ML20196J038
| ML20196J038 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/03/1988 |
| From: | Shoemaker E, Sherwin Turk NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#188-5798 OL, NUDOCS 8803140135 | |
| Download: ML20196J038 (19) | |
Text
679f i'
3/3/88 e.
000XETED
'J5NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- 88 mR 10 P4 :02 BEFORE THE ATOMIC SAFETY AND LICENSING BCffBg. 0{S{rgly BRANCH In the Matter of
)
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NE% HAMPSHIRE, et g.
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Off-site Emergency Planning
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(Seabrook Station, Units 1 and 2)
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NRC STAFF'S RESPONSE TO THE MASSACHUSETTS ATTORNEY GENERAL'S MOTION TO LIFT TEMPORARY PROTECTIVE OR_ DER On February 17, 1988, the Licensing Board entered a temporary protective order, permitting the parties to gain access to certain information contained in the Applicants' offsite emergency plan for Massachusetts, which information the App!! cants had filed under a request for ' confidential treatment. O On February 19, 1988, the Massachusetts Attorney General ("Mass AG") filed a motion seeking to lift the temporary protective order and to compel public disclosure of all information redacted from the utility plan -- including information which had not previously been provided to the Staff or FEMA. U For the reasons set
-1/
"Memorandum and Order (Revising Schedule and Approving Protective Order)", dated February 17, 1988.
-2/
"Motion of Attorney General James M.
Shannon To Lift Temporary Protective Order and To Compel Disclosure of All Those Portions of the Seabrook Plan for Massachusetts Communities Which Have Yet To Be Disclosed To the Intervenors" ("Motion"), dated February 19, 1988.
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forth below, the Staff opposes the Mass AG's Motion and recommends that.
It be denied.
l.
INTRODUCTION On September 18, 1987, the Applicants in this proceeding filed before the Commission the "Seabrook Plan for Massachusetts Communities"
("S PM C"), representing the Applicants' offsite emergency preparedness plan for portions of the emergency planning zone ("EPZ") lying within the Commonwealth of Massachusetts.
In doing so, the Applicants deleted certain information from the copies of the SPMC they filed, asserting that the deletions were made "to assure that there will not be any unwarranted invasion of personal privacy of individuals and organizations needed to implement the Plan and certain members of the general public." 3_/ Copies of this redacted version of the plan were transmitted simultaneously to the parties and Licensing Board.
On November 25, 1987, the Commission issued a decision which, inter alla, required the Applicants to provide to the NRC Staff and FEMA "any of the deleted information that [they] deem necessary for detailed full power review of the [SPMC]," as a condition of low power operation b A list of the information required by FEMA and the Staff for full power review o' the SPMC was provided to the Applicants in December 1987:
this information included the names and addresses of individuals, comoanies and organizations who had contracted to provide facilities or
-3/
Letter from George S.
Thomas (PSNH) to NRC Document Control Desk, dated September 18, 1987,
-14 /
Pub!!c Service Co. of New Hampshire (Seabrook
- Station, Units 1
and 2),
C Li-87 13, 26 NRC slip op, at 6 (Nov. 25, 1987).
services in the event of an emergency at Seabrook. 5_/
This information was provided to the Staff on December 30, 1987, along with an affidavit requesting that the information be withheld from public disclosure pursuant to 10 C.F.R. 9 2.790; b on February 5, 1988, the Staff granted the Applicants' request for confidentiality on the grounds that it contained proprietary commercial information. U On several occasions during hearings before the Licensing B oa rd,
attorneys for the Massachusetts Attorney General ("Mass AC") requested that the Applicants be reauired to provide them with copies of the redacted information, which the Applicants agreed to do subject to a protective order Qee,e.g., Tr. 8398-8425, 8987-9004); on February 10, 1988, the Mass AG acquiesced to this suggestion on a temporary basis (Tr. 9724-29).
On February 17, 19P8, the Licensing Board entered its te..porary protective order, "intended to provide access to the information
-5/
See Letter from Victor Nerses (NRC) to Robert J. Harrison (PSNH),
dated December 23, 1987.
-6/
Letter from Ted C.
Felgenbaum (NHY) to NRC Document Control Desk, dated December 30, 1987.
-7/
Letter from Victor Nerses (NRC) to Robert J.
Harrison (PSNH),
dated February 5,1988.
While the Staff had the Applicants' reouest for confidential treatment under review, the Staf f received a request for release of the redacted information, pursuant to the Freedom of Information Act (FOIA), 5 U.S.C.
9 552.
On February 10, 1988, Staff Counsel informed the Board and parties in this proceeding that the Staff had determined to deny the FOIA request on grounds of economic impact (Tr. 9719, 9752); the request was subsequently denied on February 25,1988 (see Attachment 1 hereto).
until the Board can rule finaliy on whether any protective order should issue."
On February 19, 1988, the Mass AG filed the instant Motion. 8,/
11.
DISCUSSION Pursuant to 10 C.F.R. 6 '2.740(c), the Licensing Board is authorized to enter a protective order, upon a showing of good cause, "to protect a party or person from annoyance, embarassment, oppression, or undue burden or expense, including.
that the discovery may be had only on specified terms and conditions, that certain matters not be Inquired into, or that the scope of discovery be limited to certain matters [,... or) that, subject to the provisions of 56 2.744 and 2.790, a trade secret or other confidential research, development, or commercial information not be disclosed or be disclosed only in a designated way." II Although the Licensing Board's current order arose in a context different than discovery -- prior to the filing of contentions or the commencement
-8/
An opposition to the Motion was filed by the Applicants on February 25, 1988; see "Applicants' Reply to Memorandum of Attorney General of the Commonwealth of Massachusetts Regarding Unrestricted Publication of Information Redacted from the Seabrook Plan for Massachusetts Communities".
9/
10 C.F.R. 66 2.744 and 2.790 apply to requests for the production of documents directed to the NRC Staff, and incorporate the standards for release of information pursuant to the Freedom of information Act (FOl A), 5 U.S.C. 6 552.
While no such request is pending before the Licensing Board, the rules governing exemptions from disclosure recited in 10 C.F.R. 6 2.790(a) may be referred to by the Board in determinirg whether the information at issue here warrants confidential treatment.
In particular, 66 2.790(a)(4) and (a)(6) provide an exemption for disclosure of "[t]rade secrets and commercial or financial information obtained from a person and privileged or confidential", and "[%rsonnel and medical files and similar files, the disclosure of which would constitute a clearly unwarranted invasion of persona _l,p@'acy" (emphasis added).
P of discovery -- the Boa rd's authority to enter such an order is not subje,ct to serious dispute, narticularly since it was entered in the interest of providing the intervenors with immediate access to the redacted information and thus avoiding delay in the filing of contentions and litigation related to the adequacy of the SPMC. EI The standards governing the entry of a protective order to prevent the unwarranted disclosure of proprietary information were addressed by the A ppea ' Board in Kansas Gas and Electric Co. (Wolf Creek Nuclear Generating Station, Unit No. 1 ), A LA B-327, 3 NRC 408, 416-17 (1976),
a f f'd, 4 AEC 409 (1970).
There, the Appeal Board adopted a four-part analysis, requiring the proponent of a protective crder to demonstrate (1) that the information is of a type customarily held in confidence by its originator, (2) that the information has in fact been kept confidential by its originator, (3) that the information is not available from public sources, and 4) that there is a rational basis for customarily holding the information confidential. U The Appeal Board recognized that there is a strong public interest in conducting an adjudicatory proceeding which is as open as possible to full public scrutiny, which interest "most assuredly v.ould be disserved were a licensing board... to place a veil of secrecy over some aspect of a licensing proceeding in the absence of a concrete
~ _ _ _ _ _.
10/ See generally, 10 C.F.R. 5 2.718 (the presiding officer "has the duty to conduct a fair and impartial hearing according to law, to take appropriate action to avoid delay, and to maintain order," and "has all powers necessary towards those ends, including the powers to.
[r]egulate the course of the hearing and the conduct of the participants)".
H/ Accord, Virginia Electric and Power Co. (North Anna Nuclear Power Statio6, Units 1 and Y), ALAB-555,10 NRC 23, 27 (1979).
1
i l
indication that it was necessary to do so to avoid significant harm to a competing, equally cognizable interest."
Wolf Creek, supra, 3 NRC at 417. b The Appeal Board then remanded the issue to the Lidensing Boa rd, noting that if the appilcant could demonstrate a "rational basisd for treating its information as confidential, the interim protective order was to remain in e ffect, "unless the Board further finds there to be countervalling considerations militating in favor of public disclosure which clearly outweigh the potential harm which might inure from such disclosure."
Id., 3 NRC at 3:8.
An app!! cation of these principles to the present case indicates that the protective order should be remain in effect.
As indicated above, the information redacted from the SPMC consists primarily of the names and addresses of persons, companies and organizations who have contracted to provide services and/or facilities to the Applicants in the event of an emergency at Seabrook.
included in this information are the narres of companies and individuals who have entered into letters of agreement; the names of host facilities; the names and inventories of road crew companies; the names of bus, ambulance, snow removal, and wheelchair van con panies; the names of cong regate care centers, host school j
facilities and other special facliities; the identity of a hospital; the locations of certain offsite response facilities; the location of agricultural
-12/
in this regard, the Appeal Board compared to C.F.R. I 2.740(c)(6)
(concerning protective orders for proprietary information) with its "judicial counterpart", Rule 26 (c)(7), Fed. R. Civ. P.
The Appeal Board noted that the latter rule requires "a showing that the public disclosure of the allegedly confidential commercial information would
' work a clearly defined and very serious injury to the l'usiness' of the applicant for the protective order."
Id., 3 NRC at 417 n.13.
producers in the ingestion pathway EPZ: and a bus priority dispatch for West Newberry. b This information was assembled by the Applicants in the course of their efforts to develop a utility plan for the Massachusetts portion of the EPZ in accordance with 10 C.F.R. 6 50.47(c), after the Commonwealth of Massachusetts had determined that it vlould no longer participate in emergency plar.ning for Seabrook.
The identities and addresses of contractors and subcontractors have been recognized to be the type of information that quallfles for treatment as confidential proprietary information upon request by the owner of the information.
See, eg, BDM Corp.
v.
Small Business Administration, 2 GDS T 81,189, 81,495 (D.D.C.1981).
Where proprietary information is protected from disclosure, such confidential treatment is usually afforded in order to avoid injury to a private party's competitive position.
National Parks & Conservation Ass'n v. Morton, 498 F.2d 765 (D.C. Cir.
1974).
Even where no competitive position is at risk, however, such information can be protected from public disclosure as confidential where such disciosure could result in substantial economic harm to the in for-mation's owner.
See generally, 9 to 5 Organization for Women Offic_e Workers v. B_oard of Governors of the Federal Reserv,e System, 721 F.2d 1 (1st Cir.1983).
The potential loss of contracts -- which required considerable time and money to negotiate and bring to closure -- is an identifiable private
-13/ It is unclear whether the Applicants are seeking to protect the confidentiality of the last three items of information ilsted in the text above, or whether those items had simply not yet been developed at the time the SPMC was submitted for NRC and FEMA review.
interest subject to protection under the holding of 9 to 5.
Further, the Applicants' assertion that they could be harmed by public disclosure of the subject information meets the criteria for non-disclosure set forth in Wolf Creek.
With respect to the first of the Wolf Creek criteria, information concerning the identitles and addresses of persons contracting to provide services, equipment and facilities in the event of an emergency is normally disclosed in emergency response plans developed and submitted for review by a governmental entity that participates in emergency preparedness planning. UI Only in Seabrook and one other proceeding (involving the Shoreham plant), however, has a "utility plan" has been proffered for review.
Although information of this type was disclosed in that plan, it cannot be said that any "customary practice" has yet developed with respect to the disclosure of such information in utility plans. Moreover, given the difficulties experienced by Long Island Lighting Company in having te replace various contracting entities who withdrew their commitments to assist in an emergency at Shoreham, it is not unlikely that any future applicants who proffer a "utility plan" to support licensing of their facilities w!!i seek, like the App!! cants here, to retain confidentiality for the names of their emergency workers and of M/ In such cases, where State and local governmental entitles support the emergency planning effort, there is little reason *o expect that public disclosure of this type of information will result in harassment, embarassment, or social pressure directed against contructing parties or emergency workers.
Accordingly, in those circumstances there is little need to keep such Information confidential.
persons and entities who commit to provide assistance in the event of an emergency. b The other three criteria set forth in Wolf Creek have also been satisfied by the Applicants.
- Thus, the Aoplicants have held the information in confidence, the information is not available from public sources, and there is a rational basis for holding the information confidential.
With regard to the last of these criteria, it is likely that substantial economic harm could be caused to the Applicants by pub!!c disclosure of the names and addresses of persons and entitles who have entered into contractual arrangements to provide services, equipment or facilities in the event of an emergency at Seabrook, as well as by the disclosure of the names and addresses of SPMC emergency workers.
It is well known that the licensina of Seabrook is a greatly contested issue outside the confines of the hearing room.
As the Board is aware, var lous individuais in the past have engaged in protests and acts of civil disobedience in an oltsmpt to frustrate the Applicants' licensing efforts (Tr. 9742-43).
The Mass AG has not provided any reason to
-15/ The Appeal Board has indicated that the initial burden is on the owner of the allegedly proprietary information to demonstrate that it is of the type customarily held in confidence by the originator, further stating that:
Considerable weight should be accorded the view of the supplier of information that the data he is furnishing is proprietary; and cuch a proprietary designation, while not conclusive, should be overturned only if it is unreasonable in the light of what is customarily held in confidence by an originator, in the latter connection, the staff has stated in its response that the information r
involved herein is of a type "customarily held in confidence by the originator."
Northern States Power Co.
(Monticello Nuclear Generating
- Plant, IJnit 1), ALAB-10, VTT390, 398 (1970).
believe that such actions will not continue in the fu ture, and there may well be some individuals who will seek to disrupt the Applicants' contractual arrangements by attempting to harass, embarass or otherwise apply social pressure on those persons who have agreed to be of service in the event of an emergency: EI Public disclosure of this information may be expected to result in substantial exoense to the Applicants and considerable delay to the conclusion of the proceeding.
Further, public disclosure of the names and identities of contracting parties and of the SPMC emergency workers would constitute an unwarranted invasion of their personal privacy, and could could cause those persons to be exposed to harassment, annoyance and embarassment by persons who are opposed to the plant's licensing. E in light of the potential that substantial economic impact ano an invasion of privacy may result from public disclosure of the information,
-16/ Sec Affidavit of Ted C. Feigenbaum, dated December 30, 1987, and submitted in support of Appilcants' request for confidential treatment of the information submitted therewith to the NRC.
Therein, Mr.
Felgenbaum asserts that providers of services might suffer undo harassment and an invasion of their privacy if their identities were to be disclosed.
Such assertions are supported by events in the Shoreham proceeding, requiring the applicant there to have to renegotiate various letters of agreement for emergency services and resulting in substantial expense and delay in the operating license proceeding.
17/ With respect to the burden placed upon the owner of the information to derronstrate that economic harm is likely to result from disclosure of the information in order to meet the "rational basis" standard, it has been stated that the proponent of a protective order need not show that it wou!d sustain significant commercial injury, but need only make a p_ rim _a facie case showing that it might suffer such injury.
Kansas Gas and Electric Co_. (Wolf Creek Nuclear Generating Station, Onit 1), L B P-7 6-4 2, 4 NRC 580, 591-97 (1976) (dissenting opinion of Judge Kornblith), approved in A LA B-391, 5 N P.C 754, 758 (1977).
any reouest for such disclosure should be denied in the absence of an overriding public need for the information.
See, eg, Monticello, supra, 4 AEC at 398. E in this regard, the Appeal Board has noted that the need for public disclosure could be sharply reduced by providing limited disclosure, such as through the use of protective orders and M camera proceedings.
Id.
Accord _, Commonwealth Edison Co. (Zion Station, Units 1 and 2), A LA B-196, 7 AEC 457 (1974): Wisconsin Electric Power Co.
(Point Beach Nuclear Plant, Unit 2), ALAB-137. 6 AEC 491 (1973).
The temporary protective oraer entered by the Licensing Board affords the Mass AG and other intervenors full disclosure of the information submitted by the Aoplicants for Staff and FEMA review. UI The protective order permits the parties to divulge the information to a reasonable number of persons who agree to the terms of the protective order, and provides an ample opportunity for the intervenors to evaluate and I;tigate the adequacy of these aspects of the SPMC.
While the Mass AC claims that it requires broader distribution of the information in order 18/ The Appeal Board has summari7ed this balancing test as follows:
[lln considering a
request for production of proprietary information, the Licensing Board should weigh the detrimental effects of disclosure against the demonstrated need for production.
Consumers Power Co.(Midland Plant, Units 1 & 2), ALAB-35, 4 AEC 711, 714 (1571).
19/
Information as to the identities of emergency workers v!as not requested by the Staff and FEMA, and was not supplied for Staff and FF.MA review. Should the Board determine that such information is necessary for inspection by the intervenors, the Applicants have suggested that it be subject to a protective order similar to the one whch has been entered by the Board.
See Applicants' Response rt n.1.
The Staff does not oppose that suggestion.
to litigate more effectively (Motion at III), no showing has been made to support that assertion. b Further, even if the Mass AG should later
(
find that it must make broader distribution of the information in order to litigate its case e ffectively, it could then seek to make a specific application to the Board requesting such broader distribution, explaining in detail why its employees and experts are unable to provide sufficient
!itigation assistance.
(
The Mass AG also raises a concern that there may be additional persons who would seek to intervene if they first had access to the protected information (Motion at 12-13).
T his assertion is wholly speculative.
Furthe r,
even if additional persons should wish to intervene, there is no reason why they could not file intervention petitions at this time raising any other concerns they may have, in the event they were to succeed v.ith their petitions, they would then be able to gain access to the protected information under the same terms as the other parties, and could then participate in any litigation concerning the protected informetfor.
Finally, the Mass AG's assertion that "the public has both an interest and a right to know who these responders ulil be in order to 20/ Indeed, it is doubtful that any such showing could be made my the Mass AG.
The Commonwealth of Massachusetts is a sovereign State, with long and substantial experience in emergency p5nning.
The Commonwealth currently has in place emergency response plans for i
use at other nuclear plant sites, and until 1986 participated actively in drafting an emergency plan for use in the Seabrook EPZ.
In the course of its work, the State has doubtless gained considerable expertise in evaluating the adequacy of resources and commitments made by providers of services, equipment and fac!!ities, and may even have detailed knowledge of the capabilitics of the particular providers retained by the Applicants.
judge for itself how adequate the response will be" (Motion at 12), should be rejected.
As discussed in Monticello, supra, the public's interest in full disclosure of matters involved in an adjudicatory licensing proceeding must be balanced against the Applicants' interest in protectina the information.
In this respect, it should 'be noted that virtually all of the SPMC is available for public inspection, and that confidentiality has been sought for only a few discrete portions of the plan.
The availability of this other information, coupled with the fact that a!! of the information has been made available for review and litigation by the Commonwealth of Massachusetts -- with all its expertise in emergency planning ano legal capabilities -- should be sufficient to meet the public's interest in.
disclosure.
Accordingly, a balancing of the App!! cants' and public's interests should be found to weigh against broader disclosure of the information at this time.
CONCLUSION For the reasons set forth above, the Mass AC's Motion should be denied.
Respectfully submitted,
{ d W ct v d. [. [ k c u t h,, f g Edward C. Shomaker gs
..l h 40tw VI Sherwin E. Turk Counsel for NPC Staff Dated at Rockville, MD this 3rd day of March,1988 P
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e The Wormaton ccrsets of P4*es of revowac s*e ot'er Normaton the d3ciceste of *Nch movid reveal oeotities of contceets wees IDEMPTION h0il PART H C-OtNYING OFFICIALS Pursuant to 10 CFR 9 9 and or 9 in of te U $ Woesi Reguietcr, Corivwesen regulatzre. a hos been determined e4t to rermeten wthrend e eierect from production se dectaewre end that rts production or decious e contrary to te putec etar6et The persons remporebe for the Sen.el are those oMrses a$erded below es denyeg of*cean and the Oroctor.
Deveen of Rwles and Recoros. On e of Aomretra'aon, nor any emais that maf be appened to the 12eewwe Dvoctor for Operenoreitoon c
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DENylN(y)FF CIAL TitL10FFict RECORos DEN:ED_
APPE LLAf t OF Fd iAL 3
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I PART H D-APPEAL RIGHTS The denial by each deneng offcal identfed in Put il C may be appealed to the Appenate Off.cial identAed in that sectaon. Any such appeal must be in wert.ng and must be made ethin % days of receipt of this response Appeals must be addressed as appro;nate to the Eiecutrve D. recto? for Operatons or to the Secretary of the Commason. U S. Nuclear Repstory Commiss.on, Wash.ngton OC 20566, and should clearty Jtate on tho envelope and in the letter that at 's an "Appeal from an inet.al FOtA Dawn r
8:RC PCAM ese(Puim U.S. NUCLEAR RECULATO'tY COMMISSION s esi FOIA RESPONSE CONTINUATION
h Re: F01 A. 88-28 a
APPENDIX A
RECORDS TOTALLY WITHHELD NUMBER DATE DESCRIPTION & EXEMPTION The portions of the Public Service Company of New Hampshire's Seabrook Plan for Massachusetts Communities that were not previously made public will continue to be withheld pursuant to Exemption 4.
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000KE1E0 UWitC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'88 MAR 10 P4 :03 BEFORE THE ATOMIC SAFETY AND LICENSING 1%../d.~NDMXhifth.
In the Matter of
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Docket.Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL N EW H AM PS H I R E, g,a_I,.
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Off-site Emergency Planning I
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(Seabrook Station, Units 1 and 2)
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GRTIFICATE OF SERVICE I
hereby certify that copies of " N P, C STAFF'S RESPONSF.
TO THE MASSACHUSETTS ATTORNEY GENERAL"S MOTION TO LIFT TEMPORARY PROTECTIVE ORDER" in the above-captioned proceeding have been served o r, the following by deposit in the United States mall, first class or.
as indicated by an
- asterisk, by deposit in the Nuclea-Regulatory Commission's internal mall svstem, this 3rd day of March 1988.
Ivan W. Smith, Chairman
- Atomic Safety and Licensing Administrative Judge B oa rd
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Gustove A. LMenberger, Jr.*
Docketing and Service Section*
Administrative Judge Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Thomas G. Dignan, Jr., Esq.
Administrative Judge Robert K. Cad, Ill, Esq.
Atomic Safety & Licensing Board Ropes & Gray J
U.S. Nuclear Regulatory Commission 225 Franklin Street Washington. DC 20555 Bouton, MA 02110 i
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Atomic Safety and Licensing H. J. Flynn, Esq.
Appeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Washington, DC 20555 500 C Street, SW Washington, DC 20472
Philip Ahren, Esq.
Calvin A. Canney Assistant Attorney General City Hall Office of the Attorney General 126 Daniel Street State House Station Portsmouth, NH 03801 Augusta, ME 04333 L -
Mr. Angle Machiros, Chairman Carol S. Sneider, Esq.
Board of Selectmen Assistant Attorney General 25 High Road Office of the Attorney General Newbury, MA 09150 One Ashburton Place,19th Floor Boston, MA 02108 George Dana Bisbee, Esq.
Allen Lampert Assistant Attorney General Civil Defense Director Office of the Attorney General Town of Brentwood 25 Capitol Street 20 Franklin Concord, NH 03301 Exeter, NH 03833 Ellyn R. Weiss, Esq.
William Armstrong Diane Curran, Esq.
Civil Defense Director Harmen & Weiss Town oF Exeter 2001 S Street, NW 10 Front Street Suite 430 Exeter, NH 03833 Washington, DC 20009 Robert A. Backus, Esq.
Gary W. Holmes, Esq.
Backus, Meyer & Solomon Holmes & Ellis 116 Lowell Street 47 Winnacunnet Road Manchester. NH 03106 Hampton, NH 03842 Paul McEachern, Esq.
J. P. Nadeau Matthew T. Brock, Esq.
Board of Selectmen Shatnes & McEachern 10 Central Street 25 Maplewood Avenue Rye, NH 03870 l
P.O. Box 360 l
Portsmouth, NH 03801 Judith H. Mizner, Esq.
Charles P. Graham, Esq.
Silvergiate, Gertner, Baker, McKay, Murphy & Graham Fine & Good 100 Main Street 88 Board Street Amesbury, MA 01913 Boston, MA 02110 Sandra Gavutis, Chairman Robert Carrigg, Chairman Board of Selectmen Board of Selectmen RFD #1, Box 1154 Town Office Kensington, NH 03827 Atlantic Avenue North Hampton, NH 03870
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William S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall l
Town ~ Hall - Friend Street Newburyport, MN 09150 Amesbury, MA -01913 A8rs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selectmen Board of Selec.tmen 13-15 Newmarket Road South Hampton, NH 03827 Durham, NH 03824 Hon. Gordon J. Humphrey 8
- United States Senate 531 Hart Senate Office Building Washington, DC 20510 b
MC t,
Sherwin E. Turk Senior Supervisory Trial Attorney i
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