ML20154S251
| ML20154S251 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/30/1988 |
| From: | Brock M AMESBURY, MA, SHAINES & MCEACHERN |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#488-7197 OL, NUDOCS 8810050025 | |
| Download: ML20154S251 (18) | |
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Tj{p UNITED STATES OF AMERICA
'3 f) ;f 7 l NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
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September 30, 19E3
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In the Matter of ) Docket Hos. 50-443-OL-5 0- 4 4 4 -0L' -
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PUBLIC SERVICE COMPANY OF )
HEW HAMPSHIRE, et al.
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Off-site Emergency Planning Issues
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(Seabrook Station, )
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Units 1 and 2 )
TOWN OF AMESBURY RESPONSE To APPLICANTS' MOTION TO COMPEL ANSWERS TO INTERROGATORIES AND PRODUCTION OF DOCUMENTS BY AMESBURY, e HAVERHILL. AND MERRIMAC (TOA) and hereby responds to NOW COMES the Town of Amesbury APPLICANTS' MOTION TO COMP *L ANSWERS TO INTERRO HAVERHILL, AND MERRIMAC (hereinafter OF DOCUMENTS BY AMESBURY, "Motion') dated September 26, 1968 as follows:
RACFGRQED On its face, Applicants Motion purports to be a reasonable effort This is questionable. The to resolve a discovery dispute with TOA.
f generic interrogatories were answers provided by TOA to Applicants' which, in Intervenor Towns virtually identical to those of other discovery requests as substance, uniformly objected to Applicants'
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f vague, overly broad, or otherwise improper.1 Perhaps realizing the discovery disputes with Intervenors could best be resolved informally, in a Applicants' counsel contacted other Intervenor towns to request, more limited and specific manner, the discovery that Applicants seek.
and may obviate, or at Apparently those negotiations are ongoing, i least substantially limit, the need for the Board to referee any ,
discovery disp'ui.e with these Towns.2 By contrast, Applicants' counsel never approached TOA in an effort to c1'arify its discovery needs, and instead served TOA with a 23 page motion to compel.3 By appearance, therefore, Ap.licants seek to target TOA, traditionally the nost activist Massachus.tts tow.1 in j
1 f Sig TOWN OF NEWBURY'S (TON) ANSWERS TO APPLICANTS' FIRST SET OF INTERROGATORIES REGARDING THE CONTENTIONS ON THE SPMC dated FIRSTSeptember SET OF 14, 1988; TOWN OF WEST NEWBURY'S ANSWERS TO APPLICANTS' INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL PARTIES AND PARTICIPATING 10 CAL GOVERNMENTS MGARDING CONT THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES dated September 19, 1988; CITY OF NEWBURYPORT'S ANSWERS TO APPLICANTS' FIRST SET OF INTERROG ATORI*:S AND REQUEST FOR PRODUCTION OF DOCUMENTS dated l September 20, 1988. Sig also, MASSACHUSETTS ATTORNEY GENERAL JAMES M. !
SHANNON'S ANSWERS AND RESPONSES TO THE APPLICANTS' FIRST SE INTERROGATORIES AND FIRST REQUEST FOR DOCUMENTS dated Septerber 23, j 1988.
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See Towns identified in Note 1, #31pn .
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,3 v I TOA was unaware of these overtures by Applicants to other !
l Intervenor towns until af ter the subject Motion directed at TOA ;
was filed.
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i this litigation, thereby compelling TOA to expend limited resources j responding to Applicants' unwieldy motion.4 f f
At best, Applicants use of the discovery process is both uneven and premature.5 6 MRITs ;
In their Motion, Appliennts labor through 23 pages of l explanation, for 5 interrogatories, in an effort to provide content and specificity, lacking from Applicants' original discovery request. )
As Jrafted, many of Applicants' i That effort comes too late.
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interrogatorics are so vague and overly broad as to preclude any t
meaningful answer, a viek shared by virtually all Intervet.or counsel.6 Applicants cannot raw res2rrect a deficient discovery request through f f
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Although other Intervenor towns joined in the substance of T0A's l answers, Haverhill and Merrimac apparently are named in Applicants' l Motion since those municipalities adopted the form, au well as i substance, of ToA's responses to Appi,1 cants' discovery requests. [
5 Following receipt of the Motion, TOA initiated contact with f Applicants' counsel, which has resulted in agreement on certain t previously disputed issues. Thone agreements are noted, where applicable, in this response.
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Een Note 1, sunra, ,
3 war. u e arc % - m w. u. . w u . c.,
J their "clarification" in the present Motion.7
. XMTERROGATORY 28
- 2. Please identify and produce all documents, and describe ,
in detail all conversations or not refer otherwise reflected in such to what actions any l
i documents, which reflect ;
Massachusetts state or local government entity or official would, [
could, might, would not, could not, or might not take in the event of an actual radiological emergency at Seabrook Station. T ANSWER: +
i This Interrogatory is objected to on grounds of attorney-j client privilege and work product. This interrogatory is further objected to on grounds that it is so overly broad and vague as to be incomprehensible. Whatever actions a ToA of ficial "might not :
- take in the event of an actual radiological emergency at Seabrook !
Station" cnuld include a decision to pohtpone a luncheen engagement, obviously the interrogatory is defective for ,
inquiring into wholly irrelevant matters. Without waiving any of !
j the foregoing objections, to the extent this interrogatory (
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- presents an attempt to determine the response of TCA officials to an emergency at Seabrook Station, ToA has already identifleSeed numerous impediments to a planned and organized response. l 4 TOA Contentions 2, 3, and 4, with bases. Among other issuno, (
l these contentions assert that the response by ToA officials to ar. j j emergency at Seabrook would be ad hoc, and would rely upon !
' whatever personnel or other resources happen to beFor available at example, I
the particular day and time the emergency occurs.
since each of the five members of the Town of Amesbury Board of I Selectm9n hold full time jobs unrelated to their duties as (
! elected town of f teiais, and most are required to travel out of i town on some regular basis, it is likely that many, if not all, j Selectmen would not be available to provide leadership during an i emergency. In addition, as referenced in ToA contention 4(B), on
- weekdays during the summer, the ToA Police Department typically [
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- Altnough unstated in its, original request, however, /.pplicants I j have indicated their willingness to forego inspection at cheir offleen !
l of any oriainsi documents, and are contsnt to receive copies by mail. !
Motion, p. 5 and N.5. This understanding nas beca agreed to with ,
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Applicants' counsel. Accordingly. TOA will provide Applicants with t j copies of any requested, and not objectionable, d t.cu me nt s . The '
1 production of documents issue is resolved. SAq, Motion, pp. 3-5.
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police officers on duty. In an actual police chief has emergency, only approximataly 7these of ficers would be directed by thed iroat appropr to take whatever actionsinadequrhe de , " ^<ources of the Department to given the limited and The. c u '.iaa could include tra fi'i .:
meet a Seabrook emergency. :- this interrogatory is so management, security, crwholly rescue. fai nature,
.o specify the vague, however, and "emergency" at Seabrook scope, or extent of the partict necessarily TOA cannot Station contemplated by the quencion, respond more specifically to thin question.
inform the In its objection, Applicants, for the first time, parties and this Board of six contentions filed by TOA and other formed the basis for the discovery Intervenors which apparently Motion, pp. 7-8.
' requests set forth in Interrogatory 2.
Assuming the context and intent of Interrogatory 2 was to seek further, specific information on these six contentions, Applicants request.8 As obviously should have so stated in the original for any actions drafted, however, the bald demand in Interrogatory 2 could, might, would not, corld not that a government official "would, q
or might not take" in an caergancy is, as originally asserted by TOA, 8 or Most of those "Intervenor Contentions" were not The authored, two remaining JI22, 44A, 61 and contributed to, by TOA. Applicants, JI2/ and 62, in vbich TOA 65.
contentions cited by participated, at Seabrook bottom asseirt emergency that thewill response be ad hoc, of TOA and there government will be officials to a since "there 4
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substantial delays and impediments to a planned response, JI62. This answer, is simply no plan for the governments to follow". Applicants in TOA's
! in substance, has already been provided to l, original answur.
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"so overly broad and vague as to be incomprehensible."
Interrogatory 2, to the Even as clarified by Applicants' Motion, That answer provides extenc possible, has been fully answered by TOA.
Seabrook Station will be "ad that TOA's response to an emergency at hoc, and would rely upon whatever personnel or other resources happen "
to be available at the particular day and time the emergency occurs .
and no ,
As answered, plainly TOA has no hidden plan, no hidden agenda, further information responsive to the question.10 IETERROGATORY 33 and describe 3.
'Please identify and produce all documents, in detail allwhich documents, conversations reflect, refer not to, orotherwise relate in any reflected way to any in cuch action by any Massachusetts state or local government official or entity to block, hinder or delay the licensing of Seabrook Station.
9 Applicants correctly note that TOA cited as further objection Given the the attorney-client privilege and work product.
unreasonably broad sweep of Applicants' Interrogatories, request te however, peruse t
' which could be fairly construed those as including objectionua were neces,ary to I
the files of TOA counsel, l
' t protect the Town.
10 .anod insistence f TOA therefore findr mystifying Applicant .e Towns and l to uncover some TOA p) "to determine who ,
'ld make to a radiological emergency at
- p. 8. As stated, there is none.
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other officials wouldMot or Seabrook Station".
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- i ANSWER:
to on grounds it is vague, This interrogatory is objectedeven if more properly drafted, argumentative, and,
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overly broad, seek communications and documents not subject appears to or work to discovery by reason of the attorney-client privilege actions with the TOA has never undertaken any hinder or delay the licensing product. fundamental goal merely to "block, At all times governing officials of TOA a.'. necessary to of have Seabrook Station".taken whatever actions deemed appropriate The intimation protect the health andthat- safety of TOA's motives their citizens. or methods have been in the interrogatory purely obstructionist is highly objectionable.
TOA's answer to Interrogatory Even as "clariflet" by Applicants, As framed, the question seeks to 3 is both complete and accurate.
hinder or delay the licensing identify any actions by TOA to "block, has responded, in substance, there are .
of Seabrook Station" and TOA More fundamentally, however, TOA reasserts that Interrogatory 3 y none. The is both argumentative and impugns the motives of TOA officials.
question does not merit further answer. C.F.R.
interpretation of 10 Applicants' efforts to strain an 3, is for Interrogatory as belated justification 5 50. 47 (c) ,
unsupportable.
The pejorative language of Interrogatory 3 is simply outside the scope of the cited Regul.ation, which focuses upon "the l -or local governments not to particip?te further decision of State t' in emergency planning." 10 C.F.R. 550.47(c). If Applicants intend by however improperly, to TOA's vote not to this Interrogatory to refer, i.
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participate in seabrook planning, that vote is already a ratter of record, and the question thereby answered.11 INTERROGATORY 4:
Please identify and produce all documents generated 4.
after January 1, 1980 that reflect or refer to any emergency conducted or planning (otner than that engaged in by Applicants) centemplated for the Massachusetts EPZ or any portion thereof, including but not limited to emergency planning required pursuant to the Emergency Planning Act. Such documents should include, but not be limited to, documente that reflect or refer to wheth3r the SPMC or any other plan for dealing with a radiological emergency at Seabrook Station has or has not been, or will or will not be, used in planning for emergency situations other than those involving Seabrook Station-ANSWER:
This interrogatory is objectionable to the extent it seeks to invade the attorney-client privilegefor or ToA to obtain or TOA work product officials for prepared by or on behalf of counselTOA further objects to this interrogatory purposes of litigation.
on grounds that, to the best of TOA's knowledge and belief, Applicants are already in possession of all planning documents for the Snabrook EPZ, and further that Applicants "engaged in", or were involved with, generating these documents prior toities decisions that by the Commonwealth and Massachusetts EPZ com' 4 .iA is not in emergency planning for Seabrook is not feasible.
possession of any planning documents, TOAwithin the scope acknowledges, of the however, request, generated since that date.
to the extent required under the Emergency its responsibilitiesalthough Planning Act, no such planning document has been approved by the Town.
11 Applicants for this Interrogatory, As furthera contencion "clarification" TOA did not author, for the proposition cite to MAG 2, that "Applicants' per force need evidence of the state and local activities and obstacles rolevant to all, the admitted contentions".
Motion, p. 12. To the extent it can be discerned, theResponse information re:
provided. See TOA I requested has already been Interrogatory 2, supra.
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am s va acrem ~ m e.. a m e n.
The dispute concerning '
oyC ory has been resolved tordingly, TOA identifies by counsel for Applicants a.
Amesbury, comere aceraency Manaaement Plaa the following:
(6/13/85).12 I)[TERROGATORY 5 3
- 5. Please list every admitted SPMC contention which you do not intend to participate in litigating, i.e., concerning which you will not take discovery, present evidence, make arguments, conduct cross-examination, or submit proposed findings.
ANSWER:
As Applicants should be aware, this interrogatory is Presently, the Commonwealth, EPZ Towns in premature.
Massachusetts, and Applicants, are engaged in streamlining and consolidating the numerous admitted contentions for submission as "joint intervenor" contentions. As of the dateIdentification of these answers, of that process has not been completed.
contentions that TOA may choose to litigate is wholly premature and speculative. In addition, any responses Applicants may make to TOA discovery requests may impact on TOA's decision whether to proceed with ferther litigation of particular contentions.
In filing its annwers to Applicants' interrogatories on september 14, TOA declined to answer Interrogatory 5 on grounds it was process of consol). dating Joint Intervenor premature, as the contentions had not yet been completed. Supra. By their motion, Applicants challenge as "questionable" the truth of this assertion.
Motion, p. 16, Note 17. Applicants are in error.
12 A copy of this documurit has been served upon Applicants and the NRC staff. Upon request, TOA will make available additional copies.
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l Although Applicants claim that the "final changes" in the process of consolidating Intervenor contentions occurred on September 13, Id.,
it is a matter of record that the scope and interpretation of Joint Intervenor contentions was still in dispute as of September 19, as referenced by the Staff in its letter to the Board of that date.
Exhibit 1 attached.13 .
Since, however, that consolidation process has now been completed .
4 TOA is prepared to hereby supplement its prior answer to Interrogatory 5 as follows:
Presently, TOA does not intend to conduct discovery, present evidence, make arguments, conduct cross examination, or submit proposed findings except as to the following contentions: JI2, 4, 14, 23, 24, 27, 50, 55, 58, 60 and 62.
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l 13 As stated in that letter, which included a STIPULATION AS TO CONTENTIONS, Applicants and Intervenors still disagreed as to the scope of the redrafted contentions, and the effect of the bases originally submitted and admitted by the Board. TOA has been advised that these issues were not finally resolved until on or ;
abou September 27. ,
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As with its answers to other interrogatories, TOA shall supplement this interrogatory if and when circumstances new facts are discovered, or issues raised, change, and/or TOA determines it is necessary to further exercise its rights afforded under 10 C.F.R. 52.715(c) to pro,tect the interests of the Town.14 INTERROGATORY 68
- 6. For every admitted SPMC contention that you submitted and do not hereby withdraw, and for every other admitted SPMC contention that you did not list in response to Interrogatory 5 above, individually for each such contention, please:
- a. State in detail all the facts underlying each assertion contained in the contention;
- b. State the source of each such fact. If the source is identify the the personal knowledge of one or more persons, person (s). If the source is one or more documents, identify and produce the document (s) ;
- c. Identify any expert witness who is to testify concerning the contention, and state the substance of the facts, opinions, and grounds for opinions to which the expert is expected to testify; a
- d. Identify any non-expert witness who is to testify concerning-the contention, and state the substance of the facts to which the witness is expected to testify; and I
r 14 Although TOA has not confirmed Applicants' agreement witn this Answer in all respects, TOA believes it has now fully responded to Interrogatory 5.
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- e. Identify and produce any documents which reflect or refer to any type of study, calculation or analysis bearing upon the substance of the contentions.
ANSWER:
- a. See Answer to Interrogatory 5. By way of further objection, this interrogatory is objected to as vague and unduly ToA asserts that "the facts underlying each burdensome.
assertion contained in the contention" are stated with reasonable specificity in the basis for each contention proffered by ToA.
Absent a reasonably specific request by Applicants for particular information, ToA objects to Applicants' fishing expedition for "all the facts" which may possibly pertain to any particular contention.
- b. See answer to Interrogatory 5 and 6a.
- c. See answer to Interrogatory 5 and 6a. By way of further answer, TOA has not yet identified any experts who will testify on behalf of ToA.
- d. See answer to Interrogatory 5 and 6a. By way of further answer, this interrogatory is objected to as outside the scope of permissible discovery, as premature, and as constituting a fishing expedition intended to intrude into the litigation strategies, and mental impressions of ToA counsel and officials.
- e. See answers to Interrogatories 5, 6a, and 6d. By way of further objection, this interrogatory, which seeks any document "bearing upon" a contention, is so broad and vague as to be incomprehensible.
Applicants argue generally that TOA should provide additional
- "facts," to support ToA's contentions, beyond those already provided in the bases to contentions. Whatever additional "facts" Applicants j
seek, however, are never disclosed. Indeed, although expounding for l more than four pages on Interrogatory 6, Applicants' generic objection does not even discuss a single specific contention, save one, for which it claims additional "facts" should be provided. Even that t
I single Joint Intetvanor Contention, JISO, is cited only for the limited proposition that not all special needs facilities have been i
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identified. This issue, however, was never raised by TOA, e S_e_q, TOA Contention 4 (D) (2) , incorporated into JISO, and Applicants' concerns should be directed elsewhere.
Applicants also make passing reference, without citation, that TOA claitas there is inadequate equipment and personnel to follow the SPMC. While TOA agrees with this propusition, it remains mystified as ,
to how a further "factual explanation of the inadequacy," beyond that contained in bases, may be provided. If Applicants want specific information, Applicants should pose a specific, and coherent, '--'
question.15 With reference to Applicants' requert to identify TOA's non-expert witnesses, and the substance of their testimony, as TOA previously stated, this interrogatory is "premature", as TOA has not made this determination. Once obtained, however, TOA will provide Applicants with this ir.~ormation.
15 Applicants' error in logic appears grounded upon its inability to accept, as Intervenors have, that no amount of energency equipment and personnel can alter the fundamental fact that emergency planning for Seabrook cannot reasonably protect the health and safety of EPZ citizens. This position was cogently stated by FEMA in its September, 1987 testimony profiled in this :a s e , which TOA adopts, and to which Applicants should refore if addi.i.onal explanation is desired. TOA t therefore cannot identify any mis.ing "facts" that will somehow solve or compensate for the inadequacy of the emergency plans.
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With reference to Applicants' request for "any documents ...
bearing upon the substance of the contention", TOA reasserts that such a request is simply too broad to warrant a meaningful response. Nowhere in Applicants' original interrogatary, or in the Motion, is there reference to any specific contention filed, or issue raised, by TOA, nor are any reasonable bounds placed upon the scope of the request. The request is overbroad, ill-defined, and objectionable.
For reasons stated, to thT extent issues remain in dispute, TOA respectfully requests that Applicants' motion be DENIED.
Respectfully submitted, TOWN OF AMESBURY By Its Attorneys, SHAINES & McEACHERN Professional Association DATED: September 30, 1988 By: ) ( _,
Matthew T. Brock 1
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8 'n NUCLEAR 3EGULATORY COMMISSION fg, . i usmoToN, D. C. 20555
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SEP 191988 !
SEP 22 EG
=Ivan W.' Smith Esq. . ' C hairman Gustave A. Linenberger, Jr. .s.
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. N uclear R eg ulatory Commission Washington, DC 20555 Washington, DC 20655
~ - Dr. Jerry Harbour
- Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D C 20555 In the Matter of PUBLIC SERVICE COMPANY OF NEW HAMPSh ui, ET AL.
(Seabrook Station, Units 1 and 2)
Docket Nos. 50-443, 50-444 Off-Site Emergency Plarining
Dear Administrative Law Judges:
In the course of the August 3 and 4,1988 prehearing conference counsel for the NRC Staff offered to coordinate the editing, grouping and consolidation of the SPMC contentions admitted by the Licensing Board. To that end representatives of the Applicants, Intervenors and NRC Staff have conferred and produced the attached "Stipulation as to Contentions" which, with the exception of JI7 and JI8, represents a consolidation and clarification of the contentions admitted by the Board in its July 22, 1988 and August 19, 1988 Memoranda and Orders.
For ease of litigation the contentions were divided into eight issue groups and renumbered. The etymology of each contention is enclosed in the brackets which follow the new contention number. Although the bases of the admitted contentions were deleted in order to condense the final document, the Staff's and Applicant's agreement to this stipulation is grounded on their understanding that the contentions remain limited to the bases originally submitted and admitted by the Board. The Joint Intervenors do not intend that their agreement to this stipulation limits the evidence add'r:ed in support of the contentions.
Yours truly, s . _
Elaine I. Chan Counsel for NRC Staff Attachment as stated Serv;ce list m 1 BIT 1 cc w/ attachment:
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C_ERTIFICATE OF SERVICE I
'88 OCI -3 P3 :11 l I, Matthew T. Brock, one of the attorneys for the Town of Amesbury herein, hereby certify that on Septembgr.c 3 0, 1988, I made service of the foregoing document, TOWN OF XMES BURY '.RES PONS E TO APPLICANTS' MOTION TO COMPEL ANSWERS TO INTERROGATORIt54AND PRODUCTION OF DOCUMENTS BY AMESBURY, HAVERHILL, AND MERRIMAC and TOWN OF AMESBURY FIRST SUPPLEMENT TO APPLICANTS' FIRST SET OF INTERROGATORIES AND FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO ALL PARTIES AND PARTICIPATING LOCAL GOVERNMENTS REGARDING CONTENTIONS ON THE SEhBROOK PLAN FOR MASSACHUSETTS COMMUNITIES, by depositing copies thereof in the United States Mail, first class postage prepaid for delivery (or, where indicated, by Express Mail, prepaid) addressed to:
- Ivan Smith, Esq., Chairman *Dr. Jerry Harbour Atomic Safety & Licensing Board Atomic Safety & Licensing Board (Off-Site) (Off-site)
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm.
East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814
- Judge Gustave A. Linenberger, Jr.
- Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board Panel (Off-Site) U.S. Nuclear Regulatory Comm.
U.S. Nuclear Regulatory Commission Washington, DC 20555 East West Towers Building 4350 East West Highway
- Thomas Dignan, Esq.
Bethesda, MD 20814 George H. Lewald, Esq.
Kathryn A. Sollock, Esq.
- Adjudicatory File Ropes & Gray Atomic Safety & Licensing Board 225 Frankin Street Panel Docket (2 copies) Boston, MA 02110 U.S. Nuclear Regulatory Commission East West Towers Building
- Carol S. Sneider, Esq.
4350 East West Highway Stephen H. Oleskey, Esq.
l Bethesda, MD 20814 Allan R. Pierce, Esq.
Department of the Atty. General
- Stephen E. Merrill, Esq. One Ashburton Place George Dana Bisbee, Esq. Boston, MA 02108 office of the Attorney General State House Annex
- Diane Curran, Esq.
Concord, NH 03301 Andrea C. Forster, Esq.
Harmon & Weiss 2001 S Street, N.W., Suite 430 Washington, DC 20009-1125
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- Sherwin E. Turk, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission
- Richard R. Donovan 15th Floor - One White Flint North Federal Emergency Mgmt. Agency 11555 Rockville Pike Federal Regional Center Rockville, MD 20852 130 228th Street, S.W.
Bothell, Washington 98021-9796 Philip Ahrens, Esq. Robert A. Backus, Esq.
Assistant Attorney General Backus, Meyer & Solomon Office of the Attorney General 111 Lowell Street State House, Station 6 Manchester, NH 03105 Augusta, ME 04333 Jane Dough;y Richard A. Hampe, Esq.
Seacoast Anti-Pollution League Hampe and McNicholas 5 Market Street 35 Pleasant Street Portsmouth, NH 03801 Concord, NH 03301 William S. Lord, Chairman Charles P. Graham, Esq.
Board of Selectman Murphy & Graham Town of Amesbury 33 Low Street Town Hall, Friend Street Newburyport, MA 01950 Amesbury, MA 01913 R. Scott Hill-Whilton H. Joseph Flynn, Esq.
Lagoulis, Clark, Hill-Whilton Office of General Counsel
& McGuire Federal Emergency Mgmt. Agency 79 State Street 500 C Street, S.W.
Newburyport, MA 01950 Washington, DC 20472 Ashod N. Amirian, Erquire Judith H. Mizner, Esq.
376 Main Street 79 State Street Haverhill, MA 01830 2nd Floor Newburyport, MA 01950 Senator Gordon J. Humphrey Senator Gordon J. Humphrey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton) 2
Leon- "*nelman, Esquire
- Robert R. Pierce, Esq.
Bet ';aint Andre, Enquire Atomic Safety & Licensing Board Kop. Paige, P.C. Panel 77 Fi .n Street U.S. Nuclear Regulatory Comm.
Bostor .;A 02110 East West Towers Building 4350 East West Highway Bethesda, MD 20814 e>
bMatthew Ws.
T. Brock
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