Text

Response Suggesting Offsite Emergency Plan Contentions Submitted by Town of Kensington,Per ASLB 860117 Order,Be Excluded.Certificate of Svc Encl
	ML20154G667
Person / Time
Site:	Seabrook
Issue date:	03/05/1986
From:	Gad R; PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:	; Atomic Safety and Licensing Board Panel
References
	CON-#186-320 OL, NUDOCS 8603100070
	Download: ML20154G667 (35)
	v • d • e

N Filcd: Mcrch 5, 1986 DOCKETEP

'Is'n c UNITED STATES OF AMERICA

'86 NAR -6 P3 :35 NUCLEAR REGULATORY COMMISSION OFFRE,,

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00CHEimc,,,rpfga before the BRANLy ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of

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PUBLIC SERVICE COMPANY OF

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Docket Nos. 50-443-OL NEW HAMPSHIRE et al.

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50-444-OL

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l (Seabrook Station,

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(Off-Site EP)

Units 1 and 2)

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l APPLICANTS' RESPONSE TO OFF-SITE EP CONTENTIONS SUBMITTED BY TOWN OF KEN 3INGTON INew Hampshire State and Local Plans]

Introduction Purcuant to this Paard's order of. January 17, 1986, the Applicants tubmit this response to the proposed contentions relating to the New Hampshire state and local offsite emergency plans submitted by Town of Kensington (Kencington).

Before turning to the contention proffered by Kensington, however, we set I

forth some general principles governing the admission l

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f and litigation of contentions relating to offsite emergency planning that we believe may be of assistance to the Board.

General Principles i

The function of emergency planning is to effect, under the circumstances that may be presented, aggregate dose savings to the affected population.

The emergency planning requirements are not intended to impose new performance or siting criteria on nuclear power plants, and they do not require, as a condition of licensure, a demonstration of absolute assurance of perfect safety.

The purpose of emergency planning is to have in place means and methods of coping with emergencies in order to keep offsite effects to as low a level as is reasonably possible given the facilities at hand.

Scuthern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 NRC 528, 533 (1983).

The proposition that emergency plans will be judged for adequacy against a certain type of accident, and in particular one involving a prompt offsite release of i

radioactive effluent, is likewise contrary both to established law and to the fundamental precepts on i

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which emergency planning is based.

The theory upon which the regulations were based is that the planners should consider a spectrum of accidents; the key requirement is that emergency plans be flexible and capable of accomplishing a reduction of adverse effects to the greatest extent reasonably practicable given existing resources.

As the Commission has stated:

"Since a range of accidents with widely differing offsite consequencen can be postulated, the regulation does not depend on the assumption that a particular type of accident may or will occur.

In fact, no specific aiccident sequences should be specified because each accident could have different consequences bcth in nature and degree.

Although the emergency planning basis is independent of specific accident sequences, a number of accident descriptions were considered in development of the Commission's regulations including the core melt accident release categories of the Ractor Safety Study (WASH-1400)."

San Onofre, supra, 17 URC at 533.

A corollary is that there is no requirement that emergency plans either directly focus on anyone's notion of the " worst caso" accident, or that they demonstrate that, in the event of the " worst case," no member of the public will be affected.

"NUREG-0654 does not require an adequate response for the ' worst possible accident' at (a nuclear power plant.)

It provides that the worst possible accident be taken into i

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consideration in the planning basis for the provisions of NUREG-0654."

Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-85-12, 21 NRC 644, 888 (1985).

See also Philadelphia Electric Co.

l (Limerick Generation Station, Units 1 and 2), CLI t 15, 22 13 0 184, 187 (1985) (immediate effectiveness review).

j In short, the standard by which any emergency plan l

is to be judged is whether or not it represents the 1 l 1

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9 best efforts of knowledeable people through the use of reasonably available facilities to reduce to the maximum extent reasonably possible the adverse effects on the public health and safety which will result from offsite releases resulting from a spectrum of accident scenarios.

The guiding principles, as recently summarized by a Licensing Board, are thus:

"The purpose of emergency planning is to achieve dose savings to the, general public in the i

event that radioactive material is accidentally released off site.

There is no minimum standard of public radiation dose which must be met in l

emergency planning.

" Absolute protection of the public against all radiation doses cannot be guaranteed and is not required for all possible accident scenarios.

"The emergency response plan should not be developed for any specific preconceived accident sequence.

It should instead be framed to cope with a spectrum of accident possibilities including the i

worst accidents.

"There is no standard time required to be met for evacuation in a radiological emergency.

Estimates are necessary to determine accurately the actual time required for evacuation.

These estimates are needed to aid in protective action l

decisionmaking.

"No massive investment of resources (stockpiling of supplies or construction of hospitals) are required for emergency planning.

We will apply a practical standard of efficience of utilization of existing resources (such as roadways l

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and manpower) in evaluating the acceptability of the evacuation plan."

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Long Island Lighting Co. (Sh geham Nuclear Power Station, Unit 1), LBP-85e12, 21 NRC 644, 782 (1985).

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e Response to Specific Contentions Kensington has filed 15 contentions with respect to the Kensington local plan, plus an incorporation by 1

1 reference of cer'tain of the proposed contentions I

proffered by SAPL.

Contention 1 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not assure that 'each principal response organization has staff to respond and to augment its initial resopnse on a continuous basis,' as required by 10 C.F.R.

50.47(b)(1), because there I

are not alternates in several of the key emergency response positions and other departments are inadequately staffed to respond to an emergency as outlined in the plan."

The proffered basis offers the follows concerns:

(1) there are no alternates for the positions of Civil Defense Director, fire Chief, and RADEF officer; (ii) there is no designated transportation officer; (iii) the Kensington fire department is volunteer, with members who work out of town; (iv) the Kensington highway agent does not have resources that are town-owned to keep the roadways clear and "the common arrangements for ad hoc assistance by private contractors are insufficient to assure that these s

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responsibilities will be met;" and (v) the Police Chief does not reside in the town.

The,first p,roffered basis-is inadequate to require litigation.

The power to designate alternates resides, at least in the first instance, in the Selectmen of Kensington Certainly the plans cannot be said to be deficient because of something that the Selectmen have the power to cure any time they wish.

The same thing is true of the office of transportation coordinator.

The mere fact that the Kensington fire department is a volunteer organization, without a standing contingent of people stationed at the firehouse, is not a planning deficiency.

Under the Kensington local plan, the fire department has minimal duties in an emergency, the most immediate one of which is receipt and dispatch of notification.

See Kensington local plan at II.9; compare id. at II-30 through -32.

Kensington has already taken provisions to ensure that, despite its minimal fire contingent, emergency dispatches to the fire department do not go unanswered.

"Kensington maintains 24-hour Fire coverage with its red phone system, which can be I

answered at any of five locations throughout the Town.

The Fire Dispatcher or a Fire Department member is k 3

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always either on duty at the Fire Station or on Call nearby one of the red phones."

Kensington local plan, p.

II-4.

In addition, the Fire Chief has mobile and portable two-way radio communications, one of the frequencies of which (154.190 mHz) permits him to communicate directly with Rockingham County Dispatch Center.

See Kensington local plan, p.

C-7.

That same frequency also permits him to communicate directly with other town's EOC's.

See Kensington local plan,

p. C-8.

Finally, other town officials are equipped with radio paging devices, see Kensington local plan, p.

C-7, and

"[slimultaneous direct notification from Rockingham l

i County Dispatch will also be given to the Kensington 1

Selectmen and Civil Defense Director via pocket voice i

pager.

This will serve as a redundant notification path to the town."

Kensington local plan, p.

II-4.

Given these intricate provisions for communications, and the extent to which Kensington's specific situation has been taken into account in the plans, a sic 61e assertion of inadequacy, without more, is insufficient

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to raise a litigable issue.

With respect to the Road Agent, the plans again recognize that Kensington's limited municipal \\

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capability may not be sufficient, by itself, to get the job done.

For the reason, the plan does not place i

ultimate reliance upon the Road Agent:

"Should the Town's highway resources be insufficient, the. Road Agenet may rely on support from the State for j

maintenance of evacuation routes.

A representative of:

the New Hampshire Department of Public Works and Highways will be available at both the IFO/ EOF in Newingten and at the State EOC in Concord.

The highway 4

maintenance eupport available from the State is described in Section 2.6.5 and in Appendix C of the i

NHRERP."

Kensington local plan, p.

II-30.

Given the content of the plan itself, therefore, Kensington's 1

j simple recitation of limited highway resources fails to raise a litigable issue about the capacity to maintain evacuation roadways.

Finally, Kensingttn's unadorned assertion that the i

Police Chief lives out of town does not raise a 4

litigable issue.

There are no traffic control points a

in Kensington, Kensington local plan, p.

11-30, so the i

police department's functions during an emergency will be little different that what they are otherwise.

In addition, the New Hampshire state plan provides for 4

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State Police assistance if required.

NHRERP at pp.

1.3-20& -21.

In sum, therefore, Kensington's proposed Contention 1 lacks basis.,It is supported only by a litany of respects in which Kensington has determined to minimize expense in connection with municipal services generally, no doubt because the town fathers have determined over the years that little more is required to meet the town's needs.

The Kensington plan takes these limited resources into account; Kensington's bare recitation leaves one with no inkling of how the plans e

are supposed to have failed to take its limited resources into account.

The contention therefore fails for lack of the required specificity and basis.

Contention 2 The proposed contention reads as follows:

"The Kensington emergency response plan does net provide for adequate ' notification, by the licensee, of State and local response organizations and for notification of emergency response personnel by organizations ['},

as required by 10 C.F.R. 50.47(b)(5).

Provision for notification of the town emergency response organization is inadequate in that it depends upon notification through the Rockingham County dispatch and does not assure that the contact person will be available or can be reached in the event of a nuclear emergency.

In each instance, there must be direct contact between the site and the town, and there must be a i

dedicated telephone line to a location where an individual will always.be-on duty to receive the communciation and then take action."

j This proposed contention repeats the assertions of inadequacy of Kensington's fire department contained i'n the proffered basis for proposed Contention 1.

In all respects save one, our response to that proposed.

contention deals with tnis one; in particular, proffered basis provides no foundation for the claim i

that a " dedicated telephone line" is required (nor, indeed, does it even explain how a dedicated telephone line would address the asserted problem, which is personnel dispersion -- a problem that is answered by the plan's provisions for redundancy of means of communications (radios and pagers) and people with whom to communicate).

The one respect in which Kensington i

may have a point is that, given this redundancy, training in the communications procedures should not be limited to the Fire Chief, but should extend to the other members of the fire department who might receive the initial notification.

However, this point does not require hearings; having called it to the state's J

attention, the Board may properly assume either that the state will amend the plans or that the Fire Chief

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r himself will, in the ordinary course, see to it that the personnel he assigns to a task know the procedures applicable to the task.

Proposed contention 2, therefore, does hot raise a litigable issue.

Contention 3 The proposed contention reads as follows:

"The December, 1985 draft radiological energency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

because there is no provision for alternative evacuation routes."

This proposed contention should be excluded for two reasons.

First, the proffered regulatory. basis, NUREG-0654 J.lO.a says nothing about alternative evacuation routes being required.

Second, it has been held that alternative routes are not required by the Commission's regulations in any event.

Kansas Gas & Electric Co.

(Wolf Creek Generating Station, Unit 1), LBP-84-26, 20 NRC 53, 65 (1984).

The proposed contention should be excluded.

4..

e Contention 4 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency' response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

because there are no maps showing adequate shelter areas, and some existing structures which are proposed shelters provide inadequate radiological protection."

This proposed contention, which mixes two discrete concepts, should be excluded.

It has been held that the Commission's regulations do not require shelter surveys or maps.

Philadelphia Electric Co. (Limerick' Generating Station, Units 1 and 2), LBP-85-14, 21 NRC 1219, 1303 (1985).

The proffered basis for asserting that the elementary school in inadequate for shelter purposes is itself inadequate, for basements and interior rooms are not required of buildings used for shelter; what is important is the air exchange preclusion ability.

Id.

Finally, even if the school buildings were for some valid reason inadequate, authorization of an operating license could not be conditioned upon the renovation of the school or construction of another one.

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Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 NRC 528, 533 (1983).

Contention 5 The proposed contention reads as follows:

'"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C F.R.

50.47(a)(1),

because principal organinations (State and Local) involved in emergency response for the site have not seen or reviewed the Evacuation Time Estimates within the Plume Exposure Pathway."

For the reasons set forth in response to NECNP proposed contention RERP 9, relitigation of Evacuation Time Estimates is not required in connection with the offsite emergency plans.

The proposed contention, therefore, should be excluded.

Contention 6 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide adequate arrangements for effectively using assistance and resources as required by 10 C.F.R.

50.47(b)(3), because there are not appropriate letters of agreement to identify and support organizations and other facilities which are to provide assistance."

Most of the entities in the list of organizations for which Kensington "is not aware of" letters - -

r agreement are governmental employees or organizations.

Letters of agreement are not required of or contemplated in the case of governmental organizations.

See Philadelphia Electric Co.

(Limerick Generating Station, Units 1 and 2), LBP-85-14, 21 NRC 1219, 1366 r

(1985).

With respect to bus companies, the Etate plan reflects that some letters of agreement have been obtained and that the process is on-going with respect to the balance.

See NERERP, App.

I.

Since Kensington does not set forth what organizations upon which reliance is placed in the Kensington local plans for which it has concern, there is no basis for concluding that a litigable issue with respect to a planning

" obstacle" has been raised.

Finally, nothing in the Commission's regulations or the Staff's guidance j

documents requires or contemplates a letter of i

agreement with the Applicants; that is what the on-site emergency plans are for and the adequacy of those plans l

1s no longer open for litigation.

For lack of basis, therefore, the proposed contention should be excluded.

7 Contention 7 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective actions have been developed for emergency workers and the public, as required by 10 C.F.R.

50.47(b)(10), because there are no provisions for the use of radioprotective drugs or respiratory equipment for emergency workers or other persons within the plume exposure [EPZ)."

This proposed contention should be excluded for two reasons.

First, contrary to Kencington's blanket and unsupported assertion, the New Hampshire emergency plans are not devoid of any discussion regarding radioprotective drugs (KI).

NHRERP $ 2.7.3.

Second, the decision with respect to the deployment of KI is a matter for the state to decide, and is not a matter for litigation in an operating license proceeding.

Union Electric Co. (Callaway Plant, Unit 3), ALAB-754, 18 NRC 1333 (1983); Philadelphia Electric Co. (Limerick Generating Station, Units 1 and 2), LBP-84-18, 19 NRC 1020, 1032 (1984); Louisiana Power & Licht Co.

(Waterford Steam Electric Station, Unit 3), LBP-82-100, 16 NRC 1550, 1567-68 (19S2). -

Contention 8 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

because evacuation time estimates are based on mean peak pupulations as opposed to peak populations."

This proposed contention should be excluded for two independently sufficient reasons.

First, as stated-earlier, ETEs are not open for relitigation.

Second, the proposed contention flies in the face'of the Commission's general guidance that no specific I

scenarios are required to be planned for and that 1

" worst cases" are not the planning model.

The proposed contention should be excluded.

Centention 9 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

i because notifications sirens are set a[t] such a high level they will cause potential damage to the hearing of those closest to them." - -

T The Applicants believe that this proposed contention should be excluded for the following reasons.

Sound levels produced by any source diminish with distance.

Tor this reason, a rating in decibels of something like a siren must always be associated with a distance.

The guidance reference cited by Kensington, NUREG-0654, App.

3,

$ C(3), therefore properly does not specify a siren rating; what it says is that "[t]he maximum sound levels received bv any member of the oublic shou'ld be lower that 123 dB."

Id.

Kensington's proffered basis is inadequate tc show any litigable issue with respect to this standard (and, while the NHRERP does not contain the rating distance for the sirens, taking into account the height of the pole and the distance of the poles from residences, public buildings and the like, it is an improbable conclusion that members of the public would be regularly exposed to the rating sound level as an a priori matter), and the contention should therefore be

excluded, i

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Contention 10 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide for communications with contiguous state / local, governments within the plume exposure pathway EPZ as required by 10 C.F.R.

50.47 App.

E,E.(9)(a), because provisions for communications with the state government are inadequate."

This proposed contention should be excluded.

The Kensington local plans provides for communications capability between the Kensington EOC and Rockingham Dispatch..' enter (as well as other town's EOC's by.two-way radio), over a number of frequencies presently in use for police, fire and Civil Defense purposes.

Kensington's focus on the telephone system (used for initial notification because of its ability to be answered in many locations) is irrelevant; the proffered basis does not contradict the assertion that i

Kensington has these radio communications capabilities.

Moreover, the issue at this stage is the adequacy of the plans; even if some of the radio equipment were yet to be installed, that would not be a basis for concluding that the plans were inadequate.

For lack of basis, therefore, the contention should be excluded.

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h Contention 11 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide.for communications with the Federal emergency response organizations as required by 10 C.F.R.

50.47 App.EiE,(9)(b), because there are no provisions for communications with Federal emergency response organi=ations."

This contention should be excluded for lack of l

regulatory-basis.

Kensington's apparent basis for the assertion that Kensington must have the ability to communicate with federal agencies directly actually provides as follows:

"Where consistent with the function of the governmental agency, these arrangements will include Provision for communications with Federal emergency response organizations."

10 C.F.R.,

Part 50, App.

E, following 9 IV(E)(9).

The New l

Hampshire plans assign Kensington no function that would entail communications between Kensington and federal agencies and, *:herefore, the Commission's regulation requires nc. communications capability of that sort.

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T Contention 12 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

because there is no description of means for registering and monitoring of evacuees at i

relocation centers in host areas."

This contention should be excluded for two reasons.

First, the matters referred to in the proposed contention and its accompanying basis are not matters required to be in the Kensington local plan; Kensington has not been designated a host community for anyone and Kensington has no responsibility for the registration, monitoring or sheltering of evacuees.

Moreover, "[t]he operation of the Reception Centers, and the co-located decentamination centers is a State responsibility."

Kensington local plan, p.

II-32.

Second, the items the lack of which is lamented by Kensington are contained in the proper place, namely the New Hampshire plan for Manchester, the designated host community.

The Manchester local plan addresses each of the topics in question, in more detail than is required for plans (and more than would be litigable under a properly -

drawn contention in any event).

Manchester local plan, pp.

II-12 through -16.

The contention that this information must be " discussed in the Kensington l

[ local) plan," Kensington contentions p.

11, should be l

excluded.

Contention 13 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Seabrook Station, as required by 10 C.F.R.

50.47(a)(1),

because there are inadequate provisions for notifying and locating all segments of the transient and resident populations."

This contention is premised on NUREG-0654, J.lO.c, which requires that plans contain "Im]eans for notifying all segments of the transient and resident population."

The New Hampshire plans call for initial notification of the pcpulation, including transients, via the alert and notification system (principally, the sirens), and thereafter via the Emergency Radio Broadcast System and the public address functions of the sirens.

Activation of both is at the state level (via the Rockingham County Dispatch Center), though for redundancy (and to make the sirens useful for purposes -

unrelated to radiological emergencies) each local town also has activitation capacity with respect to that portion of the alert -and notification system within its borders.

However, "[p]rovision of emergency instructions [is a] State responsibility," not one of the town.

Kensington local plan, p.

II-30.

The proffered basis for this contention simply bears no relationship to the plans.

The plans neither state nor contenplate that "the [ local Kensington]

Civil Defense Director [is to] maintain [] a running log of all transients within the town borders at any given moment."

The plans neither state nor contemplate that "the [ local Kensington] Civil Defense. Director [is to]

'round up' all the transient in the town."

The matter of maintaining information on those residents (not transients) who might require assistance in evacuating has nothing to do with notification.

Given the basis offered in support of it, therefore, this proposed contention should be excluded.

Contention 14 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not provide arrangements for requesting and,

I' effectively using assistance resources regarding the transportation of contaminated victims to medical support facilities as required by 10 C.F.R.

Il 50.47)(b)(3)."

One searches section 50.47(b)(3) in vain for any reference to "the transportation'of contaminated victims to medical support facilities" that is supposedly required thereby.

In its proffered basis for this proposed contention, Kensington quotes the sentence "The contaminated person and his possessions will be sent to a State decontamination facility located at the Receptions Centers," and then complains that inadequate details on how Kensington is to do the transporting.

Kensington omitted any page reference for the quote, but the sentence can be found at Kensington local plan, p.

II-37.

So can the context:

"If the Kensington emergency workers determine that the level of radioactivity on an individual or on surfaces of vehicles, equipment or other possessions exceeds 100 CPM above backgroud levels, State DPHS will be contacted for instructions.

The contaminated person and his possessions will be sent to a State decontamination facility located at the Reception r

Centers."

Id.

Under the Kensington local plan, therefere, the details the omission of which forms the basis for the contention are not required.

The contention thus lacks a factual basis in the plans as well as a regulatory basis in the cited regulation.

It should be excluded.

Contention 15 The proposed contention reads as follows:

"The December, 1985 draft radiological emergency response plan for the Town of Kensington does not contain accurate or adequate emergency equipment to support the emergency response as required by 10 C.F.R. 50.47(b)(8)."

This contention should be excluded for two reasons.

First, insofar as the centention asserts the lack of adequate equipment for communicating instructions to the public, that is not under the New Hampshire plans a function that has been made a local responsbility.

Second, while the contention begins (as it must) with an assertien that the plans are deficient, it changes in mid-sentence into an accusation that the equipment described in the plans is not in place.

The latter is not a litigable challenge to the plans.

If Kensington is actually (despite the wording of the contention's basis) challenging the adequacy of ' hat has been w.

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planned for, the contention fails for lack of specificity.

Neither it nor the basis affords even an inkling of what equipment is inadequate or what equipment should be added to achieve adequacy.

As proffered, there is nothing to litigate and the contention should therefore be excluded.

Re,spedeft Mns,ubmitted,

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$ ~..! D C rr,;)

Thomas G. Dignan, Jr.

R. K.

Gad III Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:

423-6100 D.ated :

March 5, 1986,

1 CERTIFICATE OF SERVICE 000 METED

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USNRC f

I, Thomas G.

Dignan, Jr.,

one of the attorneys gr the Applicants herein, hereby certify that on MarchW, NNi-6 P3 :35 1986, I made service of the within " Applicants' Response to Off-Site EP Contentions Submitted by T pg g i j p,',E['.

of Kensington (New Hampshire State and Local Plans tsmg depositing copies thereof with Federal Express, SRANCtf prepaid, for delivery to (or, where indicated, by depositing in the United States mail., first class postage paid, addressed to):

Helen Hoyt, Chairperson Ms. Diana P.

Randall Atomic Safety and Licensing 70 Collins Street Board Panel Seabrook, NH 03874 U.S.

Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Emmeth A.

Luebke Diane Curran, Esquire Atomic Safety and Licensing Harmon & Weiss Board Fanel 2001 S Street, N.W.

U.S. Nuclear Regulatory Suite 430 Commission Washington, D.C. 20009 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Dr. Jerry Harbeur Stephen'E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory Assistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814

Atomic Safety and Licensing Sherwin E. Turk, Esquire Board Panel Office of the Executive Legal U.S. Nuclear Regulatory Director Commission 7735'Old Georgetown Road Washington, DC 20555 Bethesda, MD 20814,

i i

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Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel 116 Lowell Street U.S. Nuclear Regulatory P.O.

Box 516 Commission-Manchester, NH 03105 Washington, DC 20555 Philip Ahrens,' Esquire Mr. J.P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Central Road General Rye, NH 03870 Augtsta, ME 04333 Paul McEachern, Esquire JoAnn Shotwell, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O.

Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Designated Representative of City Manager the Town of Kensington City Hall RFD 1 126 Daniel Street East Kingston, NH 03627 Portsmouth, NH 03801

Senator Gordon J.

Humphrey Mr. Angie Machires U.S.

Senate Chairman of the Washington, DC 20510 Board of Selectmen (Attn:

Tom Burack)

Town of Newbury Newbury, MA 01950

Senator Gordon J. Humphrey Mr. Peter J. Matthews 1 Pillsbury Street Mayor-Concord, NH 03301 City Hall (Attn:

Herb Boynton)

Newburyport, MA 01950 Mr. Donald E.

Chick Mr. William S.

Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 -

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H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road i

Federal Emergency Management Bren

'ood, NH 03833 Agency 500 C Street,'S.W.

Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 Mr. Ed Thomas FEMA, Region I John W. McCormack Post Cffice and Court House Post Office Square Boston, MA 02109

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