies result-l ing from nonparticipation by the state and local governments of I
Massachusetts are not significant for Seabrook, that adequate interim compensating actions have been or will be taken promptly, or that there are other compelling reasons to permit Seabrook to i
1 See FEMA Profiled Testimony in hearings on New Hampshire plan, dated September 11, 1987, at global 59-60.
l operate. 10 CFR $ 50.47 (c) (1) . Applicants have apparently
- invoked only the second part of this test, stating that the SPMC is intended to compensate for the lack of State and local govern-ment participation in emergency planning at Seabrook. SPMC at 1.1-1. However, Applicants have failed to identify "those ele-ments" of regulatory compliance "for which state and local non-participation makes compliance infeasible" and the specific measures that are "designed to compensate for any deficiencies resulting from state and/or local nonparticipation." 10 CFR S
- 50. 47 (c) (1) (iii) ( A) , (B) , Moreover, for those elements of 9 50.47(b) with which they do not comply, Applicants must show that the noncompliance "is wholly or substantially the result of the non-participation of state and/or local governments." S I 50.47 (c) (1) (ii) . In short, it is impossible to determine the standard (s) which Applicants seek to fulfill through submission of the SpMC. Absent a specific identification of what portionc of the plan are addressed to what standards, Applicants have not I satisfied the requirements for invoking the provisions of S l 50.47(c),
i Part III Contention 3 Applicants have not met the requirements of 10 CFR E 50.47 (a) (1) to provide a "reasonable assurance that adequate protective measures can and will be taken in the event of a Radiological emergency" at Seabrook because they have failed to show what emergency response measures will be taken by the Massa-
e chusetts state and local governments in the event that Mode 1 of the SPMC is followed.
Basis: Section _50.47 (c) (1) (iii) (B) contains the presump-tions that-a) "state and local government officials will exercise their best efforts to protect the health and safety of the pub-lic", and b) where an applicant's inability to comply with 5 50.47(b) results wholly or partially from the nonparticipation of state and local governments, that in the' event of an actual Radiological emergency state and local officials would "generally follow" the utility plan. The SPMC establishes two alternative
, "modes" for the Massachusetts state and local governments to fol-low. Mode 1, called the "Standby mode," contemplates that Applicants will provide only resources -- i.e. equipment, buses,
, ambulances, personnel, etc. -- to the state and/or local govern -
ments.2 SPMC at 3.1-2. Aside from broadly describing the emer-gency response functions of each state agency, however (SPMC, S
]
- 2.2), the SPMC does not contain any blueprint for state and local
) government agencies to follow in undertaking primary responsibil-i ity for the emergency response. The plan describes emergency response functions for the New Hampshire Offsite Response Organi-zation ("ORO") rather than state or local governments. The means by which the state and local governments are thus presumed to 2 SPMC at 3.1-2. Mode 2, which contemplates that the state will authorize Applicants to carry out all or part of the emer-gency response, is discussed in Contention 4.
7 a
"follow" the SPMC in Mode 1 consists only of using Applicants' resources in carrying out an ad hos response. The mere provision of resources to support an unplanned emergency response does not i adequately compensate for the etate and local governments' lack of preparedness to respond to an accident at Seabrook.
Contention 4 To the extent that Mode 2 of the SPMC contemplates the substitution of Applicants for state and local governments in carrying out an emergency response, it violates the emergency planning rule and Massachusetts state law. Moreover, to the extent that it contemplates integration of the utility's func-tions with state and local emergency response functions, it does not compensate adequately for the lack of preparedness of state and local officials to respond to a Radiological emergency at Seabrock.
Basis: The SPMC contemplates that under "Mode 2,"
Applicants will "assume responsibility on behalf of the State / locals (upon authorization by the State) for implementation of the entire emergency response or integrating specific portions thereof." SPMC at 3.1-2. To the extent that Mode 2 con-templates the substitution of Applicants for state and local gov-ernments in carrying out an emergency response, it violates the emergency planning rule and Massachusetts state law. Mode 2 con-flicts with the basic premise of the amendments to S 50.47(c) (1),
which acknowledges that a utility is without legal authority to exercise the police powers that inhere in state governments.
. ~
Indeed, as the Commonwealth of Massachusetts points out in its Contention 6, Applicants cannot lawfully be authorized to exercise the state's police powers.3 Moreover, to the extert that it contemplates the integration of state / local emergency response functions with those of the ORO, the SPMC is hopelessly cumbersome and confusing. The SPMC does not provide a mechanism by which the state and local govern-ments can swiftly and efficiently interact with ORO officials to mount a timely and adequate response to an accident. This results from the cumbersome communication and coordination prob-lems created by the parallel existence of government and ORO emergency response organizations. Each counterpart of the state and local response organization must take the time-consuming steps of communicating and coordinating its efforts with a counterpart in the ORO organization. For each function, the parties must take the time-consuming steps of agreeing on divi-sions of rer,ponsibilities and all of the accompanying logistics, including communication and sharing of equipment and personnel.
Finally, to the extent that the state and local governments might assume responsibility for an accident response under Mode 2, there are no guidelines in the SPMC that are designed for state and local governments to follow. The Implementing Proce-l 3 Massachussetts' Contention 6 is hereby adopted and incorporated by reference into this contention.
l 1
,e l
dures for the SPMC are addressed to the management of the emer-gency response by the ORO, not state and local governments.
There is simply no plan for the governments to follow. In fact, the only way that the state and local governments could "follow" this plan would be to transfer their authority for managing the emergency response entirely to the ORO. This is not a viable option in light of the state and local governments' responsibil-ity to retain the police power for the protection of their citizens.
Thus, the result of any attempt by Massachusetts governments to "follow" the SPMC would be utter confusion. Given the high population density of the Seabrook EPZ and the relatively long times required to evacuate the area, there is no room for the l
confusion and delay that would arise if state and local govern-f ments attempted to implement the SPMC during a Radiological emer-j gency.
' Respectfully submitted,
\
Diane Curran
! H).RMON & WEISS 2001 "S" Street N.W. Suite 430 l Washington, D.C. 20009 l
i (202) 328-3500 April 13, 1988 l
I certify that on April 13 1988, copies of the foregoing
! pleading were mailed first-clast or as otherwise indicated on the
! parties to the attached service li t.
L Diane Curran
. s :
f h
SEABROOK SERVICE LIST - OFFSITE LICENSING BOARD i "Ivan W. Smith, Chairman Rye, New Hampshire 03870 U.S. NRC (POCH)
U.S. NRC Washington, D.C. 20555 Boston,MA 02109 l Washington, D.C. 20555 Richard E. Sullivan, Mayor !
C'ty Hall Mr. Angie Machiros, Sandra Gavutis ;
"Dr. Jerry Harbour Newbvryport,MA 01950 Chairman RFD 1 Box 1154 i U.S. NRC - Town of Newbury East Kensington, Nil 03827 l Washington, D.C,20555 Alfred V. Sargent, Chairman Town Hall,25 High Road Board of Selectmen Newbury,MA 01951 Charles P. Graham, Esq.
"Gustave Linenberger Town of Salisbury, MA 01950 McKay, Murphy and Graham U.S. NRC H. Joseph Flynn, Esq. 100 Main Street Washington, D.C. 20555 Senator Gordon J Humphrey Office of General Counsel Amesbury,MA 01913 U.S. Senate FEMA Atomic Safety and Licensing Washington, D.C. 20510 500 C Street S.W.
Board Panel (Atta. Tom Burack) Washington, D.C. 2N72 U.S. NRC
- By hand Washington, D.C. 20555 Selectmen of Northampton George Dana Bisbee, Esq.
Northampton, New Harap- Geoffrey M. Huntington, Esq. " By Overnight Mail Atomic Safety and Licensing shire 03826 Office of the Attorney General Appeal Board Panel State House Annex U.S. NRC Senator Gordon J. liumphrey Concord,NH 03301 Washington, D.C. 20555 1 Eagle Square, Ste 507 %
Concord,NH 03301 Allen Lampert %.T
- r.
Docketing and Service Ci il Defense Director
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U.S. NRC Michael Santosuosso, Town of Brentowood M
Washington, D.C. 20$55 Chairman Exeter,NH 03833 $W 4
$ h*:'
Board of Selectmen Mrs. Anne E, Goodman Jewell Street, RFD # 2 Richard A. Hampe, Esq. Yk 3 Board of Selectmen South flampton, NH 03842 Hampe and McNicholas y' y 1315 New Market Road 35 Pleasant Street
~ '
o Durham, Nil 03842 Judith H. Mizner, Esq. Concord, Nil 03301 Silmglate, Gertner, et al.
William S. Lord, Selectman 8' droad Street Gary W,liolmes, Esq.
Town liall- Friend Street Boston,MA 02110 Holmes & Ellis Amesbury,MA 01913 47 Winnacunnent Road i Rep. Roberta C. Pevear Hampton,NH 03S42
! Jane Doughty Drinkwater Road l SAPL Hampton, Falls, NH 03S44 'lliam Armstrong 5 Market Street 3 Defense Director
- Portsmouth,NH 03801 Phillip Ahrens, Esq. 10 Front Street Assistant Attorney General Exeter,NH 03333 j
- Carol S. Sneider, Esquire State House, Station # 6 Assistant Attorney General Augusta,ME N333 Cahin A. Canney 1 Ashburton Place,19th Floor City Manager l
- Boston,MA 02108 "Thomas G. Dignan, Esq. City Hall R.K. Gad II, Esq. 126 Daniel Street l Stanley W. Knowles Ropes & Gray Portsmouth,NH 03801 i Board of Selectmen 225 Franklin Street
! P.O. Box 710 Boston, MA 02110 Matthew T. Brock, Esq.
Northifampton,NH 03826 Shaines & McEachern 1 Robert A. Backus, Esq. P.O. Box 3(4 J.P. Nedeau Backus, Meyer & Solomon Maplewood Ave.
1111owell Street Portsmou'h, NH 03801 Town of R)r 155 Washington Road Manchester,NH 03105 Edward A. Thomas "Sherwin E. Turk, Esq. FEMA Office of General Counsel 442 J.W. McCormack L