ML20153E954

Contentions Opposing Nov 1985 Radiological Emergency Response Plan for Hampton,Nh.Plan Not Prepared by Town of Hampton & Fails to Provide Reasonable Assurance That Plan Implementable Per 10CFR50.47

ML20153E954
Person / Time
Site:	Seabrook
Issue date:	02/21/1986
From:	Brock M HAMPTON, NH, SHAINES & MCEACHERN
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20153E957	List: ML20153E954 ML20153E971
References
CON-#186-180 OL, NUDOCS 8602250213
Download: ML20153E954 (14)

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DOCKETED Filed: February 21,195gNRC UNITED STATES OF AMERICA ggggy NUCLEAR REGULATORY COMMISSION gFFICE OCMEii .. if-!I V before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al Docket Nos. 50-443-OL 50-444-OL (Seabrook Station, Units 1 and 2)

CONTENTIONS OF THE TOWN OF HAMPTON TO RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR THE TOWN OF HAMPTON, NEW HAMPSHIRE, NOVEMBER, 1985 INTRODUCTION On January 17, 1986 this Board issued a Memorandum and Order which established a deadline of February 24, 1986 for filing contentions against the New Hampshire Radiological Emergency Response Plan (RERP), and against RERP for local governments filed with the State plan. The following Contentions are submitted on behalf of the Town of Hampton in opposition to the Town of Hampton RERP that was prepared and submitted by the State to FEMA.

Based on the Contentions set forth herein, the Hampton RERP violates FEMA regulations and State law. The Town of Hampton RERP further fails to provide reasonable assurance that the plan is adequate or can be implemented in the event of radiological emer-gency. 10 CRF, Section 50.47.

CONTENTION I The State of New Hampshire violated FEMA regulations by denying the Town of Hampton the opportunity to prepare its own Radiological Emergency Response Plan (RERP), by failing to engage in integrated emergency planning with affected local units of government, and by failing to address substantial safety concerns raised by town officials on the inadequacy of the Hampton RERP prepared by the State. NUREG - 0654/PEMA - REP - 1, Rev. 1, Dqu2 19 - 24 (hereinafter NUREG).

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O i . BASIS: While ignoring substantial emergency planning

. concerns raised by Hampton officials, the State of New Hampshire

prepared and submitted to FEMA a local. Radiological' Emergency i Response Plan (RERP) for the. Town of Hampton. The State thereby i violated FEMA regulations by infringing upon the jurisdiction of

! the Town of Hampton to promulgate =its own RERP and by denying l Hampton officials any meaningful input into the Town emergency plan. 'NUREG, cas. 19 - 24; see also 44 CFR, Section 350.5 incor-l Doratina NUREG into FEMA reaulations.

l NUREG provides:

Contianous - Jurisdiction Government Emeroency Plannina i The conceot of Emeroency Plannina Zones (EPis)

, necessarily imolies mutually suonortive emer-cency plannina and orecaredness arranaements by several levels of covernment: federal, state and local covernments, including counties, townships and even villages. .

.There are obvious permutations and combin-J ations of these situations but these are i examples of what is desirable in terms of cross-jurisdictional emergency planning. The imoortant ooint is that intearated emeroency i olannina will benefit all of the communities i within the Emergency Planning Zones. NUREG, oa. 19.

l By its terms, NUREG contemplates " multi-jurisdictional" i

planning, NUREG, ca. 20, which confers upon each governmental _ unit j final responsibility for promulgating'its own RERP.

$ The purpose of multi-jurisdictional emergency planning is j clear. Local officials are uniquely qualified to assess -

personnel, capabilities, road and traffic hazards,-and population i fluctuations which may significantly impact upon local emergency

planning. Additionally

Local government plans and response mechanisms ,

i are particularly important for the ten mile

EPZ. This is because relatively shorter times i

may be available to implement immediate pro-

tective measures associated with the plume i exposure pathway (sheltering, thyroid blocking, j evacuation), as opposed.to the generally longer

• l times available for implementing protective j measures for the ingestion exposure pathway.

4 State covernment resources may be too far away I from the involved local iurisdictions to be of f much immediate belo for a olume exoosure oroblem in the eariv hours of an accident.

NUREG, cas. 20 - 21.

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Since the Town of Hampton is located within the 10 mile EPZ ,

the Town will necessarily be required to implement and direct immediate protective measures in the event of emergency, relying exclusively on local personnel, until such time as state assist-ance can be provided. NUREG, oo. 20.

Given the substantial responsibilities placed upon Hampton officials to respond to radiological emergency, and the FEMA mandate for multi-jurisdictional planning, the Town must be permitted to prepare its own RERP to address significant local safety concerns.

Even assuming that " multi-jurisdictional" planning does not prohibit the State from imposing an RERP on local governments, at a minimum the State was required to provide the Town with meanino-ful input into its own RERP. In preparing the Hampton RERP, however, the State failed to address or remedy any of the numerous safety concerns raised by Hampton officials to the State by letter of October 29, 1985, see attached, and unilaterally terminated discussions with the Town on these issues.

The State thereby violated the integrated emergency planning between State and local governments required by FEMA. The Town of Hampton must therefore be afforded a reasonable opportunity to prepare its own RERP. Until this opportunity is provided, the Town of Hampton declines to participate in any RERP exercise since the local emergency plan, at present, cannot be implemented in the event of radiological emergency. The Town will not give tacit approval to the Hampton RERP, in which it was denied meaningful input, by participating in the RERP exercise.

CONTENTION II The State of New Hampshire violated State law by denying the Town of Hampton the right to prepare and submit its own RERP to FEMA and by denying the Town any substantial input into the Hampton RERP prepared by the State. New Hamoshire Revised Statutes Annotated, 107 - B (1) .

BASIS: New Hampshire law provides:

Nuclear Emergency Response Plan I. The Civil Defense Agency shall, 1D cooperation with affected local units of covernment, initiate and carry out a 3

nuclear emergency response plan as speci-fled in the licensing regulations of each nuclear electrical generating plant.

NH RSA 107-B:1.

By its terms, 107-B:1 requires a cooperative effort between state and local governments in the. preparation of a local RERP. The State's unilateral termination of. emergency planning discussions with local officials, however, plainly indicates that the State has abandoned its statutory obligation to cooperate with Hampton officials in the preparation of a local RERP in favor of the State's rush to present a Hampton RERP to FEMA. By failing to cooperate with local officials to-resolve substantial safety concerns raised by the town, and by denying the town meaningful input into the Hampton RERP, there-fore, the State violated New Hampshire law.

CONTENTION III The Evacuation Time Study for the Hampton RERP is based upon faulty assumptions and inaccurate factual data and thereby fails to provide reasonable asurance that adequate protective actions can be implemented, or that adequate facilities and equipment will be provided, in the event of radiological emer-gency. 10 CFR, Section 50.47f8), (10).

BASIS: The following contentions regarding the Evacu-ation Time Study (EOS), Appendix E, of the Hampton RERP ~are based upon the ETS prepared by Costello, Lomasney and Ihe Napoli, Inc. in association with C.E. Maguire, Inc., March 1984 (hereinafter the Maguire Report). By motion filed with these Contentions, the' Town of'Hampton has requested additional time to respond to any updated or amended ETS that may subse-quently be submitted by the State to FEMA.

The Maguire Report is based on the following inaccurate, unreasonable, or misleading assumptions:

1. The Maguire Report purportedly bases its population estimates, among other factors, upon data received from local chambers of commerce. Ha.auire Reoort III -~9. Allegedly based upon this information, the Maguire Report-concludes that summer weekend transients within the Town of Hampton number 78,040, page III - 13, a resident population excluding non-auto owning individuals of 10,837, page.III - 6, and an employee population of 2,845. Page III - 24. The total of these populations estimated in the Maguire Report, however, represent less than 4

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l 40 percent of the peak summer population within the Town of I Hampton as calculated by the Hampton Chamber of Commerce. See j French Affidavit attached. The Maguire Report's reliance upon

!- unreasonably low population estimates thereby raises sub-

! stantial doubts on whether the personnel, equipment, and evacu-  ;

{ ~ ation times contained in the report are reliable and whether an j evacuation is in fact feasible utilizing this unrealistic data.

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2. The Maguire Report assumes that beach visitors will 4 be evacuated at a rate of 5.5 individuals per vehicle. Page 1 III - 11. Even under normal conditions, it is wholly unreason-

! able to assume that this person to vehicle ratio is accurate. 1 l It can reasonably be assumed that a call for evacuation would

precipitate panic and that many family members could be widely_

{ separated at the. time the evacuation notice is given. Accord-j ingly, it must be assumed that either substantially more i

vehicles will be required to evacuate the tens of thousands of beach visitors at Hampton Beach or, if additional evacuation i vehicles are unavailable, these beach visitors would simply be

} without any reasonable means to evacuate the EPZ.

3. The Maguire Report provides for a " clear time esti-i mate" of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 50 minutes within which to evacuate the '

entire 10 mile EPZ on a summer weekend under normal weather

{ conditions. Page V - 6. Alternatively, the report hypo-thesizes a clear time estimate of 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> 40 minutes to evacu-l ate the EPZ on a summer weekend during rain or fog. None of the clear time estimates, including those cited above, make any

provision for " unexpected events" or " unusual conditions." i j Page V - 7. As an example of an " unexpected event," the report i refers to a " vehicle breakdown on a busy evacuation-route."

! Page V - 7. In time of mass evacuation, however, it can only

be assumed that numerous vehicle breakdowns, stalled cars, gas

shortages, and related events will prove to be the norm. The j Maguire evacuation time estimates must therefore be dismissed out of hand as wholly unrealistic and unreasonable.

j 4. The Maguire Report states that.such special events as i

Fourth of July will have no effect on the clear time necessary I to fully-evacuate the EPZ. Page V - 7. The Hampton Chamber of i . Commerce, however, has advised-that the Fourth of July may

, increase the Town of Hampton population by as many as'100,000

individuals. See Affidavit attached. On its face, the Maguire Report's statement that an additional 100,000 individuals would '.

i have no measureable impact on clear time estimates.is wholly j unreasonable and it must be assumed that this. substantial A

population increase would only further strain available local j resources to respond to an emergency.

. 5. The Maguire Report unreasonably calculates clear time j estimates on the assumption that " generally, traffic rules and' a

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4 controls will be obeyed." Page II - 13. Even under normal summer driving conditions within the Town of Hampton, however, it is common for individuals to drive in the breakdown lane on Route 51, the major evacuation route leading from Hampton Beach and to otherwise routinely violate local traffic laws in an effort to negotiate normal peak traffic. In the event of mass evacuation, where panic by at least significant portions of the driving public must be anticipated, it can only be assumed that individuals evacuating in private vehicles would routinely'and repeatedly violate local traffic laws in an effort to flee the EPZ.

6. The Maguire Report unreasonably assumes that "all major roads will be open and capable of carrying their full capacity." Page II - 13. The report therefore unreasonably fails to account for accident, vehicle breakdown, gas shortage, or population panic.

7. The Maguire Report asuumes that certain major evacu-ation routes from the Town of Hampton, including Routes 51, lA, and most of Route 1, will be converted so that all travel lanes will lead away from the EPZ. Page IV - 11, 12. In the event this scenario is carriea out during an evacuation, however, the report fails to account for how State representatives, other emergency personnel, and evacuation vehicles located outside the EPZ will be able to enter the evacuation area to perform their responsibilities mandated by the Hampton RERP.

8. The Maguire Report recognizes that more than one-half (467) of the total of 979 buses needed to fully evacuate the EPZ are located more than 20 miles from Seabrook Station. Page IV - 25. For reasons set forth above, it is unreasonable to assume that these numerous evacuation vehicles could promptly, if ever, reach the evacuation site in view of the mass of private vehicles exiting from the EPZ in time of evacuation.

If, as recommended by the Maguire Report, travel lanes within the EPZ shall be converted to lead away from the evacuation area, this would only further impede support personnel and evacuation vehicles from reaching the EPZ.

CONTENTION IV The Hampton RERP fails to provide adequate emergency equipment to support an evacuation in the-event of radiological emergency. 10 CFR, Section 50.47(8). l BASIS: NUREG requires that each local RERP include written agreements with any organization serving an emergency response role within the emergency planning zone.

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j 32f3). The State has entered into three agreements with trans-portation companies to provide buses and. vans to the Town of i Hampton in the event of evacuation. -See attached. Under these I agreements, the Town of Hampton will be provided with only

] sixty-seven buses and two vans for an evacuation emergency. To

evacuate the~ anticipated populations from' schools, other special facilities, and the non-auto owning residents of the

, town, however, the Hampton RERP requires a minimum of seventy-l four buses, twelve vans, and twenty-three EMS vehicles. RERP, c pas. II-28,29. On its face, therefore, and even using State projections, the evacuation transportation allocated to Hampton is plainly inadequate to meet town needs.

Additionally,.while the RERP makes provision for providing

transportation to non-auto owning residents of Hampton, the l

' plan does nel provide for any transportation for vacationers, transients, or other non-resident individuals who may lack 1 their own transportation in'the event of emergency. 'In view of j the substantial number of tourists and transients coming to 4

Hampton during the summer months, it is only reasonable to assume that a-significant number of additional public trans- ,

portation vehicles will be required in the event of evacuation.

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) Finally, although three agreements for bus and van trans-portation for Hampton have been executed, only'the Berry Trans-d portation Company of North Hampton is located in reasonable proximity to the Town of Hampton in the event evacuation is The Jan-Car Leasing Corporatibn'of Nashua, and the

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1 Timberland Transportation Company of Salem, are located in the j south central portion of the state, thirty-five and forty miles respectively from the Town of Hampton. Since under the RERP, individuals evacuated from Hampton will be taken to Nashua, RERP, ca. II-17, the buses attempting to reach Hampton for-evacuation purposes will be required to maneuver through'evacu-ation traffic leaving Hampton. The likelihood of substantial delay, if not impossibility, of evacuation vehicles reaching

-! Hampton therefore raises significant questions on the feasi-

{ bility of the evacuation transportation provided to the town under its RERP.-. The Hampton RERP therefore fails to provide reasonable assurance of control of access to evacuated' areas and fails to consider the potential impediments <of evacuation traffic in promptly providing evacuation vehicles to the town.

NUREG, ca. 63, Protective ResDonse.

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! CONTENTION V l'

The Hampton RERP fails to provide reasonable assurance that evacuation procedures appropriate to the locale can be implemented in the event of radiological emergency.. 10 CFR, 1 Section 50.47(10).

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l' BASIS: The present road system available to Hampton residents and transients is wholly inadequate to implement an evacuation in the event of radiological ~ emergency. As Town

Selectmen advised the State by letter of October 29, 1985, 3

" Nuclear plant owners and regulators have known-for over 6 years that evacuation plans would be necessary; during that time no serious work has been done on Seacoast roads nor do

! there seem to be plans to improve these roads significantly."

To date, the Town has received no response whatsoever from the j State concerning these substantial emergency planning

concerns.

l Many of the evacuation routes prescribed in the Hampton t RERP are narrow, two-lane roads which may easily be blocked by

] accident or vehicle breakdown. Hamoton RERD II - 31. Route

51, which is the main access road from Route 95 to Hampton i Beach, could reasonably be expected to become impassable either 4

by the tens of thousands of beachgoers attempting to evacuate

the town or by emergency personnel attempting to reach traffic j control points. Route 51 also suffers from a serious bottle-j neck at the Tide Mill Bridge.

1 j The Hampton RERP further fails to give consideration to i the fact that Route 1, during the summer months, is frequently I comparable to a parking lot even under normal driving con-i ditions. The State, however, in preparing the Hampton RERP, i has elected the ignore these substantial safety concerns by Town officials.

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I The Hampton RERP provides for evacuation to the reception j center located in Nashua, New Hampshire. .RERP II - 17. The

. Hampton RERP therefore fails to account for the' fact that wind i

direction or other adverse weather conditions could direct the plume exposure pathway directly towards the evacuation center.

f It is only reasonable that the plan provide for alternative

! evacuation centers under'this scenario to insure adequate i

safety protection to the public. Under the Hampton RERP, no

! alternative reception centers or evacuation sites'are

! provided.

CONTENTION VI i

l The Hampton RERP fails to demonstrate that local personnel- .

I are available to respond and to augment their. initial response on a continuous basis in the event of radiological emergency.

I 10 CFR, Section 50.47 (b) (1) .

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BASIS:

(A) Population estimates. In establishing adequate levels of local personnel to respond in the event of a radio-logical emergency, the Hampton RERP relies upon a_" peak season-able population" of 110,000 for the Town of Hampton. This l population estimate is purportedly "the maximum population

! which may be expected in the Hampton area at any time during

, the peak summer months," Hamnton RERP, ca. I-ll, and was "

I computed utilizing second hand information prepared by non-i local sources. The Hampton RERP thereby violates FEMA reg-

ulations since " estimates of transient population shall be

) developed using lpcal data such as " peak tourist volumes." t

NUREG, Anoendix 4 - 3.

i By letter of October 29, 1985, the Town of Hampton I specifically advised the State that the Hampton RERP peak

! population estimate of 110,000 was substantially below traffic-

! counts and local business figures. As set forth on the f attached Affidavit of Glen French, President of the Town of j Hampton Chamber of Commerce, the local Chamber of Commerce i routinely relies upon population estimates of between 150,000 l l to 200,000 people per day for the Town of~Hampton during the >

suramer season. As many as 250,000 people can be expected

{ within the town on each day over the Fourth of July weekend.

The State therefore relies upon a peak population estimate

! less than one-half of actual figures, as determined by local j officials uniquely qualified to make these computations based 1

upon parking, both legal and illegal, business receipts, and

{ seasonal shifts in the demand for municipal services. At a j minimum, NUREG, Appendix 4 - 3 requires the State to fully 4

explore with local officials the basis-for the disparity in

State and local population figures. The State, however, termin-ated all discussion on this issue.

i Necessarily, the State's reliance upon unreasonably low population estimates raises substantial questions on the ade-quacy of local personnel allocated to the Town under the RERP to respond to a radiological emergency.

(B) Police Departments. The Hampton RERP provides that a

total of 80 police officers and personnel will be available to

, respond to a radiological emergency. Hamnton RERP, Apoendix C-i I

1 These figures are misleading and fail to account for the fact that 50 of the 80 police personnel are "special officers" i hired by the department on a part time or seasonal basis.

l These special officers' therefore lack'the experience, skill,

and training necessary to promptly implement adequate protect-ive responses in the event of radiological emergency.

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(C) Department of Public Works. The Hampton RERP provides that a total of 60 personnel are available from the Hampton Public Works Department to implement protective responses in the event of radiological emergency. Hamoton RERP, Appendix C-3. These figures are misleading. Of the 60 department personnel, 24 of these individuals constitute

" temporary" employees, who, by reason of inadequate tra'.ning and experience, cannot reasonably be expected to promptly and appropriately implement necessary evacuation procedures.

Similarly, an additional 19 members of the Public Works Depart-ment are routinely employed in waste water treatment and sewer maintenance. Accordingly, these individuals cannot reasonably be expected to implement the traffic control, evacuation trans-portation, or maintenance of evacuation routes which represent the primary responsibilities of the Hampton Public Works Department in the event of evacuation. Hampton RERP, IV 1E.

The remaining department personnel consist of the director and 16 highway personnel upon which would fall primary respons-ibility for initiating and implementing protective responses in the early stages of a radiological emergency. See NUREG, oo.

20. These duties include:

1. Responsibility for evacuation of all individuals without automobiles, families without the use of their vehicle, and people with special transportation needs. NUREG, Accendix IV - 27(7). Plainly the limited staff of 17 in the Public Works Department who are familiar with highway and trans-portation problems are wholly inadequate to insure the trans-portation of the thousands of individuals who may be located on the beach at the time evacuation is implemented, even assuming this was the sole function to be performed by the department in the event of radiological emergency. The additional and sub-stantial duties of the department to canvas the town and direct evacuation of special needs individuals, families, vacationers, and other non-auto owning individuals, merely underscores the gross inadequacy of local public works personnel to meet their responsibilities under the RERP. 10 CFR, Section 50.47(b)(1).

2. Under the Hampton RERP, the Public Works Department is responsible for ensuring that "all evacuation routes are serviceable throughout the course of an evacuation." Hamoton RERP II - 31. Clearly the available Public Works Department personnel are inadequate even to carry out this single function mandated by the Hampton RERP.

More significantly, the Hampton RERP unreasonably assumes that maintaining accessibility of evacuation routes will "entall normal adverse weather route maintenance only." RERP, oo. II - 31. The RERP therefore unreasonably fails to account 10

for accidents, breakdowns, driver disobedience, panic, and gas shortages which must be reasonably anticipated in the event of mass evacuation. The Hampton RERP therefore fails to provide reasonable assurance that the town has adequate staff to carry out its evacuation responsibilities, NUREG, ca. 31, Assianment of Responsibility, and the RERP relies upon an unreasonable and unrealistic model in determining staff capability to implement the plan. NUREG, oc. 61. Protective Response.

(D) Selectmen. The Board of Selectmen for the Town of Hampton are provided ultimate authority to direct radiological emergency operations for the Town. Hampton RERP I - 16. The RERP ignores the fact, however, that Selectmen are only part-time officials who may have full-time jobs even outside the Town of Hampton. It is reasonable to assume that at least certain members of the Board of Selectmen would be unavailable to promptly respond, implement, and direct an appropriate protective response. Additionally the Hampton Selectmen are annually elected which may thereby seriously compromise effective RERP education and training for newly elected officials.

CONTENTION VII Hampton RERP exercises are inadequate to permit a reason-able evaluation ~of major portions of the Town of Hampton's emergency response capabilities. 10 CFR, Section 50.47(14).

BASIS: Given the substantial deficiencies, as set forth above, in the Hampton RERP, and the State's failure to address the town's specific concerns over RERP inadequacies, the Town of Hampton officials have advised the State that the town will not participate in the RERP exercise currently scheduled for February 26, 1986. The Town of Hampton therefore declines to give tacit approval to a local plan in which they were denied meaningful participation and input.

Prior to approval of state or local RERP, PEMA regulations require that state and local government emergency personnel participate in a RERP exercise "in sufficient numbers to verify the capability to respond to the actions reauired by the accident scenario." 44 CFR, Section 350.2Mir 350.9. Since no local Hampton officials will be participating in scheduled exercise, the State exercise will not provide any reasonable assurance that the plan in fact can be implemented in time of emergency and, absent local participation, FEMA should decline to approve the RERP for the Town of Hampton.

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e Even assuming that, for purposes of the exercise, the State utilizes State personnel to carry out local functions established by the RERP, in the event of actual emergency those State officials will likely be far removed from the site of the accident and unable to immediately implement reasonable protective measures. As presently designed, therefore, the RERP exercise cannot show personnel capability for implementing the RERP in time of crisis.

CONTENTION VIII The Hampton RERP fails to provide for adequate emergency facilities to support an emergency response. 10 CFR, Section 50.47(8).

BASIS: In preparing the Hampton RERP, the State relies upon a " shelter-in-place" concept as a " valuable protective action" (in) that it can be implemented quickly, usually in a matter of minutes." RERP, cas. II-25, 26. The Hampton RERP acknowledges, however, that " sheltering may agt be considered as a protective action on Hampton Beach during the summer."

RERP, oc. II-RS. The plan thereby fails to provide reasonable assurance that adequate and immediate protection measures will be available to the thousands of beachgoers in the event of emergency. Under its RERP, therefore, the Town is required to rely upon evacuation as the sole means of avoiding radiological exposure to large segmento of the population. Since a " major portion" of radioactive material may be released within one hour of the initiating event, NUREG, oc. 17, and present estimates indicate evacuation could take up to seven and one-half hours, RERP, II-32, RERP measures for evacuation are a wholly inadequate protective response to meet an emergency.

SHAINES & McEACHERN

-h By Matthew T. Brock Attorney for the Town of Hampton, NH 12

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CERTIFICATE OF SERVICE NkC I, Matthew T. Brock, one of the attorneys for the Aglgants herein, hereby certify that on the 21st of February,198W Ittade N1 :36 service of the within document by mailing copies thereof, postage prepaid, to: LFF CE F OXMG. ., .

Administrative Judge Helen Hoyt Administrtive Judge Sheldon.. -

Chairperson J. Wolfe, Chairman Atomic Safety and Licensing Atomic Safety and Licensing o Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Dr. Jerry Harbour Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Philip Ahrens, Esquire Thomas J. Dignan, J r. ,

Assistant Attorney General Esquire, R.K. Gad, III, Department of Attorney General Esquire, Ropes & Gray State House Station 6 225 Franklin Street Augusta, ME 04333 Boston, MA 02110 Jo Ann Shotwell, Esquire Robert G. Perlis, Esquire Assistant Attorney General Office of the Executive Legal Department of the Attorney Director General U.S. Nuclear Regulatory One Ashburton Place, 19th Floor Commission Boston, MA 02108 Washington, DC 20555 Ms. Diana P. Randall Robert A. Backus, Esq.

70 Collins Street 116 Lowell Street Seabrook, NH 03874 P.O. Box 516 Manchester, NH 03105 Diane Curran, Esquire Anne Verge, Chairperson Harmon & Weiss Board of Selectmen 1725 I Street, N.W. Town Hall Suite 506 South Hampton, NH 03827 Washington, DC 20006

i Ms. Roberta C. Pevear Mr. Patrick J. McKeon The Town of Hampton Falls Selectmen's Office Drinkwater Road 10 Central Road Hampton Falls, NH Rye, NH 03870 Mrs. Sandra Gavutis Mr. Calvin A. Canney The Town of Kensington City Manager RFD 1 City Hall East Kingston, NH 03827 125 Daniel Street Portsmouth, NH 03801 Senator Gordon J. Humphrey Mr. Angie Machiros U.S. Senate Chairman of the Board of Washington, DC 20510 Selectmen (Attn: Tom Burack) Town of Newbury Newbury, MA 01950 Senator Gordon J. Humphrey Mr. Richard E. Sullivan U.S. Senate Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas Powers Town Manager's Office Town Manager Town Hall Town of Exeter Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn Brentwood Board of Selectmen Assistant General Counsel RFD Dalton Road Office of General Counsel Brentwood, llH 03833 Federal Emergency Management Agency Gary W. Holmes, Esquire 500 C Street, S.W. Holmes & Ella Washington, DC 20472 47 Winnacunnet Road Hampton, NH 03841 Richard A. Hampe, Esquire Stephen E. Merrill, Esquire Hampe & McNicholas Attorney General 35 Pleasant Street Office of the Attorney Concord, NH 03301 General 25 Capitol Street George Dana Bisbee Concord, NH 03301-6397 Assistant Attorney General Office of the Attorney General 5 Capitol Street Concord, NH 03301-6397 1

\%xT.3d Matthew T. Brock ,

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